Common use of PERMANENT ESTABLISHMENT Clause in Contracts

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "permanent establishment" also includes: (a) a building site, a construction, installation or assembly project, or supervisory activities connected therewith, but only where such site, project or activities lasts for more than 12 months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 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 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities 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 on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 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 that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this AgreementConvention, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "permanent establishment" also includes:; (ag) a farm of plantation; (h) a warehouse in relation to a person providing storage facilities for others; (i) a building site, a construction, installation or assembly project, or project for supervisory activities connected in connection therewith, but only ,where such site, project or activities lasts continue for a period of more than 12 6 months; (bj) the furnishing of services, services including consultancy services, services by an enterprise a resident of a one of the Contracting State States through employees or other personnel engaged by the enterprise for such purposepersonnel, but only where activities of that nature continue (for the same or a connected project) project within the other Contracting State for a period or periods aggregating more than 183 days in 6 months within any twelve-twelve month period. 43. Notwithstanding the preceding provisions provision 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of activityof a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs subparagraphs (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. 54. Notwithstanding the provisions of paragraphs 1 and 2, 2 where a person - other than an agent of an independent status to whom paragraph 6 applies supplies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name on behalf of the enterpriseenterprise of the other Contracting State, that the enterprise shall be deemed to have a permanent establishment in that State the first mentioned Contracting State, if such a person; (a) has and habitually exercises in respect the first mentioned State, an authority to conclude contracts on behalf of any the enterprise,unless his activities which that person undertakes are limited to the purchase of goods of merchandise for the enterprise; (b) has no such authority, unless but habitually maintains in the activities first mentioned State a stock of goods or merchandise belonging to the enterprise from which he regularly fills orders or makes deliveries on behalf of the enterprise; or (c) has no such person authority, but habitually secures orders in the first mentioned State wholly or almost wholly for the enterprise or for the enterprise and other enterprises which are limited controlled by it or have controlling interest in it. 5. Notwithstanding the preceding provisions of this Article, an insurance enterprise of a Contracting State shall, except in regard to those mentioned in paragraph 4 whichreinsurance, if exercised through a fixed place of business, would not make this fixed place of business be deemed to have a permanent establishment under in the provisions other State if it collects premiums in the territory of that paragraphother State or insures risks situated therein through an employee or through a representative who is not an agent of an independent status within the meaning of paragraph 6 of this Article. 6. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that State other Stat 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 of on behalf of that enterprise and other enterprises, which are controlled by it or have a controlling interest in it, he will not be considered an agent of independent status within the meaning of this paragraph. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether State(whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "permanent establishment" also includes: (a) a A building site, a or construction, assembly, or installation or assembly project, project or supervisory activities connected in connection therewith, but constitutes a permanent establishment only where such site, project or activities if it lasts for more than 12 twelve months;. (b) 4. Notwithstanding the provisions of paragraphs 1, 2 and 3, the term “permanent establishment” also encompasses the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only where if activities of that nature continue (for the same or a connected project) within the other a Contracting State for a period or periods aggregating more than 183 days in within any twelve-month period. 45. 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs (subparagraphs 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. 56. Notwithstanding the provisions of paragraphs 1 and 2, where a person - person-- other than an agent of an independent status to whom paragraph 6 7 applies - -- is acting in a Contracting State on behalf of an enterprise of the other Contracting State, and has, and habitually exercises, in a that Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that Contracting State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 5 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 67. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a 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 will not be considered an agent of an independent status within the meaning of this paragraph. 78. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "“permanent establishment" also includes” likewise encompasses: (a) a building site, a construction, assembly or installation or assembly project, project or supervisory activities connected in connection therewith, but only where such site, project or activities lasts continue for a period of more than 12 months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other engaged personnel engaged by in the enterprise for other Contracting State, provided that such purpose, but only where activities of that nature continue (for the same project or a connected project) within the other Contracting State project for a period or periods aggregating more than 183 days in 6 months within any twelve-12 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 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs subparagraphs (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 - person—other than an agent of an independent status to whom the provisions of paragraph 6 applies - apply—is acting in a Contracting State on behalf of an enterprise and hasof the other Contracting State, and has and habitually exercises, in a Contracting State exercises an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that the first-mentioned Contracting State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other Contracting 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 that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "“permanent establishment" also includes” likewise encompasses: (a) a building site, a construction, assembly or installation or assembly project, project or supervisory activities connected in connection therewith, but only where such site, project or activities lasts continue for a period of more than 12 six months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by in the enterprise for other Contracting State, provided that such purpose, but only where activities of that nature continue (for the same project or a connected project) within the other Contracting State for a period or periods aggregating more than 183 days in six months within any twelve-month period. 4. Notwithstanding the preceding provisions of this Articleparagraphs 1 to 3, 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of for collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs subparagraphs (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 - person—other than an agent of an independent status to whom the provisions of paragraph 6 applies - applies—is acting in a Contracting State on behalf of an enterprise of the other Contracting State and has, and habitually exercises, in a the first-mentioned Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that the first-mentioned Contracting State in respect of any activities which that person undertakes for the enterprise, unless the his activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this that fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other Contracting 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 that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other Contracting State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "“permanent establishment" also includes” likewise encompasses: (a) a building site, a construction, assembly or installation or assembly project, project or supervisory activities connected therewith, in connection therewith but only where such site, project or activities lasts continue for a period of more than 12 six months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by in the enterprise for other Contracting State, provided that such purpose, but only where activities of that nature continue (for the same project or a connected project) within the other Contracting State project for a period or periods aggregating more than 183 days in six months within any twelve-twelve month period. 4. Notwithstanding the preceding provisions of this Articleparagraphs 1 to 3, 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities 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 - person—other than an agent of an independent status to whom the provisions of paragraph 6 applies - apply—is acting in a Contracting State on behalf of an enterprise of the other Contracting State and has, and habitually exercises, in a Contracting State exercises an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that the first-mentioned Contracting State in respect of any activities which that person undertakes for the enterprise, unless the his activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other Contracting 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. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other Contracting State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an the enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "permanent establishment" also includes:; (ag) a farm or plantation; (h) a warehouse, in relation to a person providing storage facilities for others; (i) a building site, a construction, installation or assembly project, project or supervisory activities connected in connection therewith, but only where such site, project or activities lasts continue for a period of more than 12 six months; (bj) the furnishing of services, services including consultancy services, services by an enterprise a resident of a one of the Contracting State States through employees or other personnel engaged by the enterprise for such purposepersonnel, but only where activities of that nature continue (for the same or a connected project) project within the other Contracting State for a period or periods aggregating more than 183 days in six months within any twelve-twelve- month period. 43. Notwithstanding the preceding provisions of or 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying onadvertising, for the enterprisesupply of information, any other activity of for scientific research or for similar activities which have a preparatory or auxiliary character;, for the enterprise. (f) the maintenance of a fixed place of business solely for any combination of activities activities, mentioned in sub-paragraphs subparagraphs (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. 54. Notwithstanding the provisions of paragraphs 1 and 2, where a person - -- other than an agent of an or in independent status to whom paragraph 6 5 applies - -- is acting on behalf of an the enterprise and has, and habitually exercises, exercises in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of or any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 3 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of or that paragraph. 65. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a 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. 76. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "permanent establishment" also includes: (a) a A building site, a construction, assembly or installation or assembly project, project or supervisory activities activity connected therewith, therewith constitutes a permanent establishment but only where if such site, project or activities lasts activity continues for a period of more than 12 twelve months;. (b) the 4. The furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, constitutes a permanent establishment but only where activities of that nature continue (for the same or a connected project) project within the other Contracting State Party for a period or periods aggregating more than exceeding in the aggregate 183 days in any twelve-twelve month periodperiod commencing or ending in the fiscal year concerned. 45. 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs subparagraphs (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. 56. Notwithstanding the provisions of paragraphs 1 and 2, where a person - – other than an agent of an independent status to whom paragraph 6 7 applies - – is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State Party an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State Party in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 5 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 67. An enterprise shall not be deemed to have a permanent establishment in a Contracting State Party merely because it carries on business in that State Party 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. 