Permanent establishment: definition, fixed place and agent rules govern when a foreign enterprise creates taxable presence. The provision defines permanent establishment as a fixed place of business and lists typical forms (place of management, branch, office, factory, workshop, extraction sites, installations of a minimum duration, warehouses, and guest farms). It classifies construction and service-provision activities as permanent establishments when they exceed prescribed temporal thresholds. Exclusions cover preparatory or auxiliary activities (storage, display, occasional delivery, stock for processing, purchasing, information collection, or combinations that remain preparatory). Agency rules attribute a permanent establishment to an enterprise when a non-independent agent habitually concludes contracts or maintains delivery stock; independent agents acting in the ordinary course do not create a permanent establishment.