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of <h1>Understanding Permanent Establishment: DTAA Article 5 Defines Criteria for Business Activities and Exclusions</h1> Article 5 of the Double Taxation Avoidance Agreement (DTAA) between Malaysia and another state defines a 'permanent establishment' as a fixed place of business where an enterprise's activities are conducted. It includes places like management offices, branches, factories, and mines. However, it excludes facilities used solely for storage or delivery, and activities of a preparatory or auxiliary nature. An enterprise may be deemed to have a permanent establishment if it conducts supervisory activities for over nine months related to construction projects. Agents with authority to conclude contracts can also establish a permanent establishment, except when acting independently. Insurance enterprises collecting premiums are similarly deemed to have a permanent establishment. Control by or over a company does not inherently create a permanent establishment.
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