Permanent establishment definition determines taxable nexus; dependent agents, service projects, and exclusions shape presence rules.

Permanent establishment is a fixed place of business through which an enterprise carries on business, including offices, branches, warehouses and places of extraction; construction, installation or service projects and supervisory activities create a permanent establishment only when they exceed the treaty's duration thresholds, and service provision by personnel gives rise to a permanent establishment only where such activities persist beyond the treaty's specified period. Exclusions cover purely preparatory or auxiliary facilities and independent agents acting in the ordinary course, while dependent agents, insurance premium collection by non-independent persons, and habitual maintenance of stock or order securing activities can create a permanent establishment.

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