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of <h1>Understanding 'Permanent Establishment' in DTAA: Key Factors and Exclusions for Business Operations Abroad</h1> The term 'permanent establishment' in the context of a Double Tax Avoidance Agreement (DTAA) refers to a fixed place of business where an enterprise conducts its operations wholly or partly. This includes places such as a management office, branch, factory, or site for natural resource extraction. It can also encompass construction projects lasting over six months. However, it excludes facilities used solely for storage, display, or research, and activities conducted through independent agents. A company's control over another does not automatically establish a permanent establishment. Activities by dependent agents who conclude contracts or maintain stock for the enterprise may constitute a permanent establishment.
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