Permanent establishment defined as fixed place of business establishing taxing nexus, with specific exclusions, agent and service rules. Permanent establishment is a fixed place of business through which an enterprise carries on business, with examples including management, branch, office, factory, workshop, extraction sites and construction projects exceeding a specified duration. Exclusions cover solely preparatory or auxiliary activities such as storage, display, stock maintenance for processing, purchasing, information collection, advertising and research. Deeming rules attribute a permanent establishment where a local person habitually concludes contracts or maintains stock for regular delivery, where services are furnished through personnel for an aggregate period, and where insurers collect premiums or insure risks via non independent representatives; independent agents acting in the ordinary course do not create a permanent establishment.
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 defined as fixed place of business establishing taxing nexus, with specific exclusions, agent and service rules.
Permanent establishment is a fixed place of business through which an enterprise carries on business, with examples including management, branch, office, factory, workshop, extraction sites and construction projects exceeding a specified duration. Exclusions cover solely preparatory or auxiliary activities such as storage, display, stock maintenance for processing, purchasing, information collection, advertising and research. Deeming rules attribute a permanent establishment where a local person habitually concludes contracts or maintains stock for regular delivery, where services are furnished through personnel for an aggregate period, and where insurers collect premiums or insure risks via non independent representatives; independent agents acting in the ordinary course do not create a permanent establishment.
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