TMI BlogPermanent establishmentX X X X Extracts X X X X X X X X Extracts X X X X ..... ; (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 on ; (i) a store or premises used as a sal ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ods aggregating more than 90 days within any twelve-month period ; or (ii) the services are performed within that State for a related enterprise [within the meaning of paragraph 1 of Article 9 (Associated Enterprises)]. 3. Notwithstanding the preceding provisions of this Article, the term permanent establishment shall be deemed not to include any one or more of the following : (a) the use o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y character, for the enterprise. 4. Notwithstanding the provisions of paragraphs 1 and 2, where a personother than an agent of an independent status to whom paragraph 5 applies - is acting in a Contracting State on behalf of an enterprise of the other Contracting State, that enterprise shall be deemed to have a permanent establishment in the first-mentioned State, if : (a) he has and habituall ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of a ContractingState shall not be deemed to have a permanent establishment in the other ContractingState merely because it carries on business in that other State through a broker, general 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 o ..... X X X X Extracts X X X X X X X X Extracts X X X X
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