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Permanent establishment

Article 5 - Agreements - Kazakstan - Kazakhstan (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 carrie .....

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let; (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 activities are carried on. 3. The term "" also includes: (a) .....

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natural resources, or supervisory 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 cons .....

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eriods aggregating more than 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, disp .....

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merchandise belonging to 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 enterpr .....

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n of activities mentioned 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 an .....

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cts in the name of the enterprise, 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 .....

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, shall except in regard 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 stat .....

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