Permanent Establishment

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....t; (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 related activities are carried on; and (i) a mine, an oil or gas well, a quarry or....

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.... 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 of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage or display; (c)  the maintenance of a stock of goods or merchandise belonging to the enterprise solely fo....

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....pendent status to whom paragraph 6 applies - is acting in a Contracting State on behalf of an enterprise of the other Contracting State, that enterprise shall be deemed to have a permanent establishment in the first-mentioned Contracting State in respect of any activities which that person undertakes for the enterprise, if such a person: (a)  has and habitually exercises in that Stat....

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....t 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 that enterprise, he will not be considered an agent of an independent status within the meaning of this paragraph. 7. The fact....