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of <h1>Article 5 of DTAA: Defining Permanent Establishment and Exclusions for Business Operations and Independent Agents</h1> Article 5 of the Double Taxation Avoidance Agreement (DTAA) defines 'permanent establishment' as a fixed place of business where an enterprise's activities are conducted wholly or partly. It includes places like management offices, branches, factories, and mines, among others. Certain activities, such as storage or display of goods, are excluded unless they are of a preparatory or auxiliary nature. A person acting on behalf of an enterprise in a contracting state may create a permanent establishment if they have authority to conclude contracts or maintain stock for delivery. Insurance enterprises collecting premiums or insuring risks in another state are also considered to have a permanent establishment. Independent agents acting in the ordinary course of business do not create a permanent establishment unless their activities are primarily for one enterprise. Control by one company over another does not automatically establish a permanent establishment.
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