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: Fixed Business Locations, Contracts, and Agency Roles</h1> The term 'permanent establishment' in a Double Tax Avoidance Agreement (DTAA) refers to a fixed place of business where an enterprise conducts its activities. This includes places like management offices, branches, factories, and sites for resource extraction. Certain activities, such as storage or display of goods, do not constitute a permanent establishment unless they are part of a cohesive business operation. A person acting on behalf of an enterprise may create a permanent establishment if they habitually conclude contracts or maintain a stock of goods. Independent agents are generally excluded unless they act exclusively for related enterprises. Control relationships are defined by ownership thresholds.
TaxTMI 
TaxTMI 
