Summarised Research with respect to Article 5 (PE) in the below mentioned DTAAs with India

S.
Particulars Denmark Germany Singapore UK USA Cyprus
No.
 The definition of PE is similar in all these treaties.
1. Meaning/Definition  Any fixed place of business through which the business of an enterprise is wholly or partly carried on.
 The Treaties have a narrower definition than the definitions mentioned in respective nation’s taxation laws.

Major Components mentioned in inclusive definition of PE under Article 5(2) of all treaties:
Yes Yes Yes Yes Yes Yes
Place of Management
Yes Yes Yes Yes Yes Yes
Branch or Office
Yes Yes Yes Yes Yes Yes
Factory or workshop
Fixed place solely for the No No No No No No
purpose of purchasing goods
or merchandise
Fixed place solely for the No No No No No No
purpose of maintenance of a
stock of goods
Yes Yes Yes Yes Yes Yes
(If duration more (If duration more (If duration more (If duration (If duration (If duration
Building site or construction
than 183 days) than 6 months) than 183 days in more than 6 more than more than 6
any fiscal year.) months) 120 days) months)
Witholding Tax Rates
(tax charge for Companies/ tax charge for individuals and all other cases)
10% (standard rate is 15%/10% 15%/25%
Dividend
given)
10% 10%/15% 10%/15%
Interest
10% 15%/10% 10%/15%
Royalty
Fee for Technical Services 10% 15%/10% Not covered
(FTS) under DTAA