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of <h1>Article 5 of DTAA: Defines 'Permanent Establishment' Including Offices, Branches, and Long-term Projects Over 183 Days</h1> Article 5 of the Double Taxation Avoidance Agreement (DTAA) between Korea and another contracting state defines 'permanent establishment' as a fixed place of business where an enterprise's activities are conducted. It includes places like management offices, branches, factories, and mines. A construction site or service provision lasting over 183 days also qualifies. Exceptions include facilities used solely for storage or auxiliary activities. An enterprise is deemed to have a permanent establishment if a person in the contracting state habitually concludes contracts or maintains goods for the enterprise. Insurance enterprises collecting premiums in the other state are similarly deemed to have a permanent establishment. Independent agents acting in the ordinary course of business do not create a permanent establishment. Control by a resident company does not automatically establish a permanent establishment.
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