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of <h1>Understanding 'Permanent Establishment' in Double Tax Avoidance Agreement: Key Criteria and Exclusions Explained</h1> The term 'permanent establishment' in the Double Tax Avoidance Agreement (DTAA) between Austria and another contracting state refers to a fixed place of business where an enterprise conducts its operations. This includes places like management offices, branches, factories, and construction sites lasting over six months. However, certain activities, such as storage or delivery, are excluded. An enterprise is considered to have a permanent establishment if it operates through an agent with authority to conclude contracts or maintains a stock of goods. Insurance enterprises collecting premiums in another state also qualify, barring independent agents. Control between companies does not automatically establish a permanent establishment.
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