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, he or she will not be considered an agent of an independent status within the meaning of this paragraph.
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Samples: Convention for the Avoidance of Double Taxation, Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion, Convention for the Avoidance of Double Taxation
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 where such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly exclusively or almost wholly exclusively on behalf of that enterprise, he or she will not be considered an agent of an independent status within the meaning of this paragraph.
Appears in 2 contracts
Samples: Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion, Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion With Mauritius
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 where 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 or she will not be considered an agent of an independent status within the meaning of this paragraph.when
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Samples: Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion
An enterprise of. a Contracting State shall not be deemed to have a permanent establishment in the other Contracting State merely because it carries carried 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, he or she will not be considered an agent of an independent status within the meaning of this paragraph.are
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