78. The fact that a company which is a resident of a Contracting State Party controls or is controlled by a company which is a resident of the other Contracting StateParty, or which carries on business in that other State Party (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "permanent establishment" also includeslikewise encompasses: (a) a building site, a construction, assembly or installation or assembly project, project or supervisory activities connected in connection therewith, but only where such site, project or activities lasts continue for a period of more than 12 six months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by in the enterprise for other Contracting State, provided that such purpose, but only where activities of that nature continue (for the same project or a connected project) within the other Contracting State project for a period or periods aggregating more than 183 days in six months within any twelve-month period. 4. Notwithstanding the preceding provisions of this Articleparagraphs 1 to 3, 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of advertising, or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of the activities 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 - person, other than an agent of an independent status to whom the provisions of paragraph 6 applies - apply, is acting in a Contracting State on behalf of an enterprise and hasof the other Contracting State, has and habitually exercises, in a Contracting State exercises an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that the first-mentioned Contracting State in respect of any activities which that person undertakes for the enterprise, unless the his activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other Contracting 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 that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "“permanent establishment" also includes” likewise encompasses: (a) a building site, a construction, assembly or installation or assembly project, project or supervisory activities connected in connection therewith, but only where such site, project or activities lasts continue for a period of more than 12 months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other engaged personnel engaged by in the enterprise for other Contracting State, provided that such purpose, but only where activities of that nature continue (for the same project or a connected project) within the other Contracting State project for a period or periods aggregating more than 183 days in 12 month within any twelve-24 month period; (c) a drilling rig or ship used for the exploration for or exploitation of natural resources, or in activities connected with that exploration or exploitation but only if so used continuously or those activities continue for a period of more than 12 months. 4. Notwithstanding the preceding provisions of this Articleparagraphs 1 to 3, 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities 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 - person—other than an agent of an independent status to whom paragraph the provisions of paragra 6 applies - apply—is acting in a Contracting State on behalf of an enterprise and hasof the other Contracting State, and has a habitually exercises, in a Contracting State exercises an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that the first-mentioned Contracting State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other Contracting 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 that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes shall include especially: (a) a place of management; (b) a branch; (c) an office; (d) a factorystore, warehouse or premises used as a sales outlet unless the activities fall within paragraphs 3(a) or (b); (e) a workshop; andfactory; (f) a workshop; (g) a farm or plantation; (h) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "permanent establishment" also includes:, including timber or other forest produce; (ai) a drilling rig or working ship used for the exploration of natural resources but only where the activity continues for a period of more than 3 months; (j) a building site, a construction, installation site or assembly project, construction project or supervisory activities connected in connection therewith, but only where provided such site, project or activities lasts activity continues for a period of more than 183 days; (k) an assembly or installation project which exists for more than 12 6 months;; and (bl) the furnishing of services, including consultancy services, services by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (for the same or a connected project) within the other Contracting State country for a period or periods aggregating more than 183 days in 3 months within any twelve-twelve month period. 43. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall not be deemed not to include: (a) the use of facilities solely for the purpose purposes 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 purposes of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of for collecting information, information for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying onadvertising, for the enterprisesupply of information, any other activity of for scientific research or for similar activities which have a preparatory or auxiliary character; (f) , for the maintenance of a fixed place of business solely for any combination of activities 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 characterenterprise. 54. 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 and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterpriseother Contracting State, that enterprise shall be deemed to have a permanent establishment in that the first-mentioned Contracting State in respect of any activities which that person undertakes for the enterprise, if such a person has and habitually exercises in that Contracting State an authority to conclude contracts in the name of the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 3 which, if exercised through a fixed place of business, business would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 5. An insurance enterprise of a Contracting State shall, except with regard to reinsurance, be deemed to have a permanent establishment in the other Contracting State if it collects premiums in that other Contracting State or insures risks situated therein through an employee or through a representative who is not an agent of an independent status within the meaning of paragraph 6. 6. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other Contracting 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 or its associated enterprises, he will not be considered an agent of an independent status within the meaning of this paragraph. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other Contracting State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "“permanent establishment" also includes” likewise encompasses: (a) a building site, a construction, assembly or installation or assembly project, project or supervisory activities connected in connection therewith, but only where such site, project or activities lasts continue for a period of more than 12 six months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other engaged personnel engaged by in the enterprise for other Contracting State, provided that such purpose, but only where activities of that nature continue (for the same project or a connected project) within the other Contracting State project for a period or periods aggregating more than 183 days in six months within 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 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities 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 - person—other than an agent of an independent status to whom the provisions of paragraph 6 applies - apply—is acting in a Contracting State on behalf of an enterprise of the other Contracting State and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that the first-mentioned Contracting State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other 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 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, if the transactions between the enterprise and the agent were not made under arm’s length conditions, he will not be considered an agent of independent status within the meaning of this paragraph. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "permanent establishment" also includes: (a) a building site, a construction, installation or assembly project, or supervisory activities connected therewith, but only where such site, project or activities lasts continue for a period of more than 12 6 months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 days in any twelve-month periodcalendar year. 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities 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 on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 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 that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "permanent establishment" also includes: (a) a building site, a construction, installation or assembly project, or supervisory activities connected therewith, but only where such site, project or activities lasts for more than 12 months183 days; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 days in any twelve12-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 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities 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 on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 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 that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this AgreementConvention, the term "“permanent establishment" ” means a fixed place of business through which the business of an the enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especiallyespecially : (a) a place of managementmanagement ; (b) a branchbranch ; (c) an officeoffice ; (d) a factoryfactory ; (e) a workshop; andworkshop ; (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "permanent establishment" also includes:resources ; (ag) a place of exploration of natural resources ; (h) a building site, a construction, installation site or assembly project, construction project or supervisory activities connected in connection therewith, but only where such site, project or activities lasts activity continues for a period of more than 12 monthssix months ; (bi) the furnishing of servicesa warehouse, including consultancy services, by an enterprise of in relation to a Contracting State through employees or other personnel engaged by the enterprise person providing storage facilities for such purpose, but only where activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 days in any twelve-month periodothers. 43. Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to includeinclude : (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterpriseenterprise ; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or deliverydelivery ; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterpriseenterprise ; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterpriseenterprise ; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary charactercharacter ; (f) the maintenance of a fixed place of business solely for any combination of activities 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. 54. Notwithstanding A person acting in a Contracting State on behalf of an enterprise of the provisions of paragraphs 1 and 2, where a person - other Contracting State (other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf of an enterprise and applies) shall be deemed to be a permanent establishment in the first-mentioned State if : (a) he has, and habitually exercisesexercises in the State, in a Contracting State an authority to conclude contracts in the name on behalf of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any unless his activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which3 of this Article ; or (b) he has no such authority, if exercised through but habitually maintains in the first-mentioned State a fixed place stock of businessgoods or merchandise from which he regularly delivers goods or merchandise on behalf of the enterprise ; or (c) in so acting, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business he manufactures or processes in that State through a broker, general commission agent for the enterprise goods or any other agent of an independent status, provided that such persons are acting in merchandise belonging to the ordinary course of their businessenterprise. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; , and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "permanent establishment" also includeslikewise encompasses: (a) a building site, site or a construction, assembly or installation or assembly project, project or supervisory activities connected in connection therewith, but only where such site, construction, assembly, project or activities lasts continue for a period of more than 12 six months; (b) the furnishing of services, including consultancy or managerial services, by an enterprise individual of a Contracting State or through his employees or other personnel engaged by the enterprise for such purposepersonnel, but only where activities of that nature continue (for in the same or a connected project) within territory of the other Contracting State for a period or periods aggregating more than 183 days exceeding in the aggregate six months within any twelve-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 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities 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 7 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. Notwithstanding the foregoing provisions of this Article, an insurance enterprise of a Contracting State shall, except in regard to reinsurance, be deemed to have a permanent establishment in the other Contracting State if it collects premiums in the territory of that other State or insures risks situated therein through a person other than an agent of an independent status to whom paragraph 7 applies. 