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of <h1>Understanding Permanent Establishment in Article 5 of DTAA with Thailand: Key Definitions and Exclusions</h1> Article 5 of the Double Tax Avoidance Agreement (DTAA) with Thailand defines 'permanent establishment' as a fixed place of business where an enterprise conducts its operations. This includes places like management offices, branches, factories, workshops, sales outlets, and sites for natural resource extraction. It also covers construction projects and service provision lasting over 183 days. However, activities solely for storage, display, processing, purchasing, or auxiliary functions do not constitute a permanent establishment. Agents with authority to conclude contracts or maintain stock for an enterprise may create a permanent establishment unless they are independent agents acting in the ordinary course of business.
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