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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>DTAA Article 5: Defining 'Permanent Establishment' for Tax Purposes, Including Construction and Service Duration Criteria</h1> Article 5 of the Double Tax Avoidance Agreement (DTAA) defines 'permanent establishment' as a fixed place of business where an enterprise's activities are conducted wholly or partly. It includes places like management offices, branches, factories, and mines. Construction projects lasting over 90 days or service provision exceeding 90 days within a year also qualify. Exclusions include facilities used solely for storage or auxiliary activities. An enterprise is considered to have a permanent establishment if a person in a contracting state habitually concludes contracts or maintains stock for the enterprise. Insurance enterprises collecting premiums or insuring risks in another state also qualify, except through independent agents.
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