Article 5 - Permanent Establishment

Article 5 defines "Permanent Establishment" (PE) - a fixed place of business through which the business of an enterprise is wholly or partly carried on. India-Bahrain treaty includes: (a) a place of management, (b) a branch, (c) an office, (d) a factory, (e) a workshop, (f) a mine, oil/gas well, quarry, or other place of extraction. A building site or construction project constitutes a PE only if it lasts more than 6 months (India typical) or 12 months (OECD model). Service PE - services rendered through employees physically present for more than 90 days in any 12-month period - is included in most modern India treaties.