An enterprise of a. Contracting State shall not be deemed to have a permanent establishment in the other Contracting State merely because it carries on business in that other 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 itself or on behalf of that enterprise and other enterprises controlling, controlled by, or subject to the same common control, as that enterprise, he will not be considered an agent of an independent status within the meaning of this paragraph.
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Samples: Taxation Agreement, Taxation Avoidance Agreement, www.taxsutra.com
An enterprise of a. Contracting State shall not be deemed to have a permanent establishment in the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status 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 itself or on behalf of that enterprise and other enterprises controlling, controlled by, or subject to the same common control, as that enterprise, he will not be considered an agent of an independent status within the meaning of this paragraph.
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Samples: internationaltaxtreaty.com, www.taxsutra.com
An enterprise of a. Contracting State shall not be deemed to have a permanent establishment in the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status provided that status, where such persons are acting in the ordinary course of their business. However, when if the activities of such an agent are devoted carried out wholly or almost wholly on behalf of that for the enterprise itself (or on behalf of that for the enterprise and other enterprises controlling, which are controlled by, by it or have a controlling interest in it or are subject to the same common control, as that enterprise, ) he will shall not be considered to be an agent of an independent status within for the meaning purposes of this paragraph.
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Samples: www.taxsutra.com