Permanent establishment: fixed place of business creates tax nexus where an enterprise conducts commercial activities through it. A permanent establishment is a fixed place of business through which an enterprise's business is wholly or partly carried on, with explicit examples and a time-based rule for construction and extraction sites. Exclusions cover facilities used solely for storage, display, delivery, stock for processing, purchasing, information collection, or other preparatory or auxiliary activities. An enterprise is deemed to have a permanent establishment if a non-independent person habitually has authority to conclude binding contracts for the enterprise, while independent agents acting in the ordinary course of business 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: fixed place of business creates tax nexus where an enterprise conducts commercial activities through it.
A permanent establishment is a fixed place of business through which an enterprise's business is wholly or partly carried on, with explicit examples and a time-based rule for construction and extraction sites. Exclusions cover facilities used solely for storage, display, delivery, stock for processing, purchasing, information collection, or other preparatory or auxiliary activities. An enterprise is deemed to have a permanent establishment if a non-independent person habitually has authority to conclude binding contracts for the enterprise, while independent agents acting in the ordinary course of business do not create a permanent establishment.
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