Permanent establishment through commissionnaire arrangements deemed to arise unless independent agent exception and fixed place test apply.

Where a person in a Contracting Jurisdiction habitually concludes contracts or plays the principal role leading to contracts routinely concluded without material modification by an enterprise, and those contracts are in the enterprise's name, transfer ownership or use rights, or provide services of the enterprise, the enterprise shall be deemed to have a permanent establishment in that jurisdiction, unless those activities would not create a permanent establishment if carried out through a fixed place of business; an independent agent acting in the ordinary course is excluded, but not where acting exclusively or almost exclusively for closely related enterprises.

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