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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: Key Criteria and Exclusions for Tax Agreements</h1> Article 5 of the Double Tax Avoidance Agreement defines 'permanent establishment' as a fixed place of business where an enterprise's activities are conducted, either wholly or partly. It includes places like management offices, branches, factories, mines, and construction sites lasting over 183 days. However, it excludes facilities used solely for storage, display, or preparatory activities. A person acting on behalf of an enterprise in another state may establish a permanent establishment if they habitually conclude contracts or maintain stock for the enterprise. Insurance enterprises collecting premiums or insuring risks through non-independent agents are also considered to have a permanent establishment.
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