Most treaties contain a list of deemed physical PEs. The Estonian Treaty reflects the OECD Model in this respect:

‘5(2) The term “permanent establishment” includes especially:

(a)a place of management;

(b)a branch;

(c)an office;

(d)a factory;

(e)a workshop;

(f)a mine, an oil or gas well, a quarry or any other place of extraction of natural resources.’

It will immediately be observed that the domestic illustrative list in CTA 2010, s. 1141(2) includes these items.

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