Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding
  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram

TMI Blog

Home

Permanent establishment

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... ment; (b) a branch; (c) an office; (d) a factory; (e) a workshop; (f) a mine, a quarry, an oil field or other place of extraction of natural resources; (g) a farm, plantation or other place where agricultural forestry, plantation or related activities are carried on; (h) a building site or construction or assembly project or supervisory activities in connection therewith, where such site, project .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... nformation or for scientific research being activities solely of a preparatory or auxiliary character in the trade or business of the enterprise. 4. A person acting in a ContractingState for or on behalf of an enterprise of the other ContractingState--other than an agent of an independent status to whom the provisions of paragraph 5 apply--shall be deemed to be a permanent establishment of the ent .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... owever, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise he would not be considered an agent of an independent status within the meaning of this paragraph. 6. The fact that a company, which is a resident of Contracting State controls or is controlled by Company which is a resident of the other Contracting State, or which carries on business in t .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

 

 

 

 

Quick Updates:Latest Updates