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of <h1>Understanding Permanent Establishment: Key Criteria and Exceptions Under Article 5 of the DTAA</h1> Article 5 of the Double Taxation Avoidance Agreement (DTAA) between two contracting states defines 'permanent establishment' as a fixed place of business where an enterprise's business activities are conducted. It includes places like management offices, branches, factories, and sites for natural resource extraction, among others. A building site or project lasting over 270 days or service provision exceeding 90 days also qualifies. Exceptions include facilities used solely for storage or auxiliary activities. An enterprise is deemed to have a permanent establishment if a person in the state habitually concludes contracts or maintains a stock of goods on its behalf, except when acting through independent agents. Insurance enterprises have a permanent establishment if they collect premiums or insure risks through non-independent agents. Control or ownership between companies does not automatically create a permanent establishment.
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