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PERMANENT ESTABLISHMENT

Article 5 - 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 "" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; (f) a sales outlet; (g) a farm, plantation or other place where agricultural, forestry, plantation or related activities are carried on; (h) a mine, an oil o .....

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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 more than 183 days within any twelve-month period. 4. Notwithstanding the preceding provisions of this Article, the term "" shall be deemed not to include: (a) the use of facilities solely for the purpose of storage or display of goods or merchandise be .....

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siness 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 subparagraphs (a) to (e), provided that the overall activity of M 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 i .....

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