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of <h1>Clarifying 'Permanent Establishment' in DTAA: Fixed Business Sites, Exclusions, and Contractual Presence Explained.</h1> The term 'permanent establishment' in the context of the Double Tax Avoidance Agreement (DTAA) refers to a fixed place of business where an enterprise conducts its operations, either wholly or partly. This includes places like a branch, office, factory, or construction site lasting over 183 days. However, facilities used solely for storage, display, or auxiliary activities do not qualify as permanent establishments. An enterprise may also be deemed to have a permanent establishment if a person in a contracting state habitually concludes contracts or maintains stock on its behalf. Independent agents conducting ordinary business activities are excluded from this definition.
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