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[Music] as I mentioned business profits of a resident in the other country are taxable only in a treaty country where the person has a permanent establishment or PE in that treaty country almost all of our treaties define PE and most of them define it the same way a PE is a fixed place of business these are three separate components and well talk about each the treaties almost always include specific things that are always considered a PE and have certain things that are not in themselves considered a PE common inclusions are offices and warehouses if theres business done theyre common exclusions are administrative or research offices where no business is done some treaties deem there to be a PE if certain activities are conducted in the country for a certain length of time often a construction site even a temporary trailer is a PE if the construction lasts more than a year some other period always read the treaty the first key element of PE is that there be something fixed this mea
