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of <h1>Clarifying 'Permanent Establishment' in Ukraine's DTAA: Fixed Business Sites and Dependent Agents Defined, Exceptions Highlighted.</h1> The term 'permanent establishment' under the Double Tax Avoidance Agreement (DTAA) between Ukraine and another contracting state refers to a fixed place of business where an enterprise conducts its operations. This includes places like management offices, branches, factories, and sites for resource extraction, among others. Certain activities, such as storage or display of goods, do not constitute a permanent establishment if they are preparatory or auxiliary. An enterprise may also have a permanent establishment if it conducts business through a dependent agent with authority to conclude contracts. Independent agents do not create a permanent establishment unless their activities are primarily for the enterprise. Control relationships between companies do not automatically create a permanent establishment.
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