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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>'Permanent Establishment' in DTAA with Sri Lanka: Defined as a fixed place of business, excludes storage-only facilities.</h1> The term 'permanent establishment' in the context of the Double Tax Avoidance Agreement (DTAA) with Sri Lanka refers to a fixed place of business where an enterprise's activities are conducted. This includes places like management offices, branches, factories, and construction sites lasting over 183 days. It excludes facilities used solely for storage, display, or auxiliary activities. Agents concluding contracts on behalf of an enterprise or insurance companies collecting premiums may also constitute a permanent establishment unless acting independently. Control relationships between companies in different states do not automatically create a permanent establishment.
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