TMI BlogPermanent establishmentX X X X Extracts X X X X X X X X Extracts X X X X ..... ace of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; (f) a mine, a quarry or any other place of extraction of natural resources; (g) warehouse; and (h) premises used as a sales outlet or for receiving or soliciting orders. 3. The term permanent establishment, also includes (a) a building site, a construction, assembly or installation project or superviso ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... longing 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 purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ctivities of such person are limited to those mentioned in paragraph (4) which, if exercised through a fixed place of business, would not make the fixed place of business a permanent establishment under the provisions of that paragraph; or (b) has no such authority, but habitually maintains in the first-mentioned State a stock of goods or merchandise from which he regularly delivers goods or mer ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... uch an agent are devoted wholly or almost wholly on behalf of that enterprise, he shall not be considered an agent of an independent status within the meaning of this paragraph. 8. The fact that a company which is a resident to 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 t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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