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PERMANENT ESTABLISHMENT

Article 5 - Agreement - DTAA - Article 5 - Article 5 1. For the purposes of this Agreement, the term "" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "" inc .....

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ne, an oil or gas well, a quarry or any other place of extraction of natural resources; and (i) a warehouse, in relation to a person providing storage facilities for others. 3. The term "" shall also include: (a) a building site, a construc .....

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vices by an enterprise through employees or other personnel by the enterprise for such purpose, but only where activities of that nature continue (for the same or a connected project) within the Contracting State for a period or periods aggregating m .....

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rchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage or display; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise .....

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place of business solely for the purpose of carrying on, for the enterprise, 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 subparagr .....

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gent of an independent status to whom paragraph 7 applies - is acting in a Contracting State, on behalf of the enterprise of the other Contracting State, the enterprise shall be deemed to have a in the first-mentioned State, if such a person : (a) ha .....

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not make this fixed place of business a under the provisions of that paragraph, or (b) has no such authority, but habitually maintains in the first- mentioned State a stock of goods or merchandise belonging to the enterprise from which he regularly .....

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e enterprise of a Contracting State shall, except in regard to reinsurance, be deemed to have a in the other State if it collects premiums in the territory of that other State or insures risks situated therein through a person other than an agent of .....

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