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of <h1>Understanding 'Permanent Establishment' in Japan DTAA: Fixed Business Sites, Contract Power, and Exclusions Explained</h1> The term 'permanent establishment' in the Double Tax Avoidance Agreement (DTAA) with Japan refers to a fixed place of business where an enterprise conducts its operations. It includes places like management offices, branches, factories, and construction sites lasting over six months. Certain activities, such as storage or auxiliary functions, do not qualify as permanent establishments. An enterprise is deemed to have a permanent establishment if it has a representative in a contracting state who can conclude contracts or maintain a stock for delivery. Independent agents acting in the ordinary course of business do not constitute a permanent establishment. Control between companies does not automatically establish a permanent establishment.
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