9911796707
TMI BlogPERMANENT ESTABLISHMENTX X X X Extracts X X X X X X X X Extracts X X X X ..... 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 extraction of natural resources including timber or other forest produce; (g) a farm or plantation; (h) a sales outlet; (i) a warehouse; (j) a building site or construction, installation or assembly project which exists for more than nine months; 3. Notwi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination 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. 4. An enterprise of a Contracting State shall be deemed to have a p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the purchase of goods or merchandise for the enterprise; or (b) has no such authority, but habitually maintains in the first-mentioned State a stock of goods or merchandise belonging to the enterprise from which he regularly fills orders on behalf of the enterprise; or (c) manufactures or processes in the first-mentioned State for the enterprise goods or merchandise belonging to the enterprise. 6 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e devoted wholly or almost wholly on behalf of that enterprise, such a person shall not be considered an agent of an independent status if the transactions between the agent and the enterprise were not made under arms length conditions. 8. 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 ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
