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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 mine, an oil or gas well, a quarry or any other place of extraction of natural resources, including an installation or structure used for the exploration or exploitation ; (g) a warehouse or sales outlet ; (h) a farm, plantation or other place where agricultural, forestry, plantation or related activities are carried ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... goods 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, display or delivery ; (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 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... shall be deemed to have a permanent establishment in the first-mentioned State, if this person:- (a) has and habitually exercises in that State an authority to conclude contracts on behalf of the enterprise, unless his activities are limited to the purchase of goods or merchandise for the enterprise ; (b) has no such authority, but habitually maintains in the first-mentioned State a stock of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... greed between independent persons.
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 through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.
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