Permanent Establishment

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....anagement; (b)  a branch; (c)  an office; (d)  a factory; (e)  a workshop; (f)  a store or premises used as a sales outlet; (g)  a warehouse in relation to a person providing storage facilities for others; and (h)  a mine, an oil or gas well, a quarry or any other place of extraction of natural resour....

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....esources constitute a permanent establishment if such activities are carried on for a period or periods exceeding in the aggregate 30 days in any twelve month period. 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 occasional delivery o....

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....ties mentioned in sub-paragraphs (a) to (e), provided that the overall activity of the fixed place of business 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 6 applies - is acting in a Contracting State on behalf of an enterprise o....

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....ehalf of the enterprise; or (c)  habitually secures orders in the first-mentioned State, wholly or almost wholly for the enterprise itself. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided ....