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<h1>DTAA Article 5: Defines 'permanent establishment' for businesses with fixed locations or significant activities in Uganda.</h1> Article 5 of the Double Taxation Avoidance Agreement (DTAA) between Uganda and another contracting state defines 'permanent establishment' as a fixed business location where an enterprise's activities are conducted. This includes places like management offices, factories, mines, and construction sites lasting over six months. Certain activities, such as storage or display of goods, do not constitute a permanent establishment. A permanent establishment may also exist if a person habitually concludes contracts or maintains a stock of goods for the enterprise in the contracting state. Insurance enterprises collecting premiums or insuring risks in the other state are also considered to have a permanent establishment. Independent agents acting in the ordinary course of business do not create a permanent establishment unless their activities are almost wholly for the enterprise. Control relationships between companies do not automatically establish a permanent establishment.