Permanent establishment under the Mauritius treaty arises through fixed places, qualifying service presence, or dependent agents.

Permanent establishment means a fixed place through which an enterprise carries on all or part of its business, including specified business locations, qualifying construction or supervisory activities exceeding nine months, and qualifying services exceeding 90 days in a 12-month period. Storage, display, processing, purchasing, information collection, and other preparatory or auxiliary activities are excluded where solely undertaken for those purposes. A dependent agent may create a permanent establishment through habitual contract conclusion or order fulfilment from enterprise-owned stock, while an independent agent ordinarily does not.

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