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of <h1>Understanding 'Permanent Establishment' Under DTAA with Ethiopia: Key Criteria and Exceptions Explained</h1> A 'permanent establishment' under the Double Tax Avoidance Agreement (DTAA) with Ethiopia refers to a fixed place of business where an enterprise's activities are conducted. This includes places like management offices, branches, factories, and mines. Construction projects lasting over 183 days or service activities exceeding six months may also qualify. However, facilities used solely for storage, display, or preparatory activities are not considered permanent establishments. An enterprise may have a permanent establishment if a person in a contracting state habitually concludes contracts or maintains a stock of goods on its behalf, unless acting as an independent agent. Control by or over another company does not automatically create a permanent establishment.
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