TMI BlogPermanent establishmentX X X X Extracts X X X X X X X X Extracts X X X X ..... (a) a 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 ; (g) a warehouse in relation to a person providing storage facilities for others ; (h) a farm, plantation or other place where agriculture, forestry, plantation or related activities are carried o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the term permanent establishment shall be deemed 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 maintenance of a stock of goods or merchandise belonging to the e ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r of machinery or equipment and not continuing for a period exceeding six months. However, the provisions of sub-paragraphs (a) to (g) shall not be applicable where the enterprise maintains any other fixed place of business in the other ContractingState for any purposes other than the purposes specified in the said sub-paragraphs. 4. Notwithstanding the provisions of paragraphs (1) and (2) whe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... prise itself or for the enterprise and other enterprises controlling, controlled by, or subject to the same common control as, that enterprise. 5. An enterprise of a ContractingState shall not be deemed to have a permanent establishment in the other ContractingState merely because it carried on business in that other State through a broker, general commission agent or any other agent of an indep ..... X X X X Extracts X X X X X X X X Extracts X X X X
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