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of <h1>Definition of 'Permanent Establishment' in Cyprus DTAA: Fixed Business Locations, Excludes Storage; Effective Until March 31, 2017.</h1> The term 'permanent establishment' in the Double Tax Avoidance Agreement (DTAA) with Cyprus (effective until March 31, 2017) refers to a fixed place of business where an enterprise's business is wholly or partly conducted. This includes places like management offices, branches, factories, and mines. However, certain activities, such as storage or auxiliary functions, do not constitute a permanent establishment. An enterprise may also be deemed to have a permanent establishment if a person, excluding independent agents, habitually concludes contracts on its behalf. Control or business operations between companies in different states do not automatically create a permanent establishment.
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