Permanent establishment determines taxable presence when fixed place or dependent agent creates business presence abroad.

Permanent establishment is a fixed place of business through which an enterprise's business is wholly or partly carried on and includes management offices, branches, factories, workshops, extraction sites, farms and extended construction or service projects; furnishing services through personnel for the same or connected projects over a sustained period can also create a permanent establishment. Exclusions cover use of facilities solely for storage, display, delivery, maintenance of stocks for processing, purchasing, or preparatory or auxiliary activities. A non independent agent habitually concluding contracts can create a permanent establishment, while independent agents acting in the ordinary course generally do not.

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