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of <h1>Clarifying 'Permanent Establishment' in Swiss Double Tax Avoidance Agreement: Key Definitions and Exclusions Explained</h1> The term 'permanent establishment' under the Double Tax Avoidance Agreement between the Swiss Confederation and another state refers to a fixed place of business where an enterprise's operations are conducted. This includes places like management offices, branches, factories, and mines. It also covers construction projects lasting over six months and certain service activities exceeding specified durations. However, it excludes facilities used solely for storage, display, or preparatory activities. Insurance enterprises collecting premiums or insuring risks in another state are considered to have a permanent establishment. Independent agents acting in the ordinary course of business do not constitute a permanent establishment.
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