7. 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 that such persons are acting in the ordinary course of their businessbusiness and that in their commercial or financial relations with the enterprise, conditions are not made or imposed that differ from those generally agreed to by independent agents. 78. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1. ) For the purposes purpose of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2. ) The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3. ) The term "permanent establishment" also includeslikewise includes : (a) a building site, a construction, assembly or installation or assembly project, project or supervisory activities connected in connection therewith, but only where such site, project or activities lasts continue for a period of more than 12 months183 days; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 91 days in within any twelve-month periodcontinuous period of twelve months. (4. ) Notwithstanding the preceding provisions of this Article, ,the term "permanent establishment" shall be deemed not to includeinclude : (a) the use of facilities solely for the purpose of storage, storage or 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 storage or deliverydisplay; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying onadvertising, for the enterprisesupply of information, scientific research or any other activity of a preparatory or auxiliary character, for the enterprise; (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs (a) to (e)) of this paragraph, provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. (5. Notwithstanding ) A person acting in a Contracting State on behalf of an enterprise of the provisions of paragraphs 1 and 2other Contracting State, where a person - other than an agent of an independent status to whom the provisions of paragraph 6 applies - is acting on behalf (7) of an enterprise and this Article apply, shall be deemed to be a permanent establishment in the first-mentioned State if : (a) he has, and habitually exercisesexercises in that State, in a Contracting State an authority to conclude contracts in the name of the enterprise, that unless his activities are limited to the purchase of goods or merchandise for the enterprise; or (b) he maintains in the first-mentioned State a stock of goods or merchandise belonging to the enterprise shall from which he regularly fills orders on behalf of the enterprise. (6) An insurance enterprise of a Contracting State shall, except with regard to re-insurance, be deemed to have a permanent establishment in the other Contracting State if it collects premiums in the territory or that other State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised or insures risks situated there through an employee or through a fixed place representative established there who is not an agent of business, would not make an independent status within the meaning of paragraph (7) of this fixed place of business a permanent establishment under the provisions of that paragraphArticle. 6. (7) An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a 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, 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 to the business of that enterprise, he shall not be considered an agent of an independent status within the meaning of this paragraph. 7. (8) The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "“permanent establishment" also includes” likewise encompasses: (a) a building site, a construction, assembly or installation or assembly project, project or supervisory activities connected in connection therewith, but only where such site, project or activities lasts continue for a period of more than 12 18 months;. (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other engaged personnel engaged by in the enterprise for other Contracting State, provided that such purpose, but only where activities of that nature continue (for the same project or a connected project) within the other Contracting State project for a period or periods aggregating more than 183 days in 12 months within any twelve24-month period. 4. Notwithstanding the preceding provisions of this Articleparagraphs 1 to 3, 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 maitenance 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs subparagraphs (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 the provisions of paragraph 6 applies apply - is acting in a Contracting State on behalf of an enterprise and hasof the other Contracting State, has and habitually exercises, in a Contracting State exercises an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that the firstmentioned Contracting State in respect of any activities which that person undertakes for the enterpriseentereprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise of a Contracting State shall not be deemed deemmed to have a permanent establishment establishement in a the other Contracting State merely because it carries on business in that other Contracting State through a broker, general commission comission agent or any other agent agnet 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 that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "“permanent establishment" ” also includesencompasses: (a) a building site, a construction, installation or assembly project, project or supervisory activities connected in connection therewith, but only where if such site, project or activities lasts for last more than 12 nine (9) months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only where if activities of that nature continue (for the same or a connected project) within the other a Contracting State Party for a period or periods aggregating more than 183 days in within 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, storage or 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 storage or deliverydisplay; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities 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 Party on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterpriseother Contracting Party, that enterprise shall be deemed to have a permanent establishment in that State the first mentioned Contracting Party in respect of any activities which that person undertakes for the enterprise, if such a person: (a) has and habitually exercises in that Party an authority to conclude contracts in the name of the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph; or (b) has no such authority, but habitually maintains in the first-mentioned Party a stock of goods or merchandise from which he regularly delivers goods or merchandise on behalf of the enterprise. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State Party merely because it carries on business in that State Party 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. 7. The fact that a company which is a resident of a Contracting State Party controls or is controlled by a company which is a resident of the other Contracting StateParty, or which carries on business in that other State Party (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of relating to the exploration for or the extraction of natural resources. 3. The term "“permanent establishment" ” also includes: (a) includes a building site, a construction, assembly or installation or assembly project, or supervisory activities connected therewithin connection with a building site, or with such a project, but only where such if that site, project or activities lasts for last more than 12 six months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 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 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs subparagraphs (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 - applies) is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State Party an authority to conclude contracts in the name on behalf of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State Party in respect of any activities which that person undertakes for the enterprise, enterprise unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State Party merely because it carries on business in that State Party 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. 7. The fact that a company which is a resident of a Contracting State Party controls or is controlled by a company which is a resident of the other Contracting StateParty, or which carries on business in that other State Party (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1. ) For the purposes purpose of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2. ) The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3. ) The term "permanent establishment" also includeslikewise includes : (a) a building site, a construction, assembly or installation or assembly project, project or supervisory activities connected in connection therewith, but only where such site, project or activities lasts continue for a period of more than 12 months183 days; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 91 days in within any twelve-month periodcontinuous period of twelve months. (4. ) Notwithstanding the preceding provisions of this Article, ,the term "permanent establishment" shall be deemed not to includeinclude : (a) the use of facilities solely for the purpose of storage, storage or 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 storage or deliverydisplay; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying onadvertising, for the enterprisesupply of information, scientific research or any other activity of a preparatory or auxiliary character, for the enterprise; (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-sub- paragraphs (a) to (e)) of this paragraph, provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. (5. Notwithstanding ) A person acting in a Contracting State on behalf of an enterprise of the provisions of paragraphs 1 and 2other Contracting State, where a person - other than an agent of an independent status to whom the provisions of paragraph 6 applies - is acting on behalf (7) of an enterprise and this Article apply, shall be deemed to be a permanent establishment in the first-mentioned State if : (a) he has, and habitually exercisesexercises in that State, in a Contracting State an authority to conclude contracts in the name of the enterprise, that unless his activities are limited to the purchase of goods or merchandise for the enterprise; or (b) he maintains in the first-mentioned State a stock of goods or merchandise belonging to the enterprise shall from which he regularly fills orders on behalf of the enterprise. (6) An insurance enterprise of a Contracting State shall, except with regard to re-insurance, be deemed to have a permanent establishment in the other Contracting State if it collects premiums in the territory or that other State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised or insures risks situated there through an employee or through a fixed place representative established there who is not an agent of business, would not make an independent status within the meaning of paragraph (7) of this fixed place of business a permanent establishment under the provisions of that paragraphArticle. 6. (7) An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a 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, 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 to the business of that enterprise, he shall not be considered an agent of an independent status within the meaning of this paragraph. 7. (8) The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1. ) For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2. ) The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; , and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3. ) The term "“permanent establishment" ” also includes: (a) a building site, a construction, site or construction or installation or assembly project, or supervisory activities connected therewith, but project only where such site, project or activities if it lasts for more than 12 nine months;; and b) an installation or structure used for the exploration of natural resources or a drilling rig or ship used for the exploration of natural resources, only if such use lasts for more than nine months. (b4) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 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 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs (subparagraphs 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 on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (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 that such persons are acting in the ordinary course of their business. (7. ) The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other. (1) Income derived by a resident of a Contracting State from immovable property (including income from agriculture or forestry) situated in the other Contracting State may be taxed in that other State. (2) The term “immovable property” shall have the meaning which it has under the law of the Contracting State in which the property in question is situated. The term shall in any case include property accessory to immovable property, livestock and equipment used in agriculture and forestry, rights to which the provisions of general law respecting landed property apply, usufruct of immovable property and rights to variable or fixed payments as consideration for the working of, or the right to work, mineral deposits, sources and other natural resources; ships, boats and aircraft shall not be regarded as immovable property. (3) The provisions of paragraph 1 shall apply to income derived from the direct use, letting, or use in any other form of immovable property. (4) The provisions of paragraphs 1 and 3 shall also apply to the income from immovable property of an enterprise.