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 ... Summary
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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