Permanent establishment: fixed places or dependent agents can create taxable presence when they conduct core business activities. The provision defines permanent establishment as a fixed place of business and lists typical forms that constitute it, including management, branches, offices, warehouses, sales outlets, extraction and construction sites, and service provision through personnel when activities persist for specified periods; it specifies exclusions for purely preparatory or auxiliary functions and storage, sets conditions under which dependent agents create a permanent establishment by concluding contracts, holding delivery stocks, or securing orders, and clarifies that corporate control alone does not constitute 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 places or dependent agents can create taxable presence when they conduct core business activities.
The provision defines permanent establishment as a fixed place of business and lists typical forms that constitute it, including management, branches, offices, warehouses, sales outlets, extraction and construction sites, and service provision through personnel when activities persist for specified periods; it specifies exclusions for purely preparatory or auxiliary functions and storage, sets conditions under which dependent agents create a permanent establishment by concluding contracts, holding delivery stocks, or securing orders, and clarifies that corporate control alone does not constitute a permanent establishment.
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