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” likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities continue for a period of more than 12 months; (b) the furnishing of services, including consultancy services, by an enterprise 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 country for a period or periods aggregating more than 12 months within any 24-month period. 4. Notwithstanding the provisions of paragraphs 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 paragraph 6 applies—is acting in a Contracting State on behalf of an enterprise of the other Contracting State and has, and habitually exercises, an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in 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 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 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 natu- ral resources. 3. The term “permanent establishment” likewise also encompasses: (a) a building site, a construction, assembly or installation project project, or supervisory supervi- sory activities in connection therewith, but only where if such site, project or activities continue for a period of ac- tivities last more than 12 nine months; (b) the furnishing of services, including consultancy services, by an enterprise 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 country a Contracting State for a period or periods aggregating ag- gregating more than 12 nine months within any 24twelve-month period; c) the use of a structure, installation, drilling rig, ship or other like substantial equipment for the exploration for, or exploitation of, natural resources; or in activities connected with that exploration or exploitation for a period or periods exceeding more than nine months within any twelve-month period. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 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 en- terprise solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise en- terprise 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 collecting information, for the enterpriseenter- prise; (e) the maintenance of a fixed place of business solely for the purpose of carrying car- rying 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 ac- tivity 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, 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 of the other Contracting State, that en- terprise shall be deemed to have a permanent establishment in the first mentioned State and has, in respect of any activities which that person undertakes for the enterprise if such a per- son: a) has and habitually exercises, exercises in that State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in 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 lim- ited 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 enterprise of a Contracting State shall not be deemed to have a permanent establishment in the other Contracting state a Con- tracting State merely because it carries on business in that other Contracting State through a broker, general gen- eral 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 commer- cial and financial relations which differ from those which would have been made be- tween independent enterprises, he will not be considered an agent of an independent status sta- tus within the meaning of this paragraph. 7. 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 per- manent establishment in the other Contracting State if it collects premiums in the xxxxx- xxxx of that other State or insures risks situated therein through a person other than an agent of an independent status to whom paragraph 6 applies. 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 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” likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities continue for a period of more than 12 months; (b) the furnishing of services, including consultancy services, by an and enterprise 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 country a Contracting State for a period or periods aggregating more than 12 months within any 24-twenty four month period. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 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. 5. 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—applies - is acting in a Contracting State on behalf of an enterprise of the other Contracting State State, and has, and habitually exercises, an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in 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 the other Contracting state 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” likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities 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 country project for a period or periods aggregating more than 12 six months within any 24twelve-month period. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 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 the provisions of paragraph 6 applies—apply–is acting in a Contracting State on behalf of an enterprise of the other Contracting State and hasState, and has and habitually exercises, exercises an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in 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 the other Contracting state 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” " likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities continue for a period of more than 12 months;. (b) the furnishing of services, including consultancy services, by an enterprise 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 country for a period or periods aggregating more than 12 months within any 24-24- month period. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 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—person - other than an agent of an independent status to whom paragraph 6 applies—applies - is acting in a Contracting State on behalf of an enterprise of the other Contracting State and hasState, has and habitually exercises, exercises an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in 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 the other Contracting state 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” likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities 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 such purposeother Contracting State, but only where such activities of that nature continue (for the same project or a connected project) within the country for a period or periods aggregating more than 12 six months within any 24twelve-month period. 4. Notwithstanding the provisions of paragraphs 1 to 3 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 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 of the other Contracting State and has, has and habitually exercises, exercises an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in 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 the other Contracting state 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, 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” likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities 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 country project for a period or periods aggregating more than 12 six months within any 24twelve-month period. 4. Notwithstanding the provisions of paragraphs 1 to 3 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 of 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 the provisions of paragraph 6 appliesapply—is acting in a Contracting State on behalf of an enterprise of the other Contracting State and hasState, has and habitually exercises, exercises an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in 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 Contraction State shall not be deemed to have a permanent establishment in the other Contracting state 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” likewise encompasses" also includes: (a) a building site, a construction, installation or assembly or installation project project, or supervisory activities in connection connected therewith, but only where such site, project or activities continue lasts 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 (for the same or a connected project) within the country other Contracting State for a period or periods aggregating more than 12 months within 183 days in any 24twelve-month period. