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of <h1>Understanding 'Permanent Establishment': Fixed Business Locations & MLI Modifications on Avoidance Tactics</h1> The term 'permanent establishment' under this Convention refers to a fixed business location where an enterprise conducts its operations, wholly or partly. This includes places like management offices, branches, factories, and sites for resource extraction. Certain activities, such as storage or display of goods, are excluded unless they serve more than a preparatory or auxiliary function. Modifications by the Multilateral Instrument (MLI) address artificial avoidance of permanent establishment status, including contract splitting and commissionaire arrangements. The Convention also clarifies that a company's control over another does not automatically establish a permanent establishment, unless closely related through significant ownership or control.
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