TMI BlogPermanent EstablishmentX X X X Extracts X X X X X X X X Extracts X X X X ..... branch; (c) an office; (d) a factory; (e) a workshop; (f) a sales outlet; (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, and (i) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ndise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, 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 th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , would not make this fixed place of business a permanent establishment under the provisions of that paragraph, or (b) has no such authority, but habitually maintains in the first-mentioned State a stock of goods or merchandise from which he regularly delivers goods or merchandise on behalf of the enterprise, or (c) habitually secures orders in the first-mentioned State, wholly or almost who ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... gent are devoted wholly or almost wholly on behalf of that enterprise, he will not be considered an agent of an independent status within the meaning of this paragraph unless the transactions are at arms length. 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 which carries on busine ..... X X X X Extracts X X X X X X X X Extracts X X X X
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