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of <h1>Understanding 'Permanent Establishment' in Article 5 of DTAA: Key Definitions and Exceptions</h1> Article 5 of the Double Taxation Avoidance Agreement (DTAA) between Denmark and another contracting state defines 'permanent establishment' as a fixed place of business where an enterprise conducts its operations. This includes places like management offices, branches, factories, and sites for resource extraction. However, certain activities, such as storage or display of goods, purchasing, or advertising, do not constitute a permanent establishment. Additionally, a permanent establishment may be deemed if a representative in the contracting state habitually concludes contracts or maintains a stock of goods for the enterprise. Independent agents acting in the ordinary course of business are generally not considered permanent establishments.
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