https://www.taxtmi.com/acts?id=6047 The Article defines permanent establishment as a fixed place of business (e.g., management, branch, office, factory, warehouse) and treats construction or installation projects as PEs if they exceed six months. Preparatory or auxiliary activities and mere storage, display, purchasing, information collection, or stock maintenance for processing are excluded. A dependent agent with authority to conclude contracts or who maintains stock for regular delivery creates a PE, whereas independent agents acting in the ordinary course of business generally do not; insurance enterprises collecting premiums or insuring risks through non-independent agents are also deemed to have a PE. en-us Sat, 19 Jan 2008 22:45:54 +0530 Tue, 03 Dec 2024 11:20:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=6047 The Article defines permanent establishment as a fixed place of business (e.g., management, branch, office, factory, warehouse) and treats construction or installation projects as PEs if they exceed six months. Preparatory or auxiliary activities and mere storage, display, purchasing, information collection, or stock maintenance for processing are excluded. A dependent agent with authority to conclude contracts or who maintains stock for regular delivery creates a PE, whereas independent agents acting in the ordinary course of business generally do not; insurance enterprises collecting premiums or insuring risks through non-independent agents are also deemed to have a PE. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=6047