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Permanent establishment rules define tax nexus by fixed place, activity thresholds, and dependent agent criteria. The permanent establishment is a fixed place of business through which an enterprise's business is carried on, with examples such as management offices, branches, factories and resource extraction sites. Construction and long-term service provision can create a permanent establishment when they persist beyond specified durations, while preparatory or auxiliary activities (storage, display, processing by others, purchasing, information collection) are excluded. Dependent agents who habitually conclude contracts, maintain delivery stock, or secure orders for the enterprise can create a permanent establishment, whereas independent agents acting in the ordinary course of business do not; insurance collection through non-independent agents is also treated as creating a permanent establishment.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Permanent establishment rules define tax nexus by fixed place, activity thresholds, and dependent agent criteria.
The permanent establishment is a fixed place of business through which an enterprise's business is carried on, with examples such as management offices, branches, factories and resource extraction sites. Construction and long-term service provision can create a permanent establishment when they persist beyond specified durations, while preparatory or auxiliary activities (storage, display, processing by others, purchasing, information collection) are excluded. Dependent agents who habitually conclude contracts, maintain delivery stock, or secure orders for the enterprise can create a permanent establishment, whereas independent agents acting in the ordinary course of business do not; insurance collection through non-independent agents is also treated as creating a permanent establishment.
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