Permanent Establishment - Specifically Excluded Places

Specifically Excluded Places

Many treaties explicitly exclude from the definition of PE places where certain activities are conducted. Generally, these exclusions do not apply if non-excluded activities are conducted at the fixed place of business. Among the excluded activities are:

  • Ancillary or preparatory activities
  • The use of a storage facility solely for delivery of goods to customers
  • The maintenance of a stock of goods owned by the enterprise solely for purposes of processing by another enterprise (sometimes referred to as toll processing)
  • Purchasing or information gathering activities

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