Permanent Establishment (PE)
Generally a fixed place of business through which the business of an enterprise, wholly or partly, carries on; based on Article 5, OECD Model Double Taxation Agreement (DTA) [i.e. concept of permanency ]
Includes a place of management, a branch, an office, a factory, a workshop, a mine, a quarry, an oil/gas well, and an agricultural, pastoral or forestry property.
Subsidiary of mult-inational company is a typical PE