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TMI BlogPermanent EstablishmentX X X X Extracts X X X X X X X X Extracts X X X X ..... nt; (b) a branch; (c) an office; (d) a factory; (e) a workshop; (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources; (g) a warehouse, in relation to a person providing storage facilities for others; (h) a farm, plantation or other place where agriculture, forestry, plantation or related activities are carried on; (i) a store or premises used as a sales ou ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eriod; or (ii) the services are performed within that State for a related enterprise (within the meaning of paragraph 1 of Article 9). 3. Notwithstanding the preceding provisions of this Article, the term 'permanent establishment' shall be deemed not to include any one or more of the following: (a) the use of facilities solely for the purpose of storage, display, or occasional delivery of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... a person - other than an agent of an independent status to whom paragraph 5 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 State if: (a) he has and habitually exercises in the first-mentioned State an authority to conclude contracts on behalf of the enterp ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... acting State merely because it carries on business in that other 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, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise and the transactions between the agent and the en ..... X X X X Extracts X X X X X X X X Extracts X X X X
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