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "“permanent establishment" also includes” likewise encompasses: (a) a building site, a construction, assembly or installation or assembly project, project or supervisory activities connected in connection therewith, but only where such site, project or activities lasts continue for a period of more than 12 six months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by in the enterprise for other Contracting State, provided that such purpose, but only where activities of that nature continue (for the same project or a connected project) within the other Contracting State for a period or periods aggregating more than 183 days in six months within any twelve-month period. 4. Notwithstanding the preceding provisions of this Articleparagraphs 1 to 3, 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities 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 - person—other than an agent of an independent status to whom the provisions of paragraph 6 applies - apply—is acting on behalf of an enterprise of a Contracting State and has, and habitually exercises, in a the other Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that the last-mentioned State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a 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 will not be considered an agent of an independent status within the meaning of this paragraph. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "“permanent establishment" ” also includes: (a) a building site, a construction, assembly or installation project or assembly project, a supervisory or supervisory activities consultancy activity connected therewith, but only where if such site, project or activities activity lasts in a Contracting State for a period of more than 12 twelve months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 days in 9 months within 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 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs (subparagraphs 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 on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 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 that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploitation of natural resources.; 3. The term "permanent establishment" also includes: (ag) a building site, a construction, installation site or construction or assembly project, or installation project or supervisory activities activity connected therewith, but only therewith where such site, project or activities lasts activity continues for a period of more than 12 months;183 days; and (bh) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (for the same or a connected project) project within the other Contracting State Party for a period or periods aggregating more than 183 exceeding in the aggregate183 days in any twelve-twelve month periodperiod commencing or ending in the fiscal year concerned. 43. 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities 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. 54. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other -other than an agent of an independent status to whom paragraph 6 applies - 5 applies- is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State Party an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State Party in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 3 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 65. An enterprise of a Contracting Party shall not be deemed to have a permanent establishment in a Contracting State the other Party merely because it carries on business in that State Party 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. 76. The fact that a company which is a resident of a Contracting State Party controls or is controlled by a company which is a resident of the other Contracting StateParty, or which carries on business in that other State Party (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an the enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especiallyshall include: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a warehouse, in relation to a person providing storage facilities for others; (g) a mine, an oil or gas well, a quarry or any other place of extraction of natu- ral resources; and (h) an installation or structure used for the exploration of natural resources. 3. The term "permanent establishment" also includes: (a) a building siteA building, site or a construction, installation or assembly project, or supervisory supervi- sory activities connected in connection therewith, but constitutes a permanent establishment only where such if the site, project or activities activity lasts for more than 12 nine months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 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 delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise enter- prise solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise enter- prise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing pur- chasing goods or merchandise merchandise, or of for collecting information, for the enterpriseenter- prise; (e) the maintenance of a fixed place of business solely for the purpose of carrying onad- vertising, for the enterprisesupply of information, any other activity of for scientific research or for similar activities which have a preparatory or auxiliary character;, for the enterprise; and (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs subparagraphs (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 22 of this Article, where a person - acting in a Contracting State on behalf of an enterprise of the other Contracting State (other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf of an enterprise and this Article ap- plies) notwithstanding that he has no fixed place of business in the first-mentioned State shall be deemed to be a permanent establishment in that State if: (a) he has, and habitually exercises, a general authority in a Contracting the first-mentioned State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed unless his activi- ties are limited to have a permanent establishment in that State in respect the purchase of any activities which that person undertakes goods or merchandise for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 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 that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.; or

PERMANENT ESTABLISHMENT. 1. For the purposes of this AgreementConvention, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources; g) a farm or a plantation, and h) premises and warehouses used as sales outlets. 3. The term "A building site or construction or installation project constitutes a permanent establishment" also includes: (a) a building site, a construction, installation or assembly project, or supervisory activities connected therewith, but establishment only where such site, project or activities if it lasts for more than 12 six months; , also a preliminary survey and exploration of natural resources (bhydrocarbons) the furnishing of services, including consultancy services, by an enterprise of constitutes a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but permanent establishment only where activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating if it lasts more than 183 days in any twelve-month periodsix 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs (subparagraphs 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 on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 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 that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "permanent establishment" also includes: (a) a A building site, a or construction, assembly, or installation or assembly project, project or supervisory activities connected in connection therewith, but constitutes a permanent establishment only where such site, project or activities if it lasts for more than 12 twelve months;. (b) 4. Notwithstanding the provisions of paragraphs 1, 2 and 3, the term “permanent establishment” also encompasses the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only where if activities of that nature continue (for the same or a connected project) within the other a Contracting State for a period or periods aggregating more than 183 days in within any twelve-month period. 45. 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs (subparagraphs 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. 56. Notwithstanding the provisions of paragraphs 1 and 2, where a person - -- other than an agent of an independent status to whom paragraph 6 7 applies - -- is acting in a Contracting State on behalf of an enterprise of the other Contracting State, and has, and habitually exercises, in a that Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that Contracting State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 5 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 67. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a 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 will not be considered an agent of an independent status within the meaning of this paragraph. 78. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.other.‌

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources.; 3. The term "permanent establishment" also includeslikewise encompasses: (a) a building site, a construction, assembly or installation or assembly project, project or supervisory activities connected in connection therewith, but only where such site, project or activities lasts continue for a period of more than 12 months183 days; (b) the furnishing of services, including consultancy services, services by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (for the same or a connected project) within the other Contracting State country for a period or periods aggregating more than 183 days in three months within 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, storage or 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying onadvertising, for the enterprisesupply of information, any other activity of for scientific research or for similar activities which have a preparatory or auxiliary character, for the enterprise; (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs subparagraphs (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 7 applies - -- is acting in a Contracting State on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterpriseother Contracting State, that enterprise shall be deemed to have a permanent establishment in that 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 State an authority to conclude contracts in the name of the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph.; or 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(b) has no such authority, general commission agent or any other agent of an independent status, provided that such persons are acting but habitually maintains in the ordinary course first- mentioned State a stock of their business. 7. The fact that a company goods or merchandise from which is a resident of a Contracting State controls he regularly delivers goods or is controlled by a company which is a resident merchandise on behalf of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the otherenterprise.

PERMANENT ESTABLISHMENT. 1. For the purposes of this AgreementConvention, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (; e) a workshop; and; (f) a warehouse or premises used as a sales outlet; g) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "permanent establishment" also includes: (a) a A building site, site or a construction, assembly or installation or assembly project, project or supervisory activities connected therewith, but in connection therewith constitute a permanent establishment only where if such site, project or activities lasts continue for a period of more than 12 six months; (; b) the The furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purposepurpose constitutes a permanent establishment, but only where if the activities of that nature continue (for the same or a connected project) within the other a Contracting State for a period or periods aggregating more than 183 days in 9 months within 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, or 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 storage or deliverydisplay; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities 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 and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterpriseother Contracting State, that enterprise shall be deemed to have a permanent establishment in that the first- mentioned State in respect of any activities which that person undertakes for the enterprise if such a person: a) has and habitually exercises in that State an authority to conclude contracts on behalf of the enterprise, unless the activities of such a person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph; or b) manufactures or processes in that State for the enterprise goods or merchandise belonging to the enterprise. 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 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 to be an agent of an independent status within the meaning of this paragraph. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.. Chapter III Taxation of Income Article 6

