Artificial avoidance of permanent establishment: treaty options restrict activity-based exemptions and require notifications and anti-fragmentation checks. Article 13 permits Parties to choose Option A or Option B (or neither) to modify Covered Tax Agreement provisions so that listed activities and fixed places used solely for such activities are excluded from permanent establishment status only if those activities, or the overall activity of the fixed place, are of a preparatory or auxiliary character (with Option B preserving treaty text that already so limits an exemption). A listed activity will not be treated as non-PE where the same or closely related enterprise carries on business at the same or another place in the jurisdiction and that place constitutes a PE or the combined activities are not preparatory or auxiliary. Parties may reserve application and must notify the Depositary to effect coverage.