Permanent establishment

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....ly : (a) a place of 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 building site or construction or assembly project, but only where such site, project or activity continues for a period or peri....

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....pose of processing by another enterprise ; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise, or of collecting information, for the 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. Notwiths....

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.... agent of an independent status provided 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 contr....