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of <h1>Clarifying 'Permanent Establishment' Under Article 5 of Singapore's Double Taxation Avoidance Agreement: Key Definitions and Exceptions</h1> Article 5 of the Double Taxation Avoidance Agreement (DTAA) between Singapore and another Contracting State defines 'permanent establishment' as a fixed place of business through which an enterprise's business is conducted. It includes locations such as management places, branches, offices, factories, and sites for resource extraction, among others. Certain conditions, such as duration of activities, determine if a site qualifies as a permanent establishment. Exceptions exist for facilities used solely for storage, display, or auxiliary activities. The article also outlines conditions under which agents may or may not create a permanent establishment for an enterprise.
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