https://www.taxtmi.com/acts?id=45378 Article 5 defines permanent establishment as a fixed place of business and enumerates typical forms (place of management, branch, office, factory, workshop, extraction sites, farms, construction sites and sustained service provision by personnel). It excludes facilities or stock maintained solely for storage, display, delivery or processing, and fixed places used only for purchasing, information gathering, or preparatory or auxiliary activities. A dependent agent with authority to conclude contracts creates a permanent establishment, while independent agents acting in the ordinary course of business do not, unless they act almost exclusively for the enterprise. en-us Fri, 18 Oct 2024 12:56:44 +0530 Fri, 18 Oct 2024 12:56:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45378 Article 5 defines permanent establishment as a fixed place of business and enumerates typical forms (place of management, branch, office, factory, workshop, extraction sites, farms, construction sites and sustained service provision by personnel). It excludes facilities or stock maintained solely for storage, display, delivery or processing, and fixed places used only for purchasing, information gathering, or preparatory or auxiliary activities. A dependent agent with authority to conclude contracts creates a permanent establishment, while independent agents acting in the ordinary course of business do not, unless they act almost exclusively for the enterprise. Act-Rules DTAA Fri, 18 Oct 2024 12:56:44 +0530 https://www.taxtmi.com/acts?id=45378