Permanent establishment rules: fixed place, construction and service thresholds determine taxable presence for enterprises under the treaty.

The Article defines permanent establishment as a fixed place of business and lists specific examples; classifies construction sites exceeding twelve months, exploration installations or rigs exceeding six months, and services furnished through personnel aggregating over 90 days in twelve months as PEs. It excludes purely preparatory or auxiliary activities and certain storage or stock functions. Dependent agents with authority to conclude contracts create a PE, independent agents generally do not, and insurance enterprises collecting premiums or insuring risks through non independent agents are treated as having a PE.

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