Permanent Establishment
The term "permanent establishment" is interpreted differently for the various kinds of tax. A permanent establishment within the meaning of value-added tax law is any fixed place of business or installation serving an enterprise's operations. To this extent, the definition of the term as used for value-added tax is the same as for tax on earnings.
However, for value-added tax purposes other requirements have to be met as well. In terms of staff and equipment, the permanent establishment has to have sufficient minimum resources, enabling it to carry out its operations. So from the point of view of value-added tax - other than for purposes of tax on earnings - an installation such as a pipeline or an Internet server does not constitute a permanent establishment, because it does not meet the human resources requirement.
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