TMI BlogPERMANENT ESTABLISHMENTX X X X Extracts X X X X X X X X Extracts X X X X ..... nt 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 warehouse in relation to a person providing storage facilities for others; h) a farm, plantation or other place where agricultural, forestry, plantation or related a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the preceding provisions of this Article, the term permanent establishment shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b)the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or deliv ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 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 other Contracting State, that enterprise shall be deemed to have a permanent establishment in the first-mentioned Contracting State in respect of any activities which that person und ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ng provisions of this Article, an insurance enterprise of a Contracting State shall, except in regard to re-insurance, be deemed to have a permanent establishment 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 independent status to whom paragraph 7 applies. 7. An e ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... controls or is controlled by a company which is a resident of the other Contracting State or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other. - - statute, statutory provisions legislation, law, enactment, Acts, Rules, Regulations, Taxation Tax Manag ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
