TaxTMI Login
Just a moment...
Press 'Enter' to add multiple search terms. Rules for Better Search
of 
of 
No Folders have been created
Are you sure you want to delete "My most important" ?
NOTE:
of of 
All Acts & Rules
of of All Acts & Rules
Note
Bookmark
Share
Don't have an account? Register Here
of <h1>DTAA Article 5: Defining 'Permanent Establishment' for Tax Purposes in Turkmenistan with Key Inclusions and Exclusions.</h1> Article 5 of the Double Taxation Avoidance Agreement (DTAA) between Turkmenistan and another contracting state defines 'permanent establishment' as a fixed place of business where an enterprise conducts its operations wholly or partly. It includes places like management offices, branches, factories, and resource extraction sites. However, certain activities, such as storage or auxiliary functions, do not constitute a permanent establishment. Additionally, if a person in a contracting state habitually concludes contracts or maintains a stock of goods for an enterprise from another state, it may create a permanent establishment. Insurance enterprises collecting premiums or insuring risks also fall under this definition, except when using independent agents. Control or ownership between companies in different states does not automatically establish a permanent establishment.
TaxTMI 
TaxTMI 
