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TMI BlogPermanent establishmentX X X X Extracts X X X X X X X X Extracts X X X X ..... (c) an office; (d) a factory; (e) a workshop; (f) a mine, a gas well, a quarry or any other place of extraction of natural resources. 3. The term permanent establishment also includes: (a) A building site, a construction, assembly or installation project, or supervisory activities, in connection therewith, but only where such site, project or activities continue for a period of more than 182 days ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the name of 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, or (b) has no such authority, but habitually maintains in the first-mentioned State a stock of goods or merchandise from wh ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise, he will not be considered an agent of an independent status within the meaning of this paragraph. 8. The fact that a company which is a resident of a Contracting State control ..... X X X X Extracts X X X X X X X X Extracts X X X X
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