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of <h1>Comprehensive Guidelines Define Permanent Establishment Status for Business Enterprises Under Specific Operational and Temporal Conditions</h1> The statutory provisions define 'permanent establishment' as a fixed business location where an enterprise conducts its operations. It includes places like management offices, branches, factories, and resource extraction sites. The definition specifies a twelve-month threshold for construction or installation projects. Certain activities such as storage, information collection, or preparatory tasks are explicitly excluded from permanent establishment status. The provisions also address agency relationships and clarify that corporate control does not automatically constitute a permanent establishment.
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