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of <h1>DTAA Article 5: Defines 'permanent establishment' for businesses, with exceptions for storage and auxiliary activities.</h1> Article 5 of the Double Tax Avoidance Agreement (DTAA) between Morocco and another contracting state defines 'permanent establishment' as a fixed place of business where an enterprise conducts its operations. It includes places like branches, offices, factories, and construction sites lasting over eight months. It also considers service provision related to mineral oil extraction as establishing a permanent presence. Exceptions include facilities used solely for storage, display, or auxiliary activities. An enterprise is deemed to have a permanent establishment if a person habitually concludes contracts on its behalf, unless acting as an independent agent. Insurance enterprises collecting premiums in another state also establish a permanent presence. Control by a company in one state over a company in another does not automatically create a permanent establishment.
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