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of <h1>Article 5 of DTAA: Defining 'Permanent Establishment' for Tax Purposes, Exclusions, and Agent Activities Explained</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, either wholly or partly. This includes places like management offices, branches, factories, and mines. However, certain activities, such as storage or delivery of goods, are excluded if they are preparatory or auxiliary. A person acting on behalf of an enterprise in another state may also constitute a permanent establishment if they have authority to conclude contracts or maintain a stock of goods. Insurance enterprises are deemed to have a permanent establishment if they collect premiums or insure risks in the other state. Independent agents do not constitute a permanent establishment unless their activities are primarily for one enterprise and not at arm's length. Control or business activities between companies in different states do not automatically create a permanent establishment.
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