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 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—person - other than an agent of an independent status to whom 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 Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in the first-mentioned Contracting 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 the other a Contracting state 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” likewise encompasses" also includes: (a) a building site, a construction, installation or assembly or installation project project, or supervisory activities in connection connected therewith, but only where such site, project or activities 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 country other Contracting State for a period or periods aggregating more than 12 months within 183 days in any 24-month periodcalendar year. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 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 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 Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in the first-mentioned Contracting 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 the other a Contracting state 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 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” likewise encompasses:; (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 or installation project or supervisory activities in connection therewith, but only where such site, project or activities 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 one of the Contracting 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 country other Contracting State for a period or periods aggregating more than 12 six months within any 24-twelve- month period. 43. Notwithstanding the preceding provisions of paragraphs 1 to 3 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, 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—person -- other than an agent of an or in independent status to whom paragraph 6 applies—5 applies -- is acting in a Contracting State on behalf of an the enterprise of the other Contracting State 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 the first-mentioned Contracting 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 the other Contracting state 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. 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 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 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” likewise encompasses:; (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 or installation project or for supervisory activities in connection therewith, but only ,where such site, project or activities 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 one of the Contracting 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 country other Contracting State for a period or periods aggregating more than 12 6 months within any 24-twelve month period. 43. Notwithstanding the provisions preceding provision of paragraphs 1 to 3 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 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—person other than an agent of an independent status to whom paragraph 6 applies—supplies - is acting in a Contracting State on behalf of an the enterprise of the other Contracting State and hasState, and habitually exercises, an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in the first-first mentioned Contracting State 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 the other Contracting state State merely because it carries on business in that other Contracting State 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 enterpriseenterprise 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 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 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” likewise encompasses: (a) a A building site, a or construction, assembly assembly, or installation project or supervisory activities in connection therewith, but constitutes a permanent establishment only where such site, project or activities continue for a period of if it lasts 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 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 country a Contracting State for a period or periods aggregating more than 12 months 183 days within any 24twelve-month period. 45. Notwithstanding the preceding provisions of paragraphs 1 to 3 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—person-- other than an agent of an independent status to whom paragraph 6 applies—7 applies -- is acting in a Contracting State on behalf of an enterprise of the other Contracting State State, and has, and habitually exercises, in 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 the first-mentioned 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 the other Contracting state 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. 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 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” likewise encompasses: (a) a A building site, a construction, assembly or installation project or supervisory activities in connection therewith, activity connected therewith constitutes a permanent establishment but only where if such site, project or activities continue activity continues for a period of more than 12 twelve months;. (b) the 4. The furnishing of services, including consultancy services, by an enterprise 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 country Contracting Party for a period or periods aggregating more than 12 months within exceeding in the aggregate 183 days in any 24-twelve month periodperiod commencing or ending in the fiscal year concerned. 45. Notwithstanding the preceding provisions of paragraphs 1 to 3 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 applies—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 Contracting Party an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in the first-mentioned Contracting State that 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 of a Contracting State shall not be deemed to have a permanent establishment in the other a Contracting state Party merely because it carries on business in that other Contracting 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. 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 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 Contracting 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” likewise also encompasses: (a) a building site, a construction, installation or assembly or installation project or supervisory activities in connection therewith, but only where if such site, project or activities continue for a period of last more than 12 nine (9) months; (b) the furnishing of services, including consultancy services, by an enterprise 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 country a Contracting Party for a period or periods aggregating more than 12 months 183 days within any 24twelve-month period. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 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, 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 6 applies—applies - is acting in a Contracting State Party on behalf of an enterprise of the other Contracting State and has, and habitually exercises, an authority to conclude contracts in the name of the enterpriseParty, that enterprise shall be deemed to have a permanent establishment in the first-first mentioned Contracting State 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 of a Contracting State shall not be deemed to have a permanent establishment in the other a Contracting state Party merely because it carries on business in that other Contracting 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. 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 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 Contracting 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” likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities 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 country project for a period or periods aggregating more than 12 6 months within any 2412-month period. 4. Notwithstanding the provisions of paragraphs 1 to 3 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 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 appliesapply—is acting in a Contracting State on behalf of an enterprise of the other Contracting State and hasState, has and habitually exercises, exercises an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in 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 the other Contracting state 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” likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities 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 country project for a period or periods aggregating more than 12 months month within any 24-24 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 provisions of paragraphs 1 to 3 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 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 the provisions of paragra 6 appliesapply—is acting in a Contracting State on behalf of an enterprise of the other Contracting State and hasState, and has a habitually exercises, exercises an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in 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 the other Contracting state 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, 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” " likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities 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 country project for a period or periods aggregating more than 12 six months within any 24twelve-month period. 4. Notwithstanding the provisions of paragraphs 1 to 3 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 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—, 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 hasState, has and habitually exercises, exercises an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in 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 the other Contracting state 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” likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities 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 country project for a period or periods aggregating more than 12 six months within any 24twelve-month period. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 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. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person—other than an agent of an independent status to whom paragraph 6 applies—is acting in a Contracting State on behalf of an enterprise of the other Contracting State State, and has, and habitually exercises, in the first-mentioned State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in 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 the other a Contracting state 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” likewise term“permanent establishment”likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities 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 country project for a period or periods aggregating more than 12 6 months within any 2412-month period. 4. Notwithstanding the provisions of paragraphs 1 to 3 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 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 hasState, has and habitually exercises, an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in 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 the other Contracting state 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 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” " likewise encompassesincludes : (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities continue for a period of more than 12 months183 days; (b) the furnishing of services, including consultancy services, by an enterprise 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 country Contracting State for a period or periods aggregating more than 12 months 91 days within any 24-month periodcontinuous period of twelve months. (4. ) Notwithstanding the preceding provisions of paragraphs 1 to 3 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, 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 the provisions of paragraphs 1 and 2, where a person—other than an agent of an independent status to whom paragraph 6 applies—is ) 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 the provisions of paragraph (7) of this Article apply, shall be deemed to be a permanent establishment in the first-mentioned State and if : (a) he has, and habitually exercisesexercises in that 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 first-mentioned other Contracting State if it collects premiums in respect of any activities which the territory or that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised other State 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 the other Contracting state State merely because it carries carried on business in that other Contracting State through a broker, general commission agent or any other agent of an independent status, provided that where such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf to the business of that enterprise, he will 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 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” likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities 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 country project for a period or periods aggregating more than 12 six months within any 24twelve-month period. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 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 the provisions of paragraph 6 appliesapply—is acting in a Contracting State on behalf of an enterprise of the other Contracting State and has, and habitually exercises, an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in 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 the other Contracting state 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, 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 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” likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities 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 country project for a period or periods aggregating more than 12 6 months within any 24-12 month period. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 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. 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 appliesapply—is acting in a Contracting State on behalf of an enterprise of the other Contracting State and hasState, and has and habitually exercises, exercises an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in 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 the other Contracting state 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” likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, therewith but only where such site, project or activities 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 country project for a period or periods aggregating more than 12 six months within any 24-twelve month period. 4. Notwithstanding the provisions of paragraphs 1 to 3 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 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 appliesapply—is acting in a Contracting State on behalf of an enterprise of the other Contracting State and has, and habitually exercises, exercises an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in 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 the other Contracting state 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” likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities 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 country project for a period or