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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>DTAA Article 5: Defines 'Permanent Establishment' for Businesses, Including Criteria and Exceptions for Operations in Other States.</h1> Article 5 of the Double Tax Avoidance Agreement (DTAA) between Norway and another state defines 'permanent establishment' as a fixed place of business where an enterprise conducts its operations. This includes places like management offices, branches, factories, and mines. It also covers construction projects lasting over three months and service provision exceeding six months. Exceptions to this definition include facilities used solely for storage, display, or auxiliary activities. Furthermore, an enterprise may have a permanent establishment if a person in the other state habitually concludes contracts or maintains a stock of goods for the enterprise. Insurance enterprises are also covered if they collect premiums or insure risks in the other state. Independent agents acting in the ordinary course of their business do not constitute a permanent establishment unless their activities are primarily for the enterprise. The mere control or business relationship between companies in different states does not establish a permanent establishment.
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