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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 warehouse in relation to a person providing storage facilities for others; (g) premises as sales outlet; (h) farm or other place where agricultural, fo .....

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ces, but only if so used for a period more than 183 days; (c) the furnishing of services, including consultancy services, by an enterprise through employees or other personnel engaged by the enterprise for such purpose, but only if activities of that nature continue (for the same or a connected project) within a Contracting State for a period or periods aggregating more than 91 days within any twelve month period. 4. Notwithstanding the preceding provisions of this Article, the term "" .....

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of purchasing goods or merchandise, or of collecting information, for the enterprise; (e) the maintenance of fixed 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 subparagraphs (a) to (e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory .....

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