https://www.taxtmi.com/acts?id=44814 Article 5 defines permanent establishment as a fixed place of business and lists typical examples. It establishes a >90 day threshold for construction sites and for services furnished by personnel (aggregating periods within 12 months) to create a permanent establishment. It excludes purely preparatory or auxiliary activities, storage or display, stocks for processing, and purchasing or information-gathering premises. Agency rules deem a permanent establishment where a person habitually has authority to conclude contracts, maintains stock for delivery, or habitually secures orders for the enterprise; independent agents acting in the ordinary course do not create a permanent establishment unless devoted almost wholly to the enterprise. Insurance collection through non-independent agents also creates a permanent establishment. en-us Wed, 16 Oct 2024 15:35:43 +0530 Tue, 22 Oct 2024 13:01:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=44814 Article 5 defines permanent establishment as a fixed place of business and lists typical examples. It establishes a >90 day threshold for construction sites and for services furnished by personnel (aggregating periods within 12 months) to create a permanent establishment. It excludes purely preparatory or auxiliary activities, storage or display, stocks for processing, and purchasing or information-gathering premises. Agency rules deem a permanent establishment where a person habitually has authority to conclude contracts, maintains stock for delivery, or habitually secures orders for the enterprise; independent agents acting in the ordinary course do not create a permanent establishment unless devoted almost wholly to the enterprise. Insurance collection through non-independent agents also creates a permanent establishment. Act-Rules DTAA Wed, 16 Oct 2024 15:35:43 +0530 https://www.taxtmi.com/acts?id=44814