1. Introduction 

Art. 5(1) of the contemporary tax treaties defines a “permanent establishment” as a fixed place of business, through which the business of an enterprise is wholly or partly carried on. Thus, as a prerequisite for existence of a permanent establishment under Art. 5(1) of a tax treaty, the enterprise’s place of business in the source state must be ‘fixed’. But, in that context, how the term ‘fixed’ must be interpreted? That is a rather complex and extensively litigated aspect. That is evident from the discussion in this article on the important judicial precedents from France, the Netherlands, and Norway.