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TMI BlogPermanent EstablishmentX X X X Extracts X X X X X X X X Extracts X X X X ..... b) a branch; (c) an office; (d) a factory; (e) a workshop; (f) a warehouse in relation to a person providing storage facilities for others; (g) a farm, plantation or other place where agricultural, forestry, plantation or related activities are carried on; (h) a mine, an oil or gas well, a quarry or any other place of extraction or exploitation of natural resources; and (i) an installation or stru ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... twithstanding the preceding provisions of this Article, the term 'permanent establishment' shall be deemed not to include : (a) the use of facilities solely for the purpose of storage or display of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage or display; (c) the mainten ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er than an agent of an independent status to whom paragraph 7 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 Contracting State in respect of any activities which that person undertakes for the enterprise, if such person : (a) has and habitually exercises i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... permanent establishment in the other Contracting State if it collects premiums in the territory of that other State or insures risks situated therein through a person other than an agent of an independent status to whom paragraph 7 applies. 7. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a bro ..... X X X X Extracts X X X X X X X X Extracts X X X X
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