Permanent establishment: definition, exclusions, and agency attribution determining when cross-border business creates taxable presence under a tax treaty.

The provision defines permanent establishment as a fixed place of business through which an enterprise carries on business and lists typical examples; it prescribes exclusions for purely storage, display, occasional delivery, stockholding for processing, purchasing or information gathering activities, and preparatory or auxiliary functions. It further provides that an enterprise is deemed to have a permanent establishment where a person acting on its behalf habitually concludes contracts or maintains a stock for regular delivery, while independent agents acting in the ordinary course of business are excluded; corporate control alone does not create a permanent establishment.

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