https://www.taxtmi.com/acts?id=5747 Article 5 defines permanent establishment as a fixed place of business and enumerates specific forms (management, branch, office, factory, workshop, sales outlet, warehouses, farms, extraction installations) and activity and time based thresholds that convert temporary sites or services into a permanent establishment. It excludes purely preparatory or auxiliary facilities (storage, display, purchasing, information collection, processing by another enterprise) and provides agency rules: dependent agents with authority to conclude contracts or maintaining delivery stocks create a permanent establishment, while independent agents acting in the ordinary course of business do not, unless they act almost exclusively for the enterprise. en-us Sat, 19 Jan 2008 22:45:54 +0530 Thu, 19 Dec 2024 13:13:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5747 Article 5 defines permanent establishment as a fixed place of business and enumerates specific forms (management, branch, office, factory, workshop, sales outlet, warehouses, farms, extraction installations) and activity and time based thresholds that convert temporary sites or services into a permanent establishment. It excludes purely preparatory or auxiliary facilities (storage, display, purchasing, information collection, processing by another enterprise) and provides agency rules: dependent agents with authority to conclude contracts or maintaining delivery stocks create a permanent establishment, while independent agents acting in the ordinary course of business do not, unless they act almost exclusively for the enterprise. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5747