https://www.taxtmi.com/acts?id=44846 The Article defines permanent establishment as a fixed place of business including management, branch, office, factory, workshop or extraction sites, and treats construction or installation projects as a permanent establishment only if they exceed a temporal threshold. It lists exclusions for storage, stockholding for delivery or processing, purchasing or information-gathering, and preparatory or auxiliary activities, including combinations that remain preparatory or auxiliary. The Article further deems an enterprise to have a permanent establishment where a dependent agent habitually concludes contracts, maintains delivery stock, or secures orders almost exclusively, while excluding agents of independent status acting in the ordinary course. Corporate control alone does not create a permanent establishment. en-us Wed, 16 Oct 2024 15:51:59 +0530 Tue, 22 Oct 2024 15:09:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=44846 The Article defines permanent establishment as a fixed place of business including management, branch, office, factory, workshop or extraction sites, and treats construction or installation projects as a permanent establishment only if they exceed a temporal threshold. It lists exclusions for storage, stockholding for delivery or processing, purchasing or information-gathering, and preparatory or auxiliary activities, including combinations that remain preparatory or auxiliary. The Article further deems an enterprise to have a permanent establishment where a dependent agent habitually concludes contracts, maintains delivery stock, or secures orders almost exclusively, while excluding agents of independent status acting in the ordinary course. Corporate control alone does not create a permanent establishment. Act-Rules DTAA Wed, 16 Oct 2024 15:51:59 +0530 https://www.taxtmi.com/acts?id=44846