4.1. Domestic PE of a Foreign Entity
A permanent establishment ('PE') is a place where a person wholly or partly carries on a business, and includes:
- a place where a person wholly or partly carries on a business through an agent, other than a general agent of independent status acting in the ordinary course of business as such;
- a place where a person has, is using, or is installing substantial equipment or substantial machinery;
- one or more places within the country where a person furnishes (whether through employees or otherwise) related services (including technical, professional, or consultancy services) for a period or periods aggregating more than 90 days within any 12-month period; or
- a place where a person is engaged in a construction, assembly, or installation project for 90 days or more, including a place where a person is conducting supervisory activities in relation to such a project