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of <h1>Defining 'Permanent Establishment' in Article 5 of DTAA: Key Structures and MLI Modifications Explained</h1> Article 5 of the Double Taxation Avoidance Agreement (DTAA) defines 'permanent establishment' as a fixed place of business where an enterprise conducts its activities, either wholly or partially. It includes various structures such as management places, branches, offices, factories, and mines, among others. Certain activities, like storage or display, are excluded unless they are not of a preparatory or auxiliary nature. The Multilateral Instrument (MLI) modifies these provisions to prevent artificial avoidance of permanent establishment status. A person is closely related to an enterprise if they have significant control or beneficial interest. Independent agents are generally not considered permanent establishments unless their activities are predominantly for the enterprise.
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