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of <h1>Understanding Permanent Establishment: Key Points Under Article 5 of the Double Tax Avoidance Agreement (DTAA)</h1> Article 5 of the Double Tax Avoidance Agreement (DTAA) defines 'permanent establishment' as a fixed place of business through which an enterprise operates wholly or partly. It includes places like management offices, branches, factories, and mines. Construction projects lasting over 270 days or service activities exceeding 182 days can also constitute a permanent establishment. Exceptions include facilities used solely for storage, display, or auxiliary activities. An enterprise may have a permanent establishment if a person in the territory habitually concludes contracts or secures orders for it. Insurance enterprises are deemed to have a permanent establishment if they collect premiums or insure risks in the other territory. An independent agent acting in the ordinary course of business does not constitute a permanent establishment. Control by a company in one territory over a company in another does not automatically establish a permanent establishment.
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