TaxTMI 
TaxTMI 
Permanent establishment
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.... include : (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; (f) a mine, a quarry, an oil or gas well or other place of extraction of natural resources; (g) a farm, plantation or other place where agricultural, forestry, plantation or related activities are ....
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....ll be deemed not to include : (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the e....
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....manent establishment in the first-mentioned Contracting State, if : (a) he has and habitually exercises in the first-mentioned ContractingState, an authority to conclude contracts for or on behalf of the enterprise, unless his activities are limited to the purchase of goods or merchandise for the enterprise; (b) he habitually maintains in the first-mentioned Contracting State a sto....
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....cribed in paragraph 4 wholly or almost wholly for the enterprise itself or for the enterprise and other enterprises which are controlled by it or have a controlling interest in it. 6. The fact that a company, which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other Contracting....