TMI BlogPermanent establishmentX X X X Extracts X X X X X X X X Extracts X X X X ..... (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) sales outlet; (h) warehouse in relation to a person providing storage facilities for others. 3. The term permanent establishment likewise encompasses a building site, a construction, assembly or installation project or supervi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion, 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 the fixed place of business result ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 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. 6. Notwithstanding the preceding provisions of this Article, an insurance enterprise of a Contracting State shall, exc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... this paragraph. 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 business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other. - - statute, statutory p ..... X X X X Extracts X X X X X X X X Extracts X X X X
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