The definition of a "permanent establishment" is a key article of the OECD's model tax treaty. Which of the following would NOT be considered a permanent establishment by the OECD?

Question

Quizplus · Accepted Answer

A permanent establishment typically refers to a fixed place of business through which the business of an enterprise is wholly or partly carried on. While branches, mines, and construction sites can constitute a permanent establishment due to their fixed nature and operational role in business activities, a storage facility, in isolation, is generally not considered a permanent establishment under the OECD model tax treaty. This is because a storage facility is often used merely for the storage, display, or delivery of goods and does not by itself constitute a substantial business presence.

The Definition of a "Permanent Establishment" Is a Key Article