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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Understanding Permanent Establishment in Article 5 of DTAA: Key Criteria and Exceptions for Businesses and Agents</h1> Article 5 of the Double Taxation Avoidance Agreement (DTAA) between two Contracting States outlines the concept of 'permanent establishment,' defining it as a fixed place of business where an enterprise conducts its operations. It includes places like management offices, branches, factories, and mines. Certain activities, such as storage or preparatory tasks, do not constitute a permanent establishment. A construction project or services rendered for more than six months may qualify as a permanent establishment. Agents with authority to conclude contracts or maintain stock for the enterprise also create a permanent establishment unless they are independent. Insurance enterprises collecting premiums in another state are similarly deemed to have a permanent establishment.
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