Permanent Establishment

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.... in a fiscal year. 3. A building site, construction, installation or assembly project or supervisory activities in connection therewith constitutes a permanent establishment only if it lasts more than nine months. 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 solely for the purpose of storage, display or delivery; c) The maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing ....

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....terprises at the two places, is not of a preparatory or auxiliary character, provided that the business activities carried on by the two enterprises at the same place, or by the same enterprise or closely related enterprises at the two places, constitute complementary functions that are part of a cohesive business operation. 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 of the other Contracting State, that enterprise shall be deemed to have a permanent establishment in the first-mentioned State, if: a) He has and habitually exercises in that State an authority to conclude contr....