Permanent establishment: fixed place of business and dependent agents can create taxable presence under treaty rules. Permanent establishment is a fixed place of business through which an enterprise's business is carried on, including management, branches, offices, factories, warehouses providing storage for others, sales premises, installations for natural resource activities, and certain construction or assembly projects; provision of services or hire of plant for mineral oil prospecting or extraction can also create such establishment. Exclusions apply for facilities used solely for storage, display, stock maintenance for storage or processing by others, purchasing, information gathering, advertising, information supply, scientific research or similar preparatory or auxiliary activities unless another fixed place exists. Dependent agents who habitually conclude contracts, maintain delivery stocks, secure orders predominantly, or manufacture/process for the enterprise create a permanent establishment, while independent agents in the ordinary course of business do not, and corporate control alone is insufficient.