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of <h1>Article 5 of DTAA: Defines 'Permanent Establishment' for Enterprises, Including Exceptions and Agent Roles</h1> Article 5 of the Double Tax Avoidance Agreement (DTAA) between Korea and another contracting state defines 'permanent establishment' as a fixed place of business where an enterprise's activities are conducted. It includes places like management offices, branches, factories, and mines. It also covers construction projects lasting over 183 days and service provision exceeding 183 days within a year. Exceptions include activities solely for storage, display, or auxiliary purposes. Additionally, an enterprise may have a permanent establishment if a dependent agent habitually concludes contracts or maintains stock for the enterprise. Insurance enterprises collecting premiums or ensuring risks in the other state are also considered to have a permanent establishment. Independent agents acting in their ordinary business do not create a permanent establishment unless their activities are primarily for one enterprise under non-standard commercial conditions. Control between companies in different states does not automatically establish a permanent establishment.
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