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4.1. Domestic PE of a Foreign Entity

The definition of a permanent establishment is largely in line with the OECD Model and includes a fixed place of business through which the business of an enterprise is wholly or partly carried on and includes especially: a place of management; a branch; an office; a factory; a workshop, and any place of extraction of natural resources. The definition also includes a permanent representative, being a person who acts on behalf of an enterprise and has, and habitually exercises, an authority to conclude contracts in the name of the enterprise (agency PE).