Introducing the “In Favour Of” filter in Case Laws.
- ⚖️ Instantly identify judgments decided in favour of the Assessee, Revenue, or Appellant
- 🔍 Narrow down results with higher precision
Try it now in Case Laws →
TaxTMI Login
🚀 New Feature Launched ✕
Just a moment...
Introducing the “In Favour Of” filter in Case Laws.
Try it now in Case Laws →
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' Under Article 5 of DTAA: Criteria and Exceptions Explained</h1> Article 5 of the Double Taxation Avoidance Agreement (DTAA) between two Contracting States defines 'permanent establishment' as a fixed place of business where an enterprise conducts its operations. It includes places such as management locations, branches, offices, factories, workshops, and sites for resource extraction. However, it excludes facilities used solely for storage, display, or auxiliary activities. A permanent establishment is also recognized if a person in one state habitually concludes contracts or maintains stock for the enterprise. Service provision exceeding 91 days or insurance activities in the other state may also establish a permanent establishment, except when conducted through independent agents. Control or ownership between companies in different states does not automatically create a permanent establishment.
TaxTMI 
TaxTMI 
