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of <h1>Serbia's DTAA Article 5: Defines 'Permanent Establishment,' Covers Contract Splitting, Agent Roles, and Closely Related Enterprises.</h1> Article 5 of the Double Tax Avoidance Agreement (DTAA) between Serbia and another contracting state defines 'permanent establishment' as a fixed place of business where an enterprise's activities are conducted wholly or partly. It includes places like management offices, branches, factories, and mines. Modifications by the Multilateral Instrument (MLI) address contract splitting and specific activity exemptions, clarifying when a permanent establishment is not constituted. The article also covers situations involving agents and insurance enterprises, stipulating conditions under which a permanent establishment is deemed to exist. Additionally, it defines the relationship between closely related enterprises and the criteria for independent agents.
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