TMI BlogPERMANENT ESTABLISHMENTX X X X Extracts X X X X X X X X Extracts X X X X ..... ce 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 place w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n six months within any twelve 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 of a stock of goods or merch ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 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 7 applies - is acting in a Contracting State on behalf of an enterprise of the other Contracting State, that enterprise shall b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ( c ) habitually secures orders in the first-mentioned State, wholly or almost wholly for the enterprise itself. 6. 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 a permanent establishment in the other Contracting State if it collects premiums in the t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 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 provisions legislation, law, enactment, Acts, Rules, Regulations, Taxation Tax Management India - taxmanagementindia - taxmanagement - ..... X X X X Extracts X X X X X X X X Extracts X X X X
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