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of <h1>Understanding 'Permanent Establishment' in Germany's DTAA: Key Business Locations and Exclusions Explained</h1> The term 'permanent establishment' in the context of the Double Taxation Avoidance Agreement (DTAA) with Germany refers to a fixed place where an enterprise conducts business, such as a place of management, branch, office, factory, or construction site lasting over six months. It includes locations for resource extraction and certain service provisions. However, it excludes facilities used solely for storage, display, or auxiliary activities. An enterprise is deemed to have a permanent establishment if a person in a contracting state habitually concludes contracts or maintains a stock of goods for the enterprise. Independent agents do not constitute a permanent establishment. Control between companies does not automatically establish a permanent establishment.
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