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of <h1>'Permanent Establishment' in DTAA: Fixed Business Sites Count, Storage Doesn't. Independent Agents Exempt Unless Mainly for Enterprise.</h1> The term 'permanent establishment' in the Double Tax Avoidance Agreement (DTAA) refers to a fixed place of business where an enterprise conducts its operations. It includes places like management offices, branches, factories, and sites for resource extraction. Certain activities, such as storage or display of goods, do not constitute a permanent establishment. An enterprise may have a permanent establishment if a person acts on its behalf with authority to conclude contracts or maintains a stock of goods for regular delivery. Independent agents acting in their ordinary business do not create a permanent establishment unless devoted mainly to the enterprise.
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