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Permanent establishment: fixed place or agent activity can create tax nexus under treaty rules for enterprises. Permanent establishment means a fixed place of business through which an enterprise conducts business, including management, branch, office, factory, workshop and extraction sites; construction or installation projects become permanent establishments when sustained beyond the Convention's duration threshold. Exclusions apply for facilities used solely for storage, display, delivery, purchasing, information collection, processing by another enterprise, or other preparatory or auxiliary activities. Dependent agent activities that authorize contract conclusion, maintain stock for regular delivery, or habitually secure orders can attribute a permanent establishment, while independent agents acting in the ordinary course of business do not.
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: fixed place or agent activity can create tax nexus under treaty rules for enterprises.
Permanent establishment means a fixed place of business through which an enterprise conducts business, including management, branch, office, factory, workshop and extraction sites; construction or installation projects become permanent establishments when sustained beyond the Convention's duration threshold. Exclusions apply for facilities used solely for storage, display, delivery, purchasing, information collection, processing by another enterprise, or other preparatory or auxiliary activities. Dependent agent activities that authorize contract conclusion, maintain stock for regular delivery, or habitually secure orders can attribute a permanent establishment, while independent agents acting in the ordinary course of business do not.
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