For the purposes of the Corporation Tax Acts1 a company has a permanent establishment in a territory if (and only if):
(1) it has a fixed place of business there through which the business of the company is wholly or partly carried on; or
(2) an agent acting on behalf of the company has and habitually exercises there authority to do business on behalf of the company2.
For this purpose, a 'fixed place of business' includes (without prejudice to the generality of that expression):
(a) a place of management;
(b) a branch;
(c) an office;
(d) a factory;
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