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an the enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a warehouse or premises used as a sales outlet; g) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources.; 3. The term "permanent establishment" also includes:h) a farm or any other place of agricultural activity; (ai) a building site, a construction, construction assembly or installation or assembly project, project or supervisory activities connected in connection therewith, but only where such site, project or activities lasts continue for a period of more than 12 months90 days; (bj) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (for in the same or a connected project) within territory of the other Contracting State for a period or periods aggregating more than 183 90 days in within any twelve-month period. 43. 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, storage or 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 storage or deliverydisplay; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying onadvertising, for the enterprisesupply of information, any other activity of for scientific research or for similar activities which have a preparatory or auxiliary character, for the enterprise; (f) the maintenance of a fixed place of business solely for any combination of activities 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. 54. Notwithstanding the provisions of paragraphs 1 and 2, where a person - person, other than an agent of an independent status to whom paragraph 6 applies - 5 applies, is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterpriseother 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 in respect State, an authority to conclude contracts on behalf of any activities which that person undertakes for the enterprise, unless the his activities of such person are limited to those mentioned in paragraph 4 which3 of this Article; or b) he has no such authority, if exercised through but habitually maintains in the first-mentioned State a fixed place stock of business, would not make this fixed place goods or merchandise from which he regularly delivers goods or merchandise on behalf of business a permanent establishment under the provisions of that paragraphenterprise. 65. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, a general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 76. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "“permanent establishment" ” also includesencompasses: (a) a building site, a construction, assembly or installation or assembly project, project or supervisory activities connected in connection therewith, but only where if such site, project or activities lasts for last more than 12 nine months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State directly or through employees or other personnel engaged by the enterprise for such purpose, but only where if activities of that nature continue (for the same or a connected project) within the other a Contracting State Party for a period or periods aggregating more than 183 270 days in within 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 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities 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 on behalf of an enterprise and has, and habitually exercises, in a Contracting State Party an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State Party in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State Party merely because it carries on business in that State Party 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. 7. The fact that a company which is a resident of a Contracting State Party controls or is controlled by a company which is a resident of the other Contracting StateParty, or which carries on business in that other State Party (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "permanent establishment" also includesencompasses: (a) a building site, a construction, assembly or installation or assembly project, project or supervisory activities connected in connection therewith, but only where if such site, project or activities lasts for last more than 12 months270 days; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only where if activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 days in within 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 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities 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 7 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. Notwithstanding the preceding provisions of this Article, an insurance enterprise of a Contracting State shall, except in regard to re-insurance, be deemed to have a permanent establishment in the other Contracting State if it collects premiums in the territory of that other State or insures risks situated therein through a person other than an agent of an independent status to whom paragraph 7 applies. 7. 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 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, and conditions are made or imposed between that enterprise and the agent in their commercial and financial relations which differ from those which would have been made between independent enterprises, he will not be considered an agent of an independent status within the meaning of this paragraph. 78. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" establishment means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes establishment shall include especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "permanent establishment" also includes:; (ag) a building site, a constructionconstruction project, an installation or project, an assembly project, or supervisory activities connected therewith, but only in connection therewith where such site, project or activities lasts or any two or more of them continues or continue for more than 12 6 months; (bh) a warehouse in relation to a person providing storage facilities for others; (i) the furnishing of services, including consultancy services, by an enterprise a resident of a one of the Contracting State States through employees or other personnel engaged by the enterprise for such purposepersonnel, but only where provided activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 days in within any twelve-12 month period; (j) an agricultural, pastoral or forestry property. 43. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" An enterprise shall not be deemed not to includehave a permanent establishment merely by reason of: (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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of for collecting information, for the enterprise;; or (e) the maintenance of a fixed place of business solely for the purpose of carrying on, activities which have a preparatory or auxiliary character for the enterprise, any other activity of a preparatory such as advertising or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities 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 characterscientific research. 54. 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 on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that An enterprise shall be deemed to have a permanent establishment in one of the Contracting States and to carry on business through that permanent establishment if substantial equipment is being used in that State by, for or under contract with the enterprise. 5. A person acting in respect one of the Contracting States on behalf of an enterprise of the other Contracting State—other than a broker, general commission agent or any activities which other agent of an independent status to whom paragraph 6 applies—shall be deemed to be a permanent establishment of that person undertakes for enterprise in the firstmentioned State if the person: (a) has, and habitually exercises in that State, an authority to conclude contracts on behalf of the enterprise, unless the person’s activities of such person are limited to those the purchase of goods or merchandise for the enterprise; (b) in so acting, manufactures or processes in that State for the enterprise goods or merchandise belonging to the enterprise; (c) habitually maintains in the first mentioned State a stock of goods or merchandise belonging to the enterprise from which the person regularly fills orders on behalf of the enterprise; or (d) habitually secures orders in paragraph 4 whichthe first mentioned State, if exercised through wholly or almost wholly for the enterprise, or for the enterprise and other enterprises which are controlled by it or have a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraphcontrolling interest in it. 6. An enterprise of one of the Contracting States shall not be deemed to have a permanent establishment in a 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 where that such persons are person is acting in the ordinary course of their the person’s business. For this purpose, an agent shall not be considered to be an agent of an independent status if the agent carries on in that other State an activity described in paragraph 5 wholly or almost wholly for the enterprise or for the enterprise and any one or more enterprises which are controlled by it or have a controlling interest in it. 7. The fact that a company which is a resident of a one of the Contracting State States controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), ) shall not of itself constitute make either company a permanent establishment of the other. 8. The principles set forth in paragraphs 1 to 7 inclusive shall be applied in determining for the purposes of paragraph 5 of Article 11 and paragraph 6 of Article 12 whether there is a permanent establishment outside both Contracting States, and whether an enterprise, not being an enterprise of one of the Contracting States, has a permanent establishment in one of the Contracting States.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" ", in relation to an enterprise, means a fixed place of business through which the business of an the enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "permanent establishment" also includes:; (ag) an agricultural, pastoral or forestry property; (h) a building site, a site or construction, installation or assembly project, or supervisory activities connected therewith, but only where such site, project or activities lasts which exists for more than 12 6 months;; and (bi) the furnishing of services, including consultancy services, services in a territory by an enterprise of a Contracting State the other territory through employees or other personnel engaged by the enterprise for such purpose, but only where those activities of that nature continue (for the same or a connected project) within the other Contracting State first- mentioned territory continue for a period or periods aggregating more than 183 120 days in within any twelve-twelve month period. 43. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" An enterprise shall not be deemed not to includehave a permanent establishment merely by reason of: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise;; or (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery;; or (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise;; or (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of collecting information, for the enterprise;; or (e) the maintenance of a fixed place of business solely for the purpose of carrying on, activities which have a preparatory or auxiliary character for the enterprise, any other activity of such as advertising or scientific research. 4. An enterprise shall be deemed to have a preparatory or auxiliary character;permanent establishment in a territory and to carry on business through that permanent establishment if: (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs (a) to it carries on supervisory activities in that territory for more than 6 months in connection with a building site, or a construction, installation or assembly project, which is being undertaken in that territory; or (e)b) substantial equipment is being used in that territory by, provided for or under contract with, the enterprise where that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary characteruse continues for more than 3 months. 5. Notwithstanding A person acting in a territory on behalf of an enterprise of the provisions of paragraphs 1 and 2, where a person - other territory-- other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf applies--shall be deemed to be a permanent establishment of an that enterprise and in the first-mentioned territory if: (a) the person has, and habitually exercisesexercises in that territory, in a Contracting State an authority to conclude contracts in the name on behalf of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the person's activities of such person are limited to those mentioned the purchase of goods or merchandise for the enterprise; or (b) in paragraph 4 whichso acting, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of person manufactures or processes in that paragraphterritory for the enterprise goods or merchandise belonging to the enterprise. 6. An enterprise of a territory shall not be deemed to have a permanent establishment in a Contracting State the other territory merely because it carries on business in that State other territory through a person who is a broker, general commission agent or any other agent of an independent status, provided that such persons are status and is acting in the ordinary course of their businessthe person's business as such a broker or agent. 7. The fact that a company which is a resident of a Contracting State territory controls or is controlled by a company which is a resident of the other Contracting Stateterritory, or which carries on business in that other State territory (whether through a permanent establishment or otherwise), shall not of itself constitute make either company a permanent establishment of the other. 8. The principles set forth in the preceding paragraphs of this Article shall be applied in determining for the purposes of paragraph 5 of Article 11 and paragraph 5 of Article 12 whether an enterprise, not being an enterprise of either territory, has a permanent establishment in a territory.

