Permanent establishment definition emphasizes fixed place, service and agency thresholds shaping tax nexus. The provision defines permanent establishment as a fixed place of business and enumerates specific examples; it establishes temporal and activity thresholds that create a taxable permanent establishment for construction, supervisory, resource exploitation and service activities. Services furnished through personnel give rise to a permanent establishment when performed for specified aggregate periods or for related enterprises for shorter periods. Exclusions apply to preparatory or auxiliary activities such as storage, display, occasional delivery, purchasing, information gathering, advertising and research, unless the enterprise maintains another fixed place of business in the State. Agency rules attribute a permanent establishment where a representative habitually concludes contracts, maintains stock for delivery, or secures orders predominantly for the enterprise.
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 definition emphasizes fixed place, service and agency thresholds shaping tax nexus.
The provision defines permanent establishment as a fixed place of business and enumerates specific examples; it establishes temporal and activity thresholds that create a taxable permanent establishment for construction, supervisory, resource exploitation and service activities. Services furnished through personnel give rise to a permanent establishment when performed for specified aggregate periods or for related enterprises for shorter periods. Exclusions apply to preparatory or auxiliary activities such as storage, display, occasional delivery, purchasing, information gathering, advertising and research, unless the enterprise maintains another fixed place of business in the State. Agency rules attribute a permanent establishment where a representative habitually concludes contracts, maintains stock for delivery, or secures orders predominantly for the enterprise.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
TaxTMI 
