Permanent establishment rules define when a foreign enterprise creates taxable presence via fixed place or dependent agent. The permanent establishment rule treats a fixed place of business-such as management, branch, office, factory, warehouse, agricultural or extraction sites-as creating taxable presence, with construction or assembly projects treated as permanent only if lasting over six months. Exclusions apply to purely preparatory or auxiliary activities (storage, display, purchasing, information-gathering, or processing by another enterprise). Dependent agents who habitually conclude contracts, maintain delivery stock, or secure orders can create a permanent establishment, while genuinely independent agents acting in the ordinary course of business do not. Insurance activities conducted through non-independent persons also create a permanent establishment.