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 store or other sales outlet; (e) a factory; (f) a workshop; (g) a warehouse in relation to a person providing storage facilities for others; (h) a permanent sales exhibition; (i) a mine, a quarry, an oil or gas well, or any ot ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... es are performed within that State for a related enterprise (within the meaning of paragraph 1 of Article 9) for a period or periods aggregating more than 30 days within any twelve-month period. 3. The term "permanent establishment" shall not be deemed to include : (a) the use of facilities solely for the purpose of storage or display of goods or merchandise belonging to the ent ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ss 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 auxilliary character. 4. Notwithstanding the preceding provisions of this article, an insurance enterprise of a Contracting State shall, except in regard to re-insurance, be deemed to have ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... habitually maintains in the first-mentioned Contracting State a stock of goods or merchandise from which he regularly delivers goods or merchandise for or on behalf of the enterprise; or (iii) in so acting, he manufactures or processes in that State for the enterprise goods or merchandise belonging to the enterprise, provided that this provision shall apply only in relation to the goo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other Contracting State (whether through a permanent establishment or otherwise), shall not, of itself, constitute for either company a permanent establishment of the other.] - - statute, statutory provisions legislation, law, enactment, Acts, Rules, Regulations, Taxation Ta ..... X X X X Extracts X X X X X X X X Extracts X X X X
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