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of <h1>Clarifying 'Permanent Establishment' in DTAA: Fixed Business Sites, Duration Criteria, and Exceptions Under Article 5</h1> Article 5 of the Double Tax Avoidance Agreement (DTAA) between Cyprus and another contracting state defines 'permanent establishment' as a fixed place of business where an enterprise conducts its activities. This includes places like management offices, branches, factories, and mines. A construction site or service project qualifies as a permanent establishment if it lasts over six months or 90 days, respectively. Exceptions include activities solely for storage, display, or preparatory purposes. An enterprise may have a permanent establishment if a person in the contracting state habitually concludes contracts or maintains stock for the enterprise. Insurance enterprises are considered to have a permanent establishment if they collect premiums or insure risks in the other state. Independent agents do not create a permanent establishment unless their activities are almost exclusively for the enterprise. Control by or of another company does not automatically establish a permanent establishment.
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