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of <h1>Understanding Permanent Establishment: Article 5 of UK DTAA Clarifies Business Presence and Exceptions in Contracting States.</h1> Article 5 of the Double Taxation Avoidance Agreement (DTAA) between the UK and another Contracting State defines 'permanent establishment' as a fixed place of business where an enterprise conducts its operations. This includes places like management offices, branches, factories, and construction sites, among others. Certain activities, such as storage or display of goods for preparatory purposes, do not constitute a permanent establishment. Agents with authority to negotiate contracts may establish a permanent presence unless acting independently. Control over a company does not automatically create a permanent establishment. The article specifies conditions under which services and activities create a permanent establishment.
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