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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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cultural, 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. The term "" also encompasses: (a) a building site or a construction .....

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tural resources, 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 activi .....

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"" shall be deemed not to include: (a) the use of facilities solely for the purpose of storage or display of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterpris .....

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the purpose 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 auxili .....

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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 7 applies-is acting in a Contracting State on behalf of an enterprise of the ot .....

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an authority to conclude contracts in the name of the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a .....

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ally secures orders in the first-mentioned State, wholly or almost wholly for the enterprise itself. 6. Notwithstanding the preceding provisions of this Article, an insurance enterprise of a Contracting State shall, except in regard to re-insurance, .....

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