Permanent establishment rules determine when an enterprise's activities or agent create taxable presence under a tax treaty. Permanent establishment defines when an enterprise is treated as carrying on business through a fixed place of business in a Contracting State. It includes places such as management offices, branches, factories, warehouses and installations for natural resources, and applies time based rules for construction sites, supervisory activities, services provided through personnel, and agents who can conclude contracts or maintain stock. Independent agents acting in the ordinary course of business generally do not create a permanent establishment, while preparatory or auxiliary activities are excluded unless another fixed place exists.
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 determine when an enterprise's activities or agent create taxable presence under a tax treaty.
Permanent establishment defines when an enterprise is treated as carrying on business through a fixed place of business in a Contracting State. It includes places such as management offices, branches, factories, warehouses and installations for natural resources, and applies time based rules for construction sites, supervisory activities, services provided through personnel, and agents who can conclude contracts or maintain stock. Independent agents acting in the ordinary course of business generally do not create a permanent establishment, while preparatory or auxiliary activities are excluded unless another fixed place exists.
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