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of <h1>Understanding Permanent Establishment in DTAA: Key Definitions and Exceptions Including Article 5 Guidelines</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 wholly or partly. This includes locations such as management offices, branches, factories, and resource extraction sites. A construction site or project is considered a permanent establishment if it lasts over six months. Certain activities, like storage or auxiliary functions, do not constitute a permanent establishment. An enterprise can have a permanent establishment if a representative has authority to conclude contracts, unless acting as an independent agent. Control between companies does not automatically create a permanent establishment.
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