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of <h1>Understanding 'Permanent Establishment' in Article 5 of Belarus Double Tax Avoidance Agreement: Key Inclusions and Exclusions</h1> Article 5 of the Double Tax Avoidance Agreement (DTAA) between Belarus and another state defines 'permanent establishment' as a fixed place of business where an enterprise conducts its activities. This includes places like offices, factories, and mines, as well as construction sites lasting over six months. Exclusions from this definition involve facilities used solely for storage, display, or auxiliary activities. An enterprise can still be deemed to have a permanent establishment if a representative in the other state habitually concludes contracts or maintains a stock of goods for delivery. Insurance enterprises are considered to have a permanent establishment if they collect premiums or insure risks in the other state.
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