Permanent establishment
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....ecially (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term permanent establishment likewise encompasses a building site, a construction, assembly or installation project or supervisory activities....
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....dise or for collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of advertising, the supply of information, scientific research or any other activity, if it has a preparatory or auxiliary character in the trade or business of the enterprise; (f) the maintenance of a fixed place if business solely for any combinati....
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.... fixed place of business, would not make this fixed place of business a permanent establishment by virtue of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a ContractingState merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, where such persons are acting in the or....
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