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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Understanding 'Permanent Establishment' in Article 5: Key Criteria for Business Activities and Exceptions Explained.</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, including places like branches, offices, factories, and mines. It excludes locations used solely for storage or auxiliary activities. A building site or project qualifies as a permanent establishment if it lasts over nine months. An enterprise is considered to have a permanent establishment if a representative in another state habitually concludes contracts on its behalf, except when acting as an independent agent. Insurance enterprises are deemed to have a permanent establishment if they collect premiums or insure risks in another state. Control by or over another company does not automatically establish a permanent establishment.
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