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TMI BlogPermanent establishmentX X X X Extracts X X X X X X X X Extracts X X X X ..... ement; (b) a branch; (c) an office; (d) a factory; (e) a workshop; (f) a warehouse; (g) a mine, quarry or other place of extraction of natural resources; (h) a building site or construction or assembly project or the like which exists for more than 183 days. 3. The term "permanent establishment" shall not be deemed to include: (a) the use of facilities solely for the pur ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... aphs (1) & (2), where a person - other than an agent of an independent status, to whom paragraph (5) applies - is acting in a Contracting State on behalf of an enterprise of the other Contracting State, that enterprise shall be deemed to have a permanent establishment in the first-mentioned State, if (a) he has, and habitually exercises, in the first-mentioned State a general authority to conclu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... commission agent or any other agent of an independent status, where such persons are acting in the ordinary course of their business and their activities do not fall within the scope of paragraph (4)(c) above. 6. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business ..... X X X X Extracts X X X X X X X X Extracts X X X X
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