https://www.taxtmi.com/acts?id=5476 Article 5 defines permanent establishment as a fixed place of business-including management, branch, office, factory, installations for resource extraction, warehouses, farms, sales outlets and building sites-and treats furnishing of services through personnel exceeding an aggregate six months in any 12 month period as a permanent establishment. It excludes purely preparatory or auxiliary uses such as storage, display, processing by another enterprise, purchasing, information gathering, advertising or scientific research, unless the enterprise maintains another fixed place for substantive purposes. A dependent agent with authority to conclude contracts or maintaining stock for regular delivery creates a permanent establishment, while independent agents do not; mere corporate control is insufficient. en-us Sat, 19 Jan 2008 22:45:54 +0530 Sat, 14 Dec 2024 12:52:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5476 Article 5 defines permanent establishment as a fixed place of business-including management, branch, office, factory, installations for resource extraction, warehouses, farms, sales outlets and building sites-and treats furnishing of services through personnel exceeding an aggregate six months in any 12 month period as a permanent establishment. It excludes purely preparatory or auxiliary uses such as storage, display, processing by another enterprise, purchasing, information gathering, advertising or scientific research, unless the enterprise maintains another fixed place for substantive purposes. A dependent agent with authority to conclude contracts or maintaining stock for regular delivery creates a permanent establishment, while independent agents do not; mere corporate control is insufficient. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5476