Permanent establishment rules clarify fixed place, activity exemptions and agent attribution under the DTAA and MLI anti avoidance framework. The document defines permanent establishment as a fixed place of business with enumerated examples, treats construction/assembly projects with temporal aggregation rules, and sets out specific activity exemptions for preparatory or auxiliary functions while imposing anti-avoidance limits when other fixed places or related enterprises' complementary activities render the overall operation non auxiliary. It further provides agency rules deeming certain dependent agents to create a permanent establishment while excluding independent agents acting in the ordinary course, and addresses public entertainers and a definition of closely related persons.
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Provisions expressly mentioned in the judgment/order text.
Permanent establishment rules clarify fixed place, activity exemptions and agent attribution under the DTAA and MLI anti avoidance framework.
The document defines permanent establishment as a fixed place of business with enumerated examples, treats construction/assembly projects with temporal aggregation rules, and sets out specific activity exemptions for preparatory or auxiliary functions while imposing anti-avoidance limits when other fixed places or related enterprises' complementary activities render the overall operation non auxiliary. It further provides agency rules deeming certain dependent agents to create a permanent establishment while excluding independent agents acting in the ordinary course, and addresses public entertainers and a definition of closely related persons.
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