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Permanent establishment

Article 5 - Agreements - Kazakstan - Article 5 - Article 5 : 1. For the purposes of this Convention, the term "" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "& .....

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elation to a person providing storage facilities for others; and (i) a farm, plantation or other place where agricultural forestry, plantation or related activities are carried on. 3. The term "" also includes: (a) a building site or constr .....

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pervisory activities connected therewith, or a drilling rig or ship used for the exploration of natural resources, only if such use or activity lasts for 1[more than 6 months.] 2[(c) the furnishing of services, including consultancy services, by an e .....

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han 90 days within any twelve-month period.] 4. Notwithstanding the preceding provisions of this Article, the term "" shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or delivery of goods .....

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the enterprise only 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 .....

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in sub-paragraphs (a) to (e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person-other .....

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terprise, that enterprise shall be deemed to have a 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 4 which, if exercised thr .....

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to re-insurance, be deemed to have a in the other Contracting State if it collects premiums in the territory of that other State or it insures risks situated therein through a person other than an agent of an independent status to whom paragraph 7 ap .....

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