Permanent establishment definition limits tax nexus: fixed place, agent activities, and service thresholds determine taxable presence.

Article 5 defines permanent establishment as a fixed place of business through which an enterprise's business is wholly or partly carried on, listing examples such as places of management, branches, offices, factories, workshops, warehouses providing storage, agricultural sites, extraction sites and installations for resource exploration beyond a specified duration. It provides temporal thresholds for construction or service activities to constitute a permanent establishment, enumerates exclusions for preparatory or auxiliary activities and stockholding, and sets agency rules whereby non-independent agents who habitually conclude contracts, maintain stock for deliveries, or secure orders for the enterprise create a permanent establishment. Insurance collection through non-independent agents also creates a permanent establishment, while independent agents acting in the ordinary course do not.

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