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TMI BlogPermanent EstablishmentX X X X Extracts X X X X X X X X Extracts X X X X ..... ties are carried on. 3. The term permanent establishment also includes: (a) a building site or construction or installation or assembly project, or supervisory activities connected therewith, only if such site, project or activity lasts for more than 12 months, and (b) an installation or structure used for the exploration of natural resources, or supervisory activities connected therewith, or a drilling rig or ship used for the exploration of natural resources, only if such use or activity lasts for 1 [more than 6 months.] 2 [(c) the furnishing of services, including consultancy services, by an enterprise through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (for t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... State and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. Notwithstanding the preceding provisions of this Article, an insurance enterprise of a Contracting State, shall except in regard to re-insurance, be deemed to have a permanent establishment in the other Contrac ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... performing services in the other Contracting State is, during a period of time, associated with another enterprise that performs substantially similar services in that other Contracting State for the same project or for connected projects through one or more individuals who are present and performing such services in that other Contracting State, the first-mentioned enterprise shall be deemed, during that period of time, to be performing services in other Contracting State for that same project or for connected projects through these individuals. For the purpose of the preceding sentence, an enterprise shall be associated with another enterprise if one is controlled directly or indirectly by the other, or both are controlled directly or in ..... X X X X Extracts X X X X X X X X Extracts X X X X
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