PERMANENT ESTABLISHMENT. 1. For the purposes of this AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially:; (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources.; 3. The term "" permanent establishmentestablishment " also includes:likewise encompasses; (a) a building site, a construction, assembly or installation or assembly project, project or supervisory activities connected in connection therewith, but only where such sitesite , project or activities lasts continue for a period of more than 12 6 months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other engaged personnel engaged by in the enterprise for other Contracting State, provided that such purpose, but only where activities of that nature continue (for the same project or a connected project) within the other Contracting State project for a period or periods aggregating more than 183 days in 6 months within any twelve-12 month period. 4. Notwithstanding the preceding provisions of this Articleparagraphs 1 to 3, 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs (subparagraphs 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 and of the other Contracting State has, and habitually exercises, in a Contracting State exercises an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that the first-mentioned Contracting State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a that other Contracting State merely because it carries on business in that other Contracting 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 that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) : • a place of management; (b) ; • a branch; (c) ; • an office; (d) ; • a factory; (e) ; • a workshop; and (f) , and • a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "permanent establishment" also includes: (likewise encompasses: a) a building site, a construction, assembly or installation or assembly project, project or supervisory activities connected in connection therewith, but only where such site, project or activities lasts continue for a period of more than 12 months; (sixmonths; b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the an enterprise for such purpose, but only where activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 days in six months within 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 delivery of displayor deliveryof 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 displayor delivery; (c) ; • the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) ; • the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) ; • the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) ; • the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs (subparagraphs 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 on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other Contracting 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 that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other Contracting State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "“permanent establishment" also includes” likewise encompasses: (a) a building site, a construction, assembly or installation or assembly project, project or supervisory activities connected in connection therewith, but only where such site, project or activities lasts continue for a period of more than 12 months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other engaged personnel engaged by in the enterprise for other Contracting State, provided that such purpose, but only where activities of that nature continue (for the same project or a connected project) within the other Contracting State project for a period or periods aggregating more than 183 days in any twelve-month period12 months. 4. Notwithstanding the preceding provisions of this Articleparagraphs 1 to 3, 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying onon advertising, for the enterpriseinformation, any other activity scientific research or similar activities of a preparatory or auxiliary charactercharacter for the enterprise; (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs (subparagraphs 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 the provisions of paragraph 6 applies - apply -- is acting in a Contracting State on behalf of an enterprise and hasof the other Contracting State, has and habitually exercises, in a Contracting State exercises an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that the first-mentioned Contracting State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other Contracting 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. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especiallyespecially : (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; andworkshop or a warehouse; (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources; (g) an installation or structure, used for the exploration or exploitation of natural resources; (h) the provision of services or facilities in connection with or supply of plant and machinery on hire used or to be used in, the prospecting for, or extraction or production of mineral oils; (i) a premises used as a sales outlet or for receiving or soliciting orders; (j) a building site or construction, installation or assembly project or supervisory activities in connection therewith, where such site, project or activities (together with other such sites, projects or activities, if any) continue for a period of more than six months, or where such project or supervisory activity, being incidental to the sale of machinery or equipment, continues for a period not exceeding six months and the charges payable for the project or supervisory activity exceed 10 per cent of the sale price of the machinery and equipment. 3. The term "permanent establishment" also includes: (a) a building site, a construction, installation or assembly project, or supervisory activities connected therewith, but only where such site, project or activities lasts for more than 12 months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 days in any twelve-month period. 4. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall not be deemed not to includeinclude :— (a) the use of facilities solely for the purpose of storage, storage or 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 storage or deliverydisplay; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of for collecting information, for the enterprise; (ed) the maintenance of a fixed place of business solely for the purpose of carrying onscientific research, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities 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. 54. Notwithstanding Subject to the provisions of paragraphs 1 and 2paragraph 5, 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 and has, and habitually exercises, in a of the other Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment of that enterprise in the first-mentioned State, if :— (a) he has and habitually exercises, in that State in respect an authority to conclude contracts on behalf of any activities which that person undertakes for the enterprise, unless the his activities of such person are limited to those the purchase of goods or merchandise for that enterprise; or (b) he habitually maintains in the first-mentioned Contracting State a stock of goods or merchandise belonging to the enterprise from which the person regularly delivers goods or merchandise on behalf of the enterprise; or (c) he habitually secures orders in paragraph 4 whichthe first-mentioned Contracting State, if exercised through exclusively or almost exclusively, for the enterprise itself, or for the enterprise and other enterprises which are controlled by it or have a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraphcontrolling interest in it. 65. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a 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. 76. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that the other Contracting State (whether through a permanent establishment or otherwise), ) shall not of itself constitute either company a permanent establishment of the other.. CHAPTER III TAXATION OF INCOME

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; andworkshop;and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "permanent establishmentestablisment" also includeslikewise encompasses: (a) a building site, a construction, assembly or installation or assembly project, project or supervisory activities connected in connection therewith, but only where such site, project or activities lasts continue for a period of more than 12 six months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (for the same or a connected project) within the other Contracting State country for a period or periods aggregating more than 183 days in three months within any twelve-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, storage or 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 storage or deliverydisplay; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying onadvertising, for the enterprisesupply of information, any other activity of for scientific research or for similar activities which have a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities 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 7 applies - -- is acting in a Contracting State on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterpriseother Contracting State, that enterprise shall be deemed to have a permanent establishment in that the first-mentioned State in respect of any activities which that person undertakes for the enterprise, if such a person: (a) has and habitually exercises in the first-mentioned State an authority to conclude contracts in the name of the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph; or (b) has no such authority, but habitually maintains in the first-mentioned State a stock of goods or merchandise from which he regularly delivers goods or merchandise on behalf of the enterprise. 6. An insurance enterprise of a Contracting State shall, except with regard to reinsurance, be deemed to have a permanent establishment in the other Contracting State if it collects premiums in that other State or insures risks situated therein through an employee or through a representative who is not an agent of an independent status within the meaning of paragraph 7. 7. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a 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 shall not be considered an agent of an independent status within the meaning of this paragraph. 78. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) premises used as sales outlet; (g) a mine, an oil or gas well, a quarry or any other place of exploration, extraction or exploitation, of natural resources. 3. The term "permanent establishment" also includes:; and (ah) a building site, a construction, assembly or installation project or assembly any supervisory activity in connection with such site or project, or supervisory activities connected therewith, but only where such site, project or activities lasts for more than 12 months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (for the same or a connected project) within the other Contracting State activity continues for a period or periods aggregating of more than 183 days in any twelve-month period(6) six months. 43. 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character;; or (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs subparagraphs (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. 54. 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 on behalf of an enterprise and has, and habitually exercisesexercise, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which3 which , if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 5. Notwithstanding the preceding provisions of this Article, an insurance enterprise of a Contracting State except in regard to reinsurance, shall be deemed to have a permanent establishment in the other Contracting State if it collects premiums on the territory of that other Contracting State or insures risks situated therein through a person, other than an agent of an independent status to whom paragraph 6 applies. 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 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, and conditions are made or imposed between that enterprise and the agent in their commercial and financial relations which differ from those which would have been made between independent enterprises, he will not be considered an agent of an independent status within the meaning of this paragraph. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this AgreementConvention, the term "" permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; , and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "“permanent establishment" also includes” likewise encompasses: (a) a building site, or a construction, assembly or installation or assembly project, project or supervisory activities connected in connection therewith, but only where such site, project or activities lasts continue for a period of more than 12 twelve months; (b) the furnishing of services, including consultancy or managerial services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (for in the same or a connected project) within territory of the other Contracting State for a period or periods aggregating more than 183 days exceeding in the aggregate six months within any twelve-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 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs (subparagraphs 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 on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 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 that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an the enterprise is wholly or partly carried on. 2. The term "permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a warehouse or premises used as a sales outlet; g) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources.; 3. The term "permanent establishment" also includes:h) a farm or any other place of agricultural activity; (ai) a building site, a construction, construction assembly or installation or assembly project, project or supervisory activities connected in connection therewith, but only where such site, project or activities lasts continue for a period of more than 12 months90 days; (bj) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (for in the same or a connected project) within territory of the other Contracting State for a period or periods aggregating more than 183 90 days in within any twelve-month period. 43. 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, storage or 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 storage or deliverydisplay; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying onadvertising, for the enterprisesupply of information, any other activity of for scientific research or for similar activities which have a preparatory or auxiliary character, for the enterprise; (f) the maintenance of a fixed place of business solely for any combination of activities 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. 54. Notwithstanding the provisions of paragraphs 1 and 2, where a person - person, other than an agent of an independent status to whom paragraph 6 applies - 5 applies, is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterpriseother 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 in respect State, an authority to conclude contracts on behalf of any activities which that person undertakes for the enterprise, unless the his activities of such person are limited to those mentioned in paragraph 4 which3 of this Article; or b) he has no such authority, if exercised through but habitually maintains in the first-mentioned State a fixed place stock of business, would not make this fixed place goods or merchandise from which he regularly delivers goods or merchandise on behalf of business a permanent establishment under the provisions of that paragraphenterprise. 65. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, a general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 76. