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Permanent Establishment: Storage, Display, Delivery in Spain-Singapore Double Taxation Agreement (DTA) | Bestar Permanent Establishment: Storage, Display, Delivery in Spain-Singapore Double Taxation Agreement (DTA) Under Article 5 (Permanent Establishment) of the Spain-Singapore Double Taxation Agreement (DTA), a fixed place of business used solely for the storage, display, or delivery of goods belonging to the enterprise does not constitute a PE. This is a standard negative