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of <h1>Understanding 'Permanent Establishment' in Article 5 of DTAA: Key Inclusions and Exclusions Explained</h1> Article 5 of the Double Tax Avoidance Agreement (DTAA) defines 'permanent establishment' as a fixed place of business where an enterprise's business is conducted. This includes management locations, branches, offices, factories, workshops, sales outlets, warehouses, agricultural sites, and extraction sites. It also covers construction projects or service provision lasting over six months. Exclusions include facilities used solely for storage, display, or preparatory activities. Agents with authority to conclude contracts may create a permanent establishment unless they are independent. Control by or over a company in another state does not automatically establish a permanent establishment.
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