https://www.taxtmi.com/acts?id=4994 Article 5 defines permanent establishment as a fixed place of business carrying on an enterprise's activities, listing examples (place of management, branch, office, factory, workshop, extraction sites, farms, and construction sites exceeding six months) and including supervisory activities beyond six months. Exclusions cover solely preparatory or auxiliary activities (storage, display, processing by others, purchasing, information collection, advertising or research). A person habitually concluding contracts or maintaining stocks for regular order fulfilment creates an agency PE, while independent agents acting in the ordinary course of business do not, and insurance enterprises collecting premiums through non-independent representatives create a PE. en-us Sat, 19 Jan 2008 22:45:54 +0530 Wed, 04 Mar 2009 17:59:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4994 Article 5 defines permanent establishment as a fixed place of business carrying on an enterprise's activities, listing examples (place of management, branch, office, factory, workshop, extraction sites, farms, and construction sites exceeding six months) and including supervisory activities beyond six months. Exclusions cover solely preparatory or auxiliary activities (storage, display, processing by others, purchasing, information collection, advertising or research). A person habitually concluding contracts or maintaining stocks for regular order fulfilment creates an agency PE, while independent agents acting in the ordinary course of business do not, and insurance enterprises collecting premiums through non-independent representatives create a PE. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4994