Although some early treaties contain no provision relating to construction sites, building or assembly projects (for example, Jersey and Seychelles), many treaties address this issue. Under domestic law, a building site or construction or installation project is simply included on the illustrative list of deemed fixed places of business.51 This is at variance with the OECD Model and not found in most treaties. The common approach is adopted by art. 5(3) of the Russian Treaty, which reads:

‘5(3) A building site or construction or installation project constitutes a permanent establishment only if it lasts more than twelve months.’

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