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of <h1>Understanding 'Permanent Establishment' Under Article 5 of DTAA: Key Points on Business Activity and Duration Requirements</h1> Article 5 of the Double Taxation Avoidance Agreement (DTAA) defines 'permanent establishment' as a fixed place of business where an enterprise's activities are conducted, wholly or partly. It includes places like management locations, branches, offices, factories, workshops, and sites for natural resource extraction. A construction site or project is considered a permanent establishment if it lasts over six months. Certain activities, such as storage, display, or preparatory tasks, do not constitute a permanent establishment. An enterprise may also have a permanent establishment if a person in one state acts on its behalf with authority to conclude contracts or regularly delivers goods. Independent agents acting in the ordinary course of business do not create a permanent establishment unless transactions are not at arm's length. Control between companies in different states does not automatically establish a permanent establishment.
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