Permanent establishment: agency and site activities can create taxable presence where contracts or aggregated project activities establish significant business presence. Permanent establishment is a fixed place of business through which an enterprise's business is carried on, including management offices, branches, factories, warehouses and construction or installation projects that exceed the applicable duration. The MLI modifies duration and aggregation rules for construction sites, tightens exclusions for preparatory or auxiliary activities to prevent artificial avoidance, deems dependent agents who habitually conclude or effectively secure contracts to create a PE, preserves an independent agent exception except where the agent acts almost exclusively for closely related enterprises, and treats insurance premium collection by non independent persons as giving rise to a PE.