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PERMANENT ESTABLISHMENT

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..... ( a ) place of management; ( b ) a branch; ( c ) an office; ( d ) a factory; ( e ) a workshop; ( f ) a store or premises used as a sales outlet; ( g ) a warehouse in relation to a person providing storage facilities for others; and ( h ) a mine, an oil or gas well, a .....

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..... n connection with the exploration or exploitation of the sea bed and sub-soil and their natural resources constitute a permanent establishment if such activities are carried on for a period or periods exceeding in the aggregate 30 days in any twelve month period. 4. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: .....

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..... se, 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 resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisio .....

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..... ( 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 wholly for the enterprise itself. 6. An enterprise shall not be deemed to hav .....

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