Permanent establishment is a fixed headquarters from which a non-resident entity practices its activity in whole or in part.

The expression of 'Permanent Establishment' includes -specifically- the following:

1. Management headquarters, branch, store, office, factory, workshop, sales points, warehouse, mine, oil or gas well, quarry, or any other location to explore, extract, and exploit natural resources.

2. Building site, construction project, assembly or installation project, or supervision activities related to such site or projects, provided that such site, project, or activities should continue for more than six months within any twelve months.

3. Providing services by a non-resident entity provided that such activities should continue within the state for a period(s) that exceeds in total of 6 months during any twelve months.

4. An agent, in accordance with the controls and conditions set by the executive regulations.

It is considered a permanent establishment any place of business not covered by the previous provisions, through which a non-resident entity conducts operations in the state, provided that the income attributable to these operations is exempt from taxation in the state or jurisdiction of the non-resident. The executive regulations specify the necessary rules and controls for applying the provisions of this Article.