TMI BlogPermanent establishmentX X X X Extracts X X X X X X X X Extracts X X X X ..... 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 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 agricultural forestry, plantation or related activiti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... within the Contracting State for a period or periods aggregating more than 90 days within any twelve-month period.] 4. Notwithstanding the preceding provisions of this Article, the term permanent establishment shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maint ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person-other than an agent of an independent status to whom paragraph 7 applies-is acting on behalf of an enterprise of the other Contracting State and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ent status to whom paragraph 7 applies. 7. An enterprise shall not be deemed to have a permanent establishment in a ContractingState merely because it carries on business in that 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 age ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
