Permanent establishment

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....management ; (b) a branch; (c) an office; (d) a factory; (e) a workshop; (f) a mine, an oil or gas well, quarry or any other place of extraction of natural resources; (g) a building site or a construction or an assembly project or supervisory activities in connection therewith; but only where such site, project or activ....

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....e enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on for the enterprise, any other activity of a preparatory or auxiliary character. 4. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of independent status to whom paragraph 5 applies is acting on behalf of an enterprise and has, and habitual....

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....ided that such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise, he will not be considered an agent of an independent status within the meaning of this paragraph. 6. The fact that a company, which is a resident of a Contracting State controls or is controlled by a company, ....