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of <h1>Understanding 'Permanent Establishment' in Model Tax Conventions: Key for Taxing Business Profits in Source State</h1> Article 5 of the Model Tax Conventions outlines the concept of 'Permanent Establishment' (PE), which is crucial for determining tax liability on business profits in a Source State. A PE is defined as a fixed place of business where an enterprise's activities are conducted, including management, branches, offices, factories, and more. Certain activities, like storage or auxiliary functions, do not constitute a PE. Agents concluding contracts may establish a PE unless acting independently. The UN Model includes additional provisions for construction projects and services, differing from the OECD Model. Indian law uses 'Business Connection,' a broader concept than PE, for tax purposes.
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