TMI BlogPermanent establishmentX X X X Extracts X X X X X X X X Extracts X X X X ..... ce of management ; (b) a branch ; (c) an office ; (d) a factory ; (e) a workshop ; (f) a mine, an oil or gas well, a quary or any other place of extraction of natural resources ; (g) a warehouse in relation to a person providing storage facilities for others ; (h) a farm, plantation or other place where agricultural, forestry, plantation or related activities are carried on ; (i) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d. 3. Notwithstanding the preceding provisions of this article, the term permanent establishment shall be deemd not to include (a) the use of facilities solely for the purpose of storage or display 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 or display ; (c) the ma ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ing the provisions of paragraphs (1) and (2) where a person - other than an agent of an independent status to whom paragraph (5) applies - is acting in a ContractingState on behalf of an enterprise of the other ContractingState, that enterprise shall be deemed to have a permanent establishment in the first-mentioned State, if (a) he has and habitually exercises in that State an authority to con ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 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 agent are devoted wholly or almost wholly on behalf of that enterprise itself or on behalf of that enterprise and other enterprise controlling, controlled by, or subject to the same common control as, that enterprise, ..... X X X X Extracts X X X X X X X X Extracts X X X X
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