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of <h1>Article 5 of DTAA: Defining 'Permanent Establishment' in Business, Construction, and Insurance Contexts</h1> Article 5 of the Double Taxation Avoidance Agreement (DTAA) between the Hashemite Kingdom of Jordan and another state defines 'permanent establishment' as a fixed place of business where an enterprise conducts business activities. This includes places like management offices, branches, factories, and mines. A construction project lasting over six months also qualifies. However, certain activities, such as storage or auxiliary functions, do not constitute a permanent establishment. An enterprise is deemed to have a permanent establishment if it has a representative with authority to conclude contracts, except when acting through an independent agent. Insurance enterprises are considered to have a permanent establishment if they collect premiums or insure risks in the other state. Control between companies in different states does not automatically establish a permanent establishment.
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