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Permanent Establishment

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..... an 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 ) A building site or .....

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..... ods 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 maintenance of a stock of goods or merchandise belonging to 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 .....

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..... med 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 a person: ( a ) has and habitually exercises in that State an authority to conclude contracts in the name of the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through .....

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..... 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. 7. 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 th .....

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