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of <h1>Understanding Permanent Establishment: Key Points in Article 5 of the Double Tax Avoidance Agreement (DTAA)</h1> Article 5 of the Double Tax Avoidance Agreement (DTAA) defines 'permanent establishment' as a fixed place of business where an enterprise conducts its activities. This includes places like management offices, branches, factories, and mines. A construction site is considered a permanent establishment if it lasts over six months. Exceptions include facilities used solely for storage or auxiliary activities. A person acting on behalf of an enterprise in another state may create a permanent establishment if they have authority to conclude contracts or maintain goods for delivery. Insurance enterprises collecting premiums in another state also qualify, except for re-insurance. Independent agents do not constitute a permanent establishment unless their activities are primarily for one enterprise. Control between companies across states does not automatically establish a permanent establishment.
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