https://www.taxtmi.com/acts?id=44969 The Article defines permanent establishment as a fixed place of business with enumerated examples and treats construction sites and sustained service provision as creating a permanent establishment when they exceed specified durations. It excludes preparatory or auxiliary activities such as storage, display, delivery, maintaining stock for processing, purchasing, or information collection. Dependent agents with contract authority, agents maintaining stock for regular delivery, or those habitually securing orders attribute a permanent establishment to the enterprise, while independent agents acting in the ordinary course of business do not, except where their activities are devoted mainly to the enterprise or commercial relations are non-arm's-length. Insurance enterprises collecting premiums or insuring risks via non-independent persons are similarly attributed a permanent establishment. en-us Wed, 16 Oct 2024 17:31:48 +0530 Tue, 22 Oct 2024 11:39:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=44969 The Article defines permanent establishment as a fixed place of business with enumerated examples and treats construction sites and sustained service provision as creating a permanent establishment when they exceed specified durations. It excludes preparatory or auxiliary activities such as storage, display, delivery, maintaining stock for processing, purchasing, or information collection. Dependent agents with contract authority, agents maintaining stock for regular delivery, or those habitually securing orders attribute a permanent establishment to the enterprise, while independent agents acting in the ordinary course of business do not, except where their activities are devoted mainly to the enterprise or commercial relations are non-arm's-length. Insurance enterprises collecting premiums or insuring risks via non-independent persons are similarly attributed a permanent establishment. Act-Rules DTAA Wed, 16 Oct 2024 17:31:48 +0530 https://www.taxtmi.com/acts?id=44969