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of <h1>Article 5 of DTAA: Defines 'permanent establishment' for tax purposes, excluding auxiliary activities and independent agents.</h1> Article 5 of the Double Taxation Avoidance Agreement (DTAA) between Malta and another Contracting State defines a 'permanent establishment' as a fixed business location where an enterprise conducts its operations, either fully or partially. This includes places like management offices, branches, factories, and mines. However, certain activities, such as storage or auxiliary functions, do not constitute a permanent establishment. The presence of substantial equipment or the authority to conclude contracts in a Contracting State may also establish a permanent establishment. Independent agents and corporate control relationships do not automatically create a permanent establishment.
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