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of <h1>Understanding 'Permanent Establishment' in DTAA: Fixed Business Locations, MLI Modifications, and Agent Conditions Explained.</h1> The concept of 'permanent establishment' in the Double Tax Avoidance Agreement (DTAA) between the Netherlands and another contracting state refers to a fixed place of business through which an enterprise's business is conducted. This includes places like management offices, branches, factories, and sites for natural resource extraction. Modifications by the Multilateral Instrument (MLI) address contract splitting and specific activity exemptions, specifying that certain preparatory or auxiliary activities do not constitute a permanent establishment. The agreement also outlines conditions under which agents create a permanent establishment and defines closely related enterprises for tax purposes.
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