TaxTMI Login
Just a moment...
Press 'Enter' to add multiple search terms. Rules for Better Search
of 
of 
No Folders have been created
Are you sure you want to delete "My most important" ?
NOTE:
of of 
All Acts & Rules
of of All Acts & Rules
Note
Bookmark
Share
Don't have an account? Register Here
of <h1>Understanding 'Permanent Establishment' in DTAA: Key Definitions and Exceptions for Business Operations and Agents.</h1> The statutory provisions define 'permanent establishment' under a Double Tax Avoidance Agreement (DTAA) as a fixed place of business where an enterprise conducts its operations. This includes places like management offices, branches, factories, and natural resource extraction sites. Certain activities, such as storage or auxiliary functions, do not qualify as a permanent establishment. However, if business activities are conducted in a cohesive manner by related enterprises, they may constitute a permanent establishment. Agents with authority to conclude contracts or maintain stock can also establish a permanent establishment. Independent agents and mere control relationships do not automatically create a permanent establishment.
TaxTMI 
TaxTMI 
