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of <h1>Clarifying 'Permanent Establishment' in Russia's DTAA: Definition, Exceptions, and Independent Agent Roles</h1> The term 'permanent establishment' in the Double Tax Avoidance Agreement (DTAA) between Russia and another state refers to a fixed place of business where an enterprise conducts its operations. This includes places like management offices, branches, factories, and mines. Certain activities, such as storage or display of goods, do not constitute a permanent establishment. An enterprise may have a permanent establishment if a person in a contracting state acts on its behalf with authority to conclude contracts or secure orders. Independent agents acting in their ordinary course of business do not create a permanent establishment. Control between companies does not inherently establish a permanent establishment.
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