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of <h1>Understanding 'Permanent Establishment' Under Article 5 of the Double Tax Avoidance Agreement (DTAA) Explained</h1> Article 5 of the Double Tax Avoidance Agreement (DTAA) defines 'permanent establishment' as a fixed place of business where an enterprise conducts its operations, wholly or partially. It includes places like management offices, branches, factories, and mines. Construction sites or service activities lasting 183 days or more also qualify. Certain activities, such as storage or preparatory tasks, do not constitute a permanent establishment. Agents with authority to conclude contracts or maintain stock can establish a permanent presence unless they act independently. Insurance enterprises collecting premiums or insuring risks in another state are also considered to have a permanent establishment.
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