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of <h1>Article 5 of DTAA: Defines 'Permanent Establishment' and Conditions for Business Activities Across Borders.</h1> Article 5 of the Double Tax Avoidance Agreement (DTAA) defines 'permanent establishment' as a fixed place of business where an enterprise's activities are conducted, including places like a branch, office, factory, or construction site lasting over nine months. It also includes service provision exceeding 90 days within a year. Certain activities, such as storage or display of goods, are excluded. Agents with authority to conclude contracts may establish a permanent establishment unless acting independently. Control or business relations between companies in different states do not automatically create a permanent establishment.
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