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of <h1>Understanding 'Permanent Establishment' in Double Tax Avoidance: Key Criteria and Exclusions Explained</h1> The term 'Permanent Establishment' in the Double Tax Avoidance Agreement refers to a fixed business location where an enterprise's operations are conducted, either wholly or partially. This includes places like a management office, branch, factory, or mine. However, it excludes facilities used solely for storage, display, or processing of goods, or for activities like purchasing or advertising that are preparatory or auxiliary. A person with authority to conclude contracts on behalf of an enterprise may constitute a permanent establishment unless acting independently. Control by or over another company does not automatically create a permanent establishment.
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