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: : (a) a place of management; ; (b) a branch; ; (c) an office; ; (d) a factory; ; (e) a workshop; and and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "permanent establishment" also likewise includes: : (a) a building site, a construction, assembly or installation or assembly project, project or supervisory activities connected in connection therewith, but only where such site, project or activities lasts continue for a period of more than 12 months; 183 days; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 91 days in within any twelve-month periodcontinuous period of twelve 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, storage or 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 storage or delivery; display; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; ; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of collecting information, for the enterprise; ; (e) the maintenance of a fixed place of business solely for the purpose of carrying onadvertising, for the enterprisesupply of information, scientific research or any other activity of a preparatory or auxiliary character; , for the enterprise; (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs subparagraphs (a) to (e)) of this paragraph, provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding A person acting in a Contracting State on behalf of an enterprise of the provisions of paragraphs 1 and 2other Contracting State, where a person - other than an agent of an independent status to whom the provisions of paragraph 6 applies - is acting on behalf 7 of an enterprise and the Article apply, shall be deemed to be a permanent establishment in the first-mentioned State if: (a) he has, and habitually exercisesexercises in that State, in a Contracting State an authority to conclude contracts in the name of the enterprise, that unless his activities are limited to the purchase of goods or merchandise for the enterprise; or (b) he maintains in the first-mentioned State a stock of goods or merchandise belonging to the enterprise shall from which he regularly fills orders on behalf of the enterprise. 6. An insurance enterprise of a Contracting State shall, except with regard to re-insurance, be deemed to have a permanent establishment in the other Contracting State if it collects premiums in the territory of that other State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised or insures risks situated there through an employee or through a fixed place representative established there who is not an agent of business, would not make an independent status within the meaning of paragraph 7 of this fixed place of business a permanent establishment under the provisions of that paragraphArticle. 67. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a 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, 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 to the business of that enterprise, he shall not be considered an agent of an independent status within the meaning of this paragraph. 78. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "“permanent establishment" also includes” likewise encompasses: (a) a building site, a construction, assembly or installation or assembly project, project or supervisory activities connected in connection therewith, but only where such site, project or activities lasts continue for a period of more than 12 months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other engaged personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (for the same or a connected project) within in the other Contracting State provided that such activities continue for the same project or a connected project for a period or periods aggregating more than 183 days in any twelve-month period12 months. 4. Notwithstanding the preceding provisions of this Articleparagraphs 1 to 3, 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities 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 the provisions of paragraph 6 applies - apply -- is acting in a Contracting State on behalf of an enterprise and hasof the other Contracting State, has and habitually exercises, in a Contracting State exercises an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that the first-mentioned Contracting State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a 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 will not be considered an agent of an independent status within the meaning of this paragraph. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources; (g) a farm, plantation or other place where agriculture or forestry activities are carried on. 3. The term "“permanent establishment" also includes” likewise encompasses: (a) a building site, a construction, installation or assembly project, project or supervisory activities connected in connection therewith, but only where such site, project or activities lasts continue for a period of more than 12 months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (premises used for the same sale of goods or a connected project) within the other Contracting State for a period or periods aggregating more than 183 days in any twelve-month periodmerchandise. 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities 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; (g) the sale of goods or merchandise belonging to the enterprise displayed in the frame of an occasional temporary fair or exhibition after the closing of the said fair or exhibition, provided that the parties or companies involved fulfill all requirements in the Contracting State where the goods are displayed. 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 on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 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 that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "permanent establishment" also includes: (a) Notwithstanding the provisions of paragraphs 1 and 2, the term “permanent establishment” shall include a building site, a construction, assembly or installation or assembly project, or as well as supervisory activities connected in connection therewith, but only where such site, project or activities lasts for more than 12 months; (b) the furnishing of services, services including consultancy services, services by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only where if these activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating of more than 183 days three months. (b) However, in any twelve-month period.the case of installation activities which are incidental to the sale of machinery by an enterprise in the other State, and the installation activities are necessary to complete the sale of that machinery or equipment, then in such a case, 4. Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall not 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character;. (f) the maintenance of 5. The term “permanent establishment” shall include a fixed place of business solely for any combination of activities mentioned in sub-paragraphs (a) to (e), provided used as a sales outlet notwithstanding the fact that the overall activity of the such fixed place of business resulting from is otherwise maintained for any of the activities mentioned in paragraph 4 of this combination is of a preparatory or auxiliary characterArticle. 56. An enterprise shall not be deemed to have a permanent establishment in one of the States merely because it carries on business in that 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. 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 one of the States on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterpriseother State, that enterprise shall be deemed to have a permanent establishment in that the first-mentioned State in respect of any activities which that person undertakes for the enterprise, if such a person: a) has and habitually exercises in that State an authority to conclude contracts in the name of the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph; or b) habitually secures orders for the sale of goods or merchandise in the first-mentioned State exclusively or almost exclusively on behalf of the enterprise itself or on behalf of the enterprise and other enterprises controlled by it or which have a controlling interest in it. 68. An enterprise shall not be deemed Subject to have a permanent establishment in a Contracting State merely because it carries on business in that State through a brokerthe preceding provisions of this Article, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State one of the States controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.. Chapter III Taxation of Income Article 6

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "« permanent establishment" establishment » means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "« permanent establishment" establishment » includes especiallyespecially : (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "« permanent establishment" establishment » also includesincludes : (a) a building site, a construction, installation or assembly project, or supervisory activities connected therewith, but only where such site, project or activities lasts last for more than 12 months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 days in any twelve-twelve month periodperiod commencing or ending in the taxable period concerned. 4. Notwithstanding the preceding provisions of this Article, the term "« permanent establishment" establishment » shall be deemed not to includeinclude : (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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities 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 on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 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 that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "“permanent establishment" ” also includes: (a) a building site, a construction, assembly or installation project or assembly project, a supervisory or supervisory activities consultancy activity connected therewith, but only where if such site, project or activities activity lasts in a Contracting State for a period of more than 12 twelve months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 days in 9 months within 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 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs (subparagraphs 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 on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 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 that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "“permanent establishment" ” also includesencompasses: (a) a building site, a construction, assembly or installation or assembly project, project or supervisory activities connected in connection therewith, but only where if such site, project or activities lasts for last more than 12 six months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State directly or through employees or other personnel engaged by the enterprise for such purpose, but only where if activities of that nature continue (for the same or a connected project) within the other a Contracting State Party for a period or periods aggregating more than 183 days in within 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 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities 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 on behalf of an enterprise and has, and habitually exercises, in a Contracting State Party an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State Party in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State Party merely because it carries on business in that State Party 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. 7. The fact that a company which is a resident of a Contracting State Party controls or is controlled by a company which is a resident of the other Contracting StateParty, or which carries on business in that other State Party (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishmentestablishment includes" includes especially:; (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "permanent establishment" also includeslikewise encompasses: (a) a building site, a construction, assembly or installation or assembly project, project or supervisory activities connected in connection therewith, but only where such site, project or activities lasts continue for a period of more than 12 three months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (for the same or a connected project) within the other Contracting State country for a period or periods aggregating more than 183 days in four months within any twelve-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 the facilities solely for the purpose of storage, storage or 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 storage or deliverydisplay; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying onadvertising, for the enterprisesupply of information, any other activity of for scientific research or for similar activities which have a preparatory or auxiliary charactercharacter for the enterprise; (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs subparagraphs (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 7 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State on behalf of' an authority to conclude contracts in the name enterprise of the enterpriseother Contracting State, that enterprise shall be deemed to have a permanent establishment in that 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 State an authority to conclude contracts in the name of the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph; or (b) has no such authority, but habitually maintains in the first-mentioned State a stock of goods or merchandise from which he regularly delivers goods or merchandise on behalf of the enterprise. 6. An insurance enterprise of a Contracting State shall, except with regard to reinsurance, be deemed to have a permanent establishment in the other Contracting State if it collects premiums in that other State or insures risks situated therein through an employee or through a representative who is not an agent of an independent status within the meaning of paragraph 7. 7. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a 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 will not be considered an agent of an independent status within the meaning of this paragraph. 78. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; , and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "permanent establishment" also includeslikewise encompasses: (a) a building site, a construction, assembly or installation project or assembly project, a supervisory or supervisory consultancy activities connected therewith, but only where such site, project or activities lasts continue for a period of more than 12 six months; (b) the furnishing of services, including consultancy or managerial services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (for in the same or a connected project) within territory of the other Contracting State for a period or periods aggregating more than 183 days exceeding in the aggregate six months within 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 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying onadvertising, for the enterprisesupply of information, any other activity of for scientific research or for similar activities which have a preparatory or auxiliary character, for the enterprise; (f) the maintenance of a fixed place of business solely for any combination of activities 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 on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 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 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 that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "permanent establishment" also includeslikewise encompasses: (a) a building site, or a construction, assembly or installation or assembly project, project or supervisory activities connected in connection therewith, but only where such site, project or activities lasts continue for a period of more than 12 twelve months; (b) the furnishing of services, including consultancy or managerial services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (for in the same or a connected project) within territory of the other Contracting State for a period or periods aggregating more than 183 days exceeding in the aggregate six months within any twelve-month twelve -month period. 