Permanent establishment
X X X X Extracts X X X X
X X X X Extracts X X X X
....ce 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 warehouse in relation to a person providing storage facilities for others; (h) a farm, plantation or other place wh....
X X X X Extracts X X X X
X X X X Extracts X X X X
....n that State in connection with the exploration or exploitation of natural resources in that State. 3. Notwithstanding the preceding provisions of this article, the term "permanent establishment" shall be deemed not 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 maintena....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... an independent status to whom paragraph (5) applies, is acting in a Contracting State on behalf of an enterprise of the other Contracting State, that enterprise shall be deemed to have a permanent establishment in the first-mentioned State if (a) he has and habitually exercises in that State an authority to conclude contracts on behalf of the enterprise, unless his activities are l....
TaxTMI