Permanent establishment

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....management; (b)  a branch; (c)  an office; (d)  a factory; (e)  a workshop; (f)  a sales outlet; (g)  a warehouse in relation to a person providing storage facilities for others; (h)  a farm, plantation or other place where agricultural, forestry, plantation or relat....

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....ablishment. 4. 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, 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 ....

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....resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 7 applies - is acting in a territory on behalf of an enterprise of the other territory, that enterprise shall be deemed to have a permanent establishment in the first-mentioned territo....

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....blishment in the other territory if it collects premiums in that other territory or insures risks situated therein through a person other than an agent of an independent status to whom paragraph 7 applies. 7. An enterprise shall not be deemed to have a permanent establishment in a territory merely because it carries on business in that territory through a broker, general commission agent or any....