Permanent establishment
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....f management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; (f) a mine, a gas well, a quarry or any other place of extraction of natural resources. 3. The term "permanent establishment" also includes: (a) A building site, a construction, assembly or installation project, or supervisory activities, in connection therewith, but o....
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....ise solely for the purpose of storage or display; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose 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 ....
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....ities which that person undertakes for the enterprise, if such a person: (a) has and habitually exercises in that State an authority to conclude contracts in the name of the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishme....
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....t be deemed to have a permanent establishment in the other Contracting State 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 of th....
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