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of <h1>Mongolia's DTAA Article 5 Clarifies 'Permanent Establishment' Definition for Tax Purposes, Excluding Certain Activities.</h1> Article 5 of the Double Tax Avoidance Agreement (DTAA) between Mongolia and another contracting state defines 'permanent establishment' as a fixed place of business where an enterprise's business is wholly or partly conducted. It includes places like management offices, branches, factories, and mines. However, certain activities such as storage or auxiliary services do not qualify as a permanent establishment. An enterprise may be deemed to have a permanent establishment if a person with authority to conclude contracts acts on its behalf, unless the activities are limited to non-establishing activities. Independent agents acting in their ordinary course are not considered permanent establishments. Control between companies does not automatically create a permanent establishment.
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