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of <h1>Understanding 'Permanent Establishment' in DTAA: Fixed Business Locations, Contract Authority, and Insurance Activities Explained</h1> The term 'permanent establishment' in the Double Tax Avoidance Agreement (DTAA) between contracting states refers to a fixed place of business where an enterprise's activities are conducted. This includes places like management offices, branches, factories, and mines, among others. Certain activities, such as storage or auxiliary activities, do not constitute a permanent establishment. A person acting on behalf of an enterprise can establish a permanent establishment if they have authority to conclude contracts or maintain stock for regular delivery. Insurance enterprises are deemed to have a permanent establishment if they collect premiums or insure risks in the other state. An independent agent does not create a permanent establishment unless their activities are almost wholly for the enterprise. Control by a company in one state over a company in another does not automatically establish a permanent establishment.
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