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of <h1>Understanding 'Permanent Establishment' in Double Tax Avoidance Agreements: Key Criteria and Exceptions Explained</h1> The term 'permanent establishment' in the context of a Double Tax Avoidance Agreement (DTAA) refers to a fixed place of business where an enterprise's activities are conducted wholly or partly. This includes locations like a place of management, branch, office, factory, workshop, sales outlet, warehouse, farm, or mining site. A construction site or project lasting over 270 days also qualifies. Exceptions include facilities used solely for storage, display, or auxiliary activities. An enterprise may have a permanent establishment if a person in another state habitually concludes contracts or maintains a stock of goods for the enterprise. Insurance enterprises are deemed to have a permanent establishment if they collect premiums or insure risks in another state. Independent agents do not create a permanent establishment unless their activities are almost wholly for the enterprise. Control by a company in one state over another does not automatically create a permanent establishment.
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