Permanent establishment
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....gement; (b) a branch; (c) an office; (d) a factory; (e) a workshop or a warehouse; (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources; (g) an installation or structure, used for the exploration or exploitation of natural resources; (h) the provision of services or facilities in connecti....
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....erm "permanent establishment" shall not be deemed 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 enterprise solely for the purpose of storage or display; (c) the maintenance of a fixed place of business solely f....
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....ng to the enterprise from which the person regularly delivers goods or merchandise on behalf of the enterprise; or (c) he habitually secures orders in the first-mentioned Contracting State, exclusively or almost exclusively, for the enterprise itself, or for the enterprise and other enterprises which are controlled by it or have a controlling interest in it. 5. An enterprise of a Contr....
TaxTMI