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of <h1>Understanding Permanent Establishment: Key Definitions and Exceptions in Article 5 of Kazakhstan's Double Taxation Agreement</h1> Article 5 of the Double Taxation Avoidance Agreement (DTAA) between Kazakhstan and another state defines 'permanent establishment' as a fixed place of business where an enterprise conducts its activities. It includes places like management offices, branches, factories, and mines. Construction projects lasting over 12 months, and certain service activities exceeding 90 days, also qualify. Exceptions include facilities used solely for storage or display. An enterprise is deemed to have a permanent establishment if a person in a contracting state regularly concludes contracts on its behalf, unless acting as an independent agent. Insurance enterprises collecting premiums or insuring risks also qualify, except for re-insurance.
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