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of <h1>Understanding Permanent Establishment: Article 5 of Romania's DTAA Defines Business Presence and Exclusions</h1> Article 5 of the Double Tax Avoidance Agreement (DTAA) between Romania and another contracting state defines 'permanent establishment' as a fixed place of business where an enterprise conducts its operations. It includes places such as management offices, branches, factories, and sites for resource extraction. However, it excludes facilities used solely for storage, display, or preparatory activities. An enterprise may also be deemed to have a permanent establishment if a person in the contracting state habitually concludes contracts or maintains a stock of goods on its behalf. Independent agents acting in the ordinary course of business do not constitute a permanent establishment.
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