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of <h1>Article 5 of DTAA: Defining 'Permanent Establishment' in Business Operations Between Uzbekistan and Contracting States.</h1> Article 5 of the Double Tax Avoidance Agreement (DTAA) between Uzbekistan and another contracting state defines 'permanent establishment' as a fixed place of business where an enterprise's activities are conducted. It includes places like management offices, branches, factories, and mines. However, it excludes facilities used solely for storage, display, or delivery of goods, or activities of a preparatory or auxiliary nature. An enterprise is deemed to have a permanent establishment if a person, not an independent agent, habitually concludes contracts on its behalf. Control by or over another company does not automatically create a permanent establishment.
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