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of <h1>Understanding Article 5: What Defines a Permanent Establishment Under the Double Tax Avoidance Agreement?</h1> Article 5 of the Double Tax Avoidance Agreement (DTAA) defines 'permanent establishment' as a fixed place of business where an enterprise conducts its operations, either wholly or partly. It includes places like management offices, branches, factories, and mines. Certain activities, such as construction projects lasting over 183 days or service provision over 90 days, also qualify as permanent establishments. However, activities solely for storage, display, or auxiliary purposes do not. Agents acting on behalf of an enterprise may create a permanent establishment unless they are independent. Insurance enterprises collecting premiums in another state are also considered to have a permanent establishment.
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