Permanent establishment: criteria for when a foreign enterprise is taxable due to fixed place or agent activities. Permanent establishment is a fixed place of business in which an enterprise's business is wholly or partly carried on, including places such as management offices, branches, factories, mines, farms, warehouses, and construction or assembly projects exceeding nine months; insurance activities creating presence when premiums are collected or risks insured through employees or non-independent representatives; and dependent agent activities where a person habitually concludes contracts or maintains stock to fulfil orders. Preparatory or auxiliary activities, independent agents acting in the ordinary course, and mere control or ownership links do not by themselves create a permanent establishment.
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: criteria for when a foreign enterprise is taxable due to fixed place or agent activities.
Permanent establishment is a fixed place of business in which an enterprise's business is wholly or partly carried on, including places such as management offices, branches, factories, mines, farms, warehouses, and construction or assembly projects exceeding nine months; insurance activities creating presence when premiums are collected or risks insured through employees or non-independent representatives; and dependent agent activities where a person habitually concludes contracts or maintains stock to fulfil orders. Preparatory or auxiliary activities, independent agents acting in the ordinary course, and mere control or ownership links do not by themselves create a permanent establishment.
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