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 sales outlet; ( g ) a warehouse in relation to a person providing storage facilities for others; ( h ) a farm, plantation or other p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... riods aggregating more than six months within any 12-month period. 4. Notwithstanding the preceding provisions of this Article 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 o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e ), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 applies - is acting in a Contracting State on behalf of an enterprise of the other Contracting State ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... enterprise; or ( c ) habitually secures orders in the first-mentioned State, wholly or almost wholly for the enterprise itself. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, pr ..... X X X X Extracts X X X X X X X X Extracts X X X X
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