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of <h1>Understanding 'Permanent Establishment' in Article 5 of DTAA: Key Definitions and Exclusions Explained</h1> Article 5 of the Double Taxation Avoidance Agreement (DTAA) between Australia and another contracting state defines 'permanent establishment' as a fixed place of business where an enterprise's activities are conducted. It includes places such as management offices, branches, factories, workshops, mines, and construction sites lasting over six months. Certain activities, like storage or display, do not constitute a permanent establishment. Agents with authority to conclude contracts can create a permanent establishment unless they act independently. Control by a resident company does not inherently establish a permanent establishment. These principles apply to determine permanent establishments outside the contracting states.
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