Permanent establishment: fixed place or dependent agent activity triggers taxable presence when business activities cross specified duration or control thresholds. Permanent establishment is a fixed place of business through which an enterprise carries on business and includes places such as management offices, branches, factories, warehouses, sales exhibitions, extraction sites, and construction or installation projects subject to duration-based thresholds; certain services rendered through personnel and dependent agent activities that habitually negotiate contracts, hold stock for delivery, or manufacture/process goods in the State also create a permanent establishment, while preparatory or auxiliary activities and independent agents acting in the ordinary course of business do not.
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 or dependent agent activity triggers taxable presence when business activities cross specified duration or control thresholds.
Permanent establishment is a fixed place of business through which an enterprise carries on business and includes places such as management offices, branches, factories, warehouses, sales exhibitions, extraction sites, and construction or installation projects subject to duration-based thresholds; certain services rendered through personnel and dependent agent activities that habitually negotiate contracts, hold stock for delivery, or manufacture/process goods in the State also create a permanent establishment, while preparatory or auxiliary activities and independent agents acting in the ordinary course of business do not.
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