https://www.taxtmi.com/acts?id=51318 A permanent establishment exists where an enterprise carries on business through a fixed place of business, with specific examples and a construction-site/installation project threshold. Exclusions apply to activities of a preparatory or auxiliary character (storage, display, delivery, purchasing, information-gathering), but a fixed place becomes a PE if combined activities cease to be preparatory or auxiliary. Paragraph 4.1 prevents fragmentation across related enterprises. Agency rules deem a PE where a person habitually concludes or principally leads to contract conclusion for the enterprise, except for genuine independent agents; close control affects that assessment. en-us Wed, 21 May 2025 13:09:17 +0530 Thu, 22 May 2025 12:58:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=51318 A permanent establishment exists where an enterprise carries on business through a fixed place of business, with specific examples and a construction-site/installation project threshold. Exclusions apply to activities of a preparatory or auxiliary character (storage, display, delivery, purchasing, information-gathering), but a fixed place becomes a PE if combined activities cease to be preparatory or auxiliary. Paragraph 4.1 prevents fragmentation across related enterprises. Agency rules deem a PE where a person habitually concludes or principally leads to contract conclusion for the enterprise, except for genuine independent agents; close control affects that assessment. Act-Rules DTAA Wed, 21 May 2025 13:09:17 +0530 https://www.taxtmi.com/acts?id=51318