https://www.taxtmi.com/acts?id=14917 arises where an enterprise carries on business through a fixed place in the other Contracting State, including management, branch, office, factory, workshop, sales outlet, warehouse, agricultural or extraction sites, but excluding premises used solely for storage, display, purchasing, processing by others, information collection, or other preparatory or auxiliary activities. Dependent agents with contracting authority, habitual stock maintenance for delivery, or habitually securing orders, service provision by personnel over an aggregated period, construction projects beyond a temporal threshold, and insurance activities through non-independent persons can create a permanent establishment; independent agents and mere cross control do not. en-us Tue, 30 Aug 2011 11:38:14 +0530 Mon, 18 Nov 2024 18:09:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=14917 arises where an enterprise carries on business through a fixed place in the other Contracting State, including management, branch, office, factory, workshop, sales outlet, warehouse, agricultural or extraction sites, but excluding premises used solely for storage, display, purchasing, processing by others, information collection, or other preparatory or auxiliary activities. Dependent agents with contracting authority, habitual stock maintenance for delivery, or habitually securing orders, service provision by personnel over an aggregated period, construction projects beyond a temporal threshold, and insurance activities through non-independent persons can create a permanent establishment; independent agents and mere cross control do not. Act-Rules DTAA Tue, 30 Aug 2011 11:38:14 +0530 https://www.taxtmi.com/acts?id=14917