Permanent establishment
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....ce of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; (f) a mine, a quarry, an oil field or other place of extraction of natural resources; (g) a farm, plantation or other place where agricultural forestry, plantation or related activities are carried on; (h) a building site or construction or assembly project or supervisory a....
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....nce of a fixed place of business solely for the purpose of advertising, for the supply of information or for scientific research being activities solely of a preparatory or auxiliary character in the trade or business of the enterprise. 4. A person acting in a ContractingState for or on behalf of an enterprise of the other ContractingState--other than an agent of an independent status to whom the....
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....or any other agent of an independent status, where 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 would 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 Contracting State con....


TaxTMI
TaxTMI