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TMI BlogPermanent EstablishmentX X X X Extracts X X X X X X X X Extracts X X X X ..... office; (d) a factory; (e) a workshop; (f) a sales outlet; (g) a warehouse in relation to a person providing storage facilities for others, (h) a farm, plantation or other place where agricultural, forestry, plantation or related activities are carried on, and (i) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. A building site or construction, instal ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ise; (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; (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs (a) to (e), provided that the overall activity of the fixed place of business resulting from this combination ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... blishment 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 which he regularly delivers goods or merchandise on behalf of the enterprise, or (c) habitually secures orders in the first-mentioned State, wholly or almost wholly for the enterprise itself. 6. Notwithstanding the preceding prov ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e will not be considered an agent of an independent status within the meaning of this paragraph unless the transactions are at arms length. 8. 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 in that other State (whether through a permanent establishment or other ..... X X X X Extracts X X X X X X X X Extracts X X X X
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