4. Notwithstanding the preceding provisions of this Article, 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying onadvertising, for the enterprisesupply of information, any other activity of for scientific research or for similar activities which have a preparatory or auxiliary character, for the enterprise; (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs (subparagraphs 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 on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 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 that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise of a Contracting State is wholly or partly carried onon in the other Contracting State. 2. The term "permanent establishment" includes shall include especially: (a) a. a place of management; (b) b. a branch; (c) c. an office; (d) d. a factory; (e) e. a workshop; and; (f) f. a warehouse or premises used as sales outlet; g. a farm or plantation; h. a mine, an oil or gas well, a quarry or any other place of extraction or exploration or exploitation of natural resources, including timber or other forest produce, drilling rig or working ship. 3. The term "permanent establishment" also includeslikewise encompasses: (a) a building site, a or construction, assembly or installation or assembly project, project or supervisory activities connected in connection therewith, but only where such site, project or activities lasts continue for a period of more than 12 6 months; (b) the furnishing of services, including consultancy services, services by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (for the same or a connected project) within the other Contracting State country for a period or periods aggregating more than 183 91 days in within 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, storage or 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 storage or deliverydisplay; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by of another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, scientific research or for the enterprise, any other activity of similar activities which have a preparatory or auxiliary character, for the enterprise; (f) the maintenance of a fixed place of business solely for any combination the purpose of activities mentioned in sub-paragraphs (a) to (e)advertising, provided that or for the overall activity supply of the fixed place of business resulting from this combination is of a preparatory or auxiliary characterinformation. 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 and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterpriseother Contracting State, that enterprise shall be deemed to have a permanent establishment in that the first-mentioned State in respect of any activities which that person undertakes for the enterprise, if such a person: (a) has or habitually exercises in that State an authority to conclude contracts in the name of the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraphparagraph [sic]; or (b) has no such authority, but habitually maintains in the first-mentioned State a stock of goods or merchandise on behalf of the enterprise; or (c) manufactures or processes in that State for the enterprise goods or merchandise belonging to the enterprise. 6. An insurance enterprise of one of the two States shall, except with regard to reinsurance, be deemed to have a permanent establishment in the other State if it collects premiums in the territory of that other State or insures risks situated therein through an employee or through a representative who is not an agent of an independent status within the meaning of paragraph 7 7. An enterprise of one of the two States shall not be deemed to have a permanent establishment in a Contracting the other 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 such a broker or agent carries on activities wholly or almost wholly for that enterprise itself or for that enterprise and other enterprises which are controlled by or have a controlling interest in it, he shall not be considered an agent of an independent status with the meaning of this paragraph. 78. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of managementmanagement of a part of the enterprise; (b) a branch; (c) an office; (d) a factory; (e) a workshop; , and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "“permanent establishment" also includes” likewise encompasses: (a) a building site, or a construction, assembly or installation or assembly project, project or supervisory activities connected in connection therewith, but only where such site, project or activities lasts continue for a period of more than 12 twelve months; (b) the furnishing of services, including consultancy or managerial services, by an enterprise of a Contracting State or through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (for in the same or a connected project) within territory of the other Contracting State for a period or periods aggregating more than 183 days exceeding in the aggregate six months within any twelve-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 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities 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 on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 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 that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "permanent establishment" also includeslikewise encompasses: (a) a building site, or a construction, assembly or installation or assembly project, project or supervisory activities connected in connection therewith, but only where such site, project or activities lasts continue for a period of more than 12 twelve months; (b) the furnishing of services, including consultancy or managerial services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (for in the same or a connected project) within territory of the other Contracting State for a period or periods aggregating more than 183 days exceeding in the aggregate six months within any twelve-month period. 4. Notwithstanding the preceding provisions of this Article, 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying onadvertising, for the enterprisesupply of information, any other activity of for scientific research or for similar activities which have a preparatory or auxiliary character, for the enterprise; (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs (subparagraphs 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 on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 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 that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an the enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a warehouse or premises used as a sales outlet; g) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources.; 3. The term "permanent establishment" also includes:h) a farm or any other place of agricultural activity; (ai) a building site, a construction, construction assembly or installation or assembly project, project or supervisory activities connected in connection therewith, but only where such site, project or activities lasts continue for a period of more than 12 months90 days; (bj) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (for in the same or a connected project) within territory of the other Contracting State for a period or periods aggregating more than 183 90 days in within any twelve-month period. 43. 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, storage or 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 storage or deliverydisplay; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying onadvertising, for the enterprisesupply of information, any other activity of for scientific research or for similar activities which have a preparatory or auxiliary character, for the enterprise; (f) the maintenance of a fixed place of business solely for any combination of activities 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. 54. Notwithstanding the provisions of paragraphs 1 I and 2, where a person - person, other than an agent of an independent status to whom paragraph 6 applies - 5 applies, is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterpriseother 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 in respect State, an authority to conclude contracts on behalf of any activities which that person undertakes for the enterprise, unless the his activities of such person are limited to those mentioned in paragraph 4 which3 of this Article; or b) he has no such authority, if exercised through but habitually maintains in the first mentioned State a fixed place stock of business, would not make this fixed place goods or merchandise from which he regularly delivers goods or merchandise on behalf of business a permanent establishment under the provisions of that paragraphenterprise. 65. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, a general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 76. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "permanent establishment" also includesencompasses: (a) a building site, a construction, assembly or installation or assembly project, project or supervisory activities connected in connection therewith, but only where if such site, project or activities lasts for more than 12 months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State Party through employees or other personnel engaged by the enterprise for such purpose, but only where if activities of that nature continue (for the same or a connected project) within the other Contracting State Party for a period or periods aggregating more than 183 365 days in any twelve15-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 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities 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 on behalf of an enterprise and has, and habitually exercises, in a Contracting State Party an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State Party in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State Party merely because it carries on business in that State Party 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. 7. The fact that a company which is a resident of a Contracting State Party controls or is controlled by a company which is a resident of the other Contracting StateParty, or which carries on business in that other State Party (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "permanent establishment" also includes: (a) a building site, site or a construction, installation construction or assembly project, or installation project or supervisory activities connected in connection therewith, but only where if such site, project or activities lasts for last more than 12 nine months;. (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only where if activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 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 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities 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 and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterpriseother Contracting State, that enterprise shall be deemed to have a permanent establishment in that 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 State an authority to conclude contracts in the name of the enterprise unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph, or b) has no such authority, but habitually maintains in the first-mentioned State a stock of goods or merchandise from which he delivers goods or merchandise on behalf of the enterprise. 6. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other Contracting 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 that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this AgreementConvention, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a1) a place of management; (b2) a branch; (c3) an office; (d4) a factory; (e5) a workshop; , and (f6) a mine, an oil or gas well, a quarry or any other place of extraction or exploitation of natural resources. 3. The term "“permanent establishment" also includes” likewise encompasses: (a1) a building site, a construction, assembly or installation project or assembly any supervisory activity in connection with such site or project, or supervisory activities connected therewith, but only where such site, project or activities lasts activity continues for a period of more than 12 twelve months; (b2) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the an enterprise for such purpose, but only where activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than exceeding in the aggregate 183 days in any twelve-month periodperiod commencing or ending in the fiscal year concerned. 4. Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to include: (a1) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b2) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c3) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d4) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of collecting information, for the enterprise; (e5) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f6) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs subparagraphs (a1) to (e5), 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 on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 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 that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term "A building site or construction or installation project constitutes a permanent establishment" also includes: (a) a building site, a construction, installation or assembly project, or supervisory activities connected therewith, but establishment only where such site, project or activities if it lasts for more than 12 twelve months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 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 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 by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities 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. Paragraph 4 shall not apply to a fixed place of business that is used or maintained by an enterprise if the same enterprise or a closely related enterprise carries on business activities at the same place or at another place in the same Contracting State and a) that place or other place constitutes a permanent establishment for the enterprise or the closely related enterprise under the provisions of this Article, or b) the overall activity resulting from the combination of the activities carried on by the two enterprises at the same place, or by the same enterprise or closely related enterprises 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. 6. For the purposes of paragraph 5, an enterprise is closely related to an enterprise if, based on all the relevant facts and circumstances, one has control of the other or both are under the control of the same persons or enterprises. In any case, an enterprise shall be considered to be closely related to an enterprise if one possesses directly or indirectly more than 50 per cent of the beneficial interest in the other (or, in the case of a company, more than 50 per cent of the aggregate vote and value of the interest in the company) or if another person or enterprise possesses directly or indirectly more than 50 per cent of the beneficial interest (or, in the case of a company, more than 50 per cent of the aggregat the company) in the person and the enterprise or in the two enterprises. 7. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 8 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name on behalf of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 68. 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 that such persons are acting in the ordinary course of their business. 79. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.