https://www.taxtmi.com/acts?id=6019 The Article defines permanent establishment as a fixed place of business through which an enterprise carries on business and lists typical forms (management, branch, office, factory, extraction sites, warehouses, sales premises, and construction or installation projects). It sets temporal triggers-notably projects exceeding six months-and a value linked exception for incidental supervisory activities. Specified exclusions cover purely preparatory or auxiliary activities (storage, display, occasional delivery, purchasing, information collection, advertising, fairs). Agency rules deem an enterprise to have a permanent establishment when a dependent agent habitually concludes contracts, maintains delivery stock, or secures orders; independent agents acting in the ordinary course do not create such presence. Control between related companies alone is insufficient to constitute a permanent establishment. en-us Sat, 19 Jan 2008 22:45:54 +0530 Tue, 03 Dec 2024 10:07:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=6019 The Article defines permanent establishment as a fixed place of business through which an enterprise carries on business and lists typical forms (management, branch, office, factory, extraction sites, warehouses, sales premises, and construction or installation projects). It sets temporal triggers-notably projects exceeding six months-and a value linked exception for incidental supervisory activities. Specified exclusions cover purely preparatory or auxiliary activities (storage, display, occasional delivery, purchasing, information collection, advertising, fairs). Agency rules deem an enterprise to have a permanent establishment when a dependent agent habitually concludes contracts, maintains delivery stock, or secures orders; independent agents acting in the ordinary course do not create such presence. Control between related companies alone is insufficient to constitute a permanent establishment. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=6019