TMI BlogPERMANENT ESTABLISHMENTX X X X Extracts X X X X X X X X Extracts X X X X ..... pecially: (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 place where agricultural, forestry, plantation or related activities are carried on; and (i) a mine, an o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... onnection with the exploration or exploitation of the sea bed and sub-soil and their natural resources, but only 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: (a) the use of facilities so ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lely 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 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 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 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 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 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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