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of <h1>Defining 'Permanent Establishment' in Double Tax Avoidance Agreement: 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 conducts its activities, either wholly or partly. It includes management places, branches, offices, factories, workshops, sales outlets, warehouses, and sites for natural resource extraction. A permanent establishment also encompasses construction projects or service provision lasting over 183 days within a year. Exceptions include activities solely for storage, display, or auxiliary purposes. Agents acting independently do not constitute a permanent establishment unless they act exclusively for closely related enterprises. Control or ownership exceeding 50% defines closely related enterprises.
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