TMI BlogPermanent EstablishmentX X X X Extracts X X X X X X X X Extracts X X X X ..... (a) a place of management; (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 exploration, exploitation or extraction of natural resources; (g) a sales outlet; (h) a warehouse in relation to a person providing storage facilities for others; and (i) a farm, plantation or other place where agricultur ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of facilities solely for the purpose of storage, display or delivery of 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 ente ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 5 which, if exercised through a fixed ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ons 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, he will not be considered an agent of an independent status within the meaning of this paragraph. 9. 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 ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
