CRA considers that “installation should be the main activity” for a project to be an “assembly” or “installation” project PE

CRA considers that the reference in the permanent establishment definition in the Canada-Brazil Treaty to an "assembly project" means essentially the same as the more common reference to "installation project," and interprets this phrase somewhat narrowly, e.g., "installation should be the main activity."

Neal Armstrong.  Summary of 10 January 2014 T.I. 2013-0505911I7 under Treaties – Art. 5.