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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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agricultural, forestry, plantation or related activities are carried on; and (i) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. (a) A building site or construction, installation or assembly project or s .....

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aged by the enterprise for such purpose, but only where activities of that nature continue (for the same or connected project) within the country for a period or periods aggregating more than 90 days within any 12-month period. 4. Notwithstanding the .....

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ods 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 solely for the purpose of processing by another enterprise; (d) the mainte .....

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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 the fixed place of bus .....

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racting State on behalf of an enterprise of the other Contracting State, that enterprise shall be deemed to have a in the first-mentioned Contracting State in respect of any activities which that person undertakes for the enterprise, if such a person .....

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s, would 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 from which he regularly delivers goods or mer .....

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ing State shall, except in regard to re-insurance, be deemed to have a in the other Contracting 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 an independen .....

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