Two of the emerging trends in wireless cellular systems are Device-to-Device (D2D) and Machine-to-Machine (M2M) communications. D2D enables efficient reuse of the licensed spectrum to support localized transmissions, while M2M connections are often characterized by fixed and low transmission rates. D2D connections can be instrumental in localized aggregation of uplink M2M traffic to a more capable cellular device, before being finally delivered to the Base Station (BS). In this paper we show that a fixed M2M rate is an enabler of efficient Machine-Type D2D underlay operation taking place simultaneously with another downlink cellular transmission. In the considered scenario, a BS B transmits to a user U, while there are NM Machine-Type Devices (MTDs) attached to U, all sending simultaneously to U and each using the same rate RM. While assuming that B knows the channel B 􀀀 U, but not the interfering channels from the MTDs to U, we prove that there is a positive downlink rate that can always be decoded by U, leading to zero-outage of the downlink signal. This is a rather surprising consequence of the features of the multiple access channel and the fixed rate RM. We also consider the case of a simpler, single-user decoder at U with successive interference cancellation. However, with single-user decoder, a positive zero-outage rate exists only when NM = 1 and is zero when NM > 1. This implies that joint decoding is instrumental in enabling fixed-rate underlay operation.