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        DTAA

        Article 5 - Permanent Establishment

        Netherlands
        Chapter II
        DEFINITIONS

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        Permanent establishment rules: MLI-modified criteria expand nexus, prevent contract-splitting and specific-activity avoidance, and clarify agency and closely related enterprise tests. The Convention defines permanent establishment as a fixed place of business with listed examples and temporal thresholds for construction or installation projects. MLI modifications aggregate related periods and activities (anti-contract-splitting) and tighten specific-activity exemptions for preparatory or auxiliary functions, while agency and closely related person tests determine when personnel or affiliated enterprises create a PE.
                          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: MLI-modified criteria expand nexus, prevent contract-splitting and specific-activity avoidance, and clarify agency and closely related enterprise tests.

                                The Convention defines permanent establishment as a fixed place of business with listed examples and temporal thresholds for construction or installation projects. MLI modifications aggregate related periods and activities (anti-contract-splitting) and tighten specific-activity exemptions for preparatory or auxiliary functions, while agency and closely related person tests determine when personnel or affiliated enterprises create a PE.


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