Permanent Establishment ('PE') is not defined under the Income Tax Act of Greenland. Generally, Greenland relies on the principles of the OECD model tax treaty for PE determination. Further, domestic law deems business income to be derived from Greenland in the following cases:

income from professional services from a fixed place of business in Greenland, or presence in Greenland for at least 90 consecutive days to provide such services, or participation in such business or entitlement to a share in the revenue, profits, etc. from such business;
income from carrying out shipping or air transport operations in Greenland territory or regular traffic between a location in Greenlandic territory and a location outside Greenland, or participation in such business or are entitlement to a share in the revenue, profits, etc. of such business;
income from prospecting, exploration and exploitation of mineral resources, including seismic surveys, construction of pipelines, utility services and shipping and pipeline transport of recovered hydrocarbons carried out in Greenland, including in Greenlandic territorial waters and the Greenland continental shelf area by enterprises awarded a license under the Greenland Parliament Act on mineral resources and mineral resource activities; or
income from exploration and exploitation of mineral resources, including seismic surveys, construction of pipelines, utility services and shipping and pipeline transport of recovered hydrocarbons work carried out in Greenland, including in Greenlandic territorial waters and the Greenland continental shelf area under specific circumstances.

Some tax treaties concluded by Greenland, such as with Norway, specifically provide for a service PE clause, which requires the physical presence of employees or personnel of the non-resident company for a prescribed period (more than 6 months) in Greenland. Certain tax treaties with countries like Denmark and Iceland do not have a service PE clause.

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