Permanent establishment definition establishes tax nexus for a fixed place of business, with specified exclusions and agent rules.

The provision defines permanent establishment as a fixed place of business including management, branch, office, factory, workshop, extraction sites, and construction or assembly projects exceeding the duration threshold, while excluding facilities used solely for storage, display, delivery, stock held for processing, purchasing or information collection, and preparatory or auxiliary activities. It further provides that a person (other than an independent agent acting in the ordinary course of business) who habitually has authority to conclude contracts on an enterprise's behalf will create a permanent establishment for that enterprise, and that control between related companies does not by itself constitute a permanent establishment.

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