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of <h1>Article 5 DTAA with Namibia: Defines 'Permanent Establishment' and Exclusions for Specific Business Activities and Independent Agents.</h1> Article 5 of the Double Taxation Avoidance Agreement (DTAA) with Namibia defines 'permanent establishment' as a fixed place of business where an enterprise's activities are conducted. It includes places like management offices, branches, factories, and natural resource extraction sites. Certain activities, such as storage or preparatory work, do not constitute a permanent establishment. An enterprise may also have a permanent establishment if a person in a contracting state acts on its behalf with authority to conclude contracts or maintains a stock of goods for regular delivery. Independent agents acting in the ordinary course of business do not create a permanent establishment.
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