9911796707
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 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. The t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ources, but only if such activities are carried on for a period or periods exceeding in the aggregate 30 days in any twelve month period. 4. Notwithstanding 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, display or delivery of goods or merchandise belonging to the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 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 esta ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y for the enterprise itself. 6. 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 broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, where the activities of such an agent are devot ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
