TaxTMI Login
Just a moment...
Press 'Enter' to add multiple search terms. Rules for Better Search
of 
of 
No Folders have been created
Are you sure you want to delete "My most important" ?
NOTE:
of of 
All Acts & Rules
of of All Acts & Rules
Note
Bookmark
Share
Don't have an account? Register Here
of <h1>Article 5 Defines 'Permanent Establishment' in Double Taxation Agreement: Key Criteria and Exclusions Explained</h1> Article 5 of the Double Taxation Avoidance Agreement outlines the concept of 'permanent establishment' as a fixed place of business where an enterprise's activities are conducted wholly or partly. This includes places like management offices, branches, factories, and warehouses. Certain construction projects and service provisions qualify as permanent establishments if they exceed specified durations. However, facilities used solely for storage, display, or preparatory activities do not constitute a permanent establishment. Agents with authority to conclude contracts or maintain stock for delivery may establish a permanent establishment unless they are independent agents acting in the ordinary course of business. Control or ownership between companies does not automatically create a permanent establishment.
TaxTMI 
TaxTMI 
