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; (g) a mine, quarry or other place of extraction of natural resources; (h) a building site or construction or assembly project or the like which exists for more than 183 days. 3. The term permanent establishment shall not be deemed to include: (a) the use of facilities solely for the purposes of storage or ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ere a person - other than an agent of an independent status, to whom paragraph (5) applies - is acting in a ContractingState on behalf of an enterprise of the other ContractingState, 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 a general authority to conclude contracts for or ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... any other agent of an independent status, where such persons are acting in the ordinary course of their business and their activities do not fall within the scope of paragraph (4)(c) above. 6. 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 Sta ..... X X X X Extracts X X X X X X X X Extracts X X X X
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