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of <h1>Defining 'Permanent Establishment' in DTAA Article 5: Key Criteria and Exclusions for Businesses in Poland.</h1> Article 5 of the Double Taxation Avoidance Agreement (DTAA) between Poland and another contracting state defines 'permanent establishment' as a fixed place of business where an enterprise conducts its activities. It includes places like management offices, branches, factories, and construction sites active for over six months. The provision also covers service provision exceeding six months within a 12-month period. Exclusions include facilities used solely for storage, display, or auxiliary activities. An enterprise is deemed to have a permanent establishment if a person in the other state habitually concludes contracts or maintains stock for delivery on its behalf. Independent agents acting in the ordinary course of business do not constitute a permanent establishment. Control between companies in different states does not automatically create a permanent establishment.
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