DT Agreements: South Africa - Income from a UK source paid to a resident of South Africa
Construction Industry Scheme: Permanent establishment provisions
From 6 April 2003: Article 5 of the 2002 convention
The permanent establishment provisions of Article 5 include references to a buildingsite, a construction, assembly or installation project or any supervisory activity inconnection with such site or project. This provides that where such a site or activitycontinues for a period of more than twelve months it will constitute a permanentestablishment.
Before 6 April 2003: Article 4 of the 1969 Convention
The permanent establishment provisions of Article 4 of the 1969 Convention includereferences to a building site or construction or assembly project. This provides thatwhere such a site continued for a period of more than twelve months it constituted apermanent establishment.