Permanent establishment
X X X X Extracts X X X X
X X X X Extracts X X X X
.... management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources; (g) a warehouse in relation to a person providing storage facilities for others; (h) a premises 'used' as a sales outlet or f....
X X X X Extracts X X X X
X X X X Extracts X X X X
....shall be deemed to have a permanent establishment in a Contracting State and to carry on business through that permanent establishment if it provides services or facilities in connection with or supplies plant and machinery on hire used or to be used in, the prospecting for, or extraction or production of mineral oils in the State. 3. Notwithstanding the preceding provisions of this Article, th....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ormation, for scientific research, or for similar activities which have a preparatory or auxiliary character, for the enterprise. However, the provisions of sub-paragraphs (a) to (e) shall not be applicable where the enterprise maintains any other fixed place of business in the other Contracting State for any purposes other than the purposes specified in the said sub-paragraphs. 4. Notwithst....
X X X X Extracts X X X X
X X X X Extracts X X X X
....res orders in the first-mentioned State, wholly or almost wholly for the enterprise itself or for the enterprise and other enterprise controlling, controlled by, or subject to the same common control, as that enterprise; or (d) in so acting, he manufactures or processes in that State for the enterprise goods or merchandise belonging to the enterprise. 5. An enterprise of a Contrac....
TaxTMI