Permanent establishment

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....ially (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 quary 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 where agric....

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....ct) within the country for a period or periods aggregating to more than six months within any 12 months period. 3. Notwithstanding the preceding provisions of this article, the term permanent establishment shall be deemd 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 maintenance ....

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....ce of business in the other ContractingState for any purposes other than the purposes specified in the said sub-paragraphs. 4. Notwithstanding the provisions of paragraphs (1) and (2) where a person - other than an agent of an independent status to whom paragraph (5) applies - is acting in a ContractingState on behalf of an enterprise of the other ContractingState, that enterprise shall be deem....

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....all not be deemed to have a permanent establishment in the other ContractingState merely because it carries on business in that other State through a broker, general commission agent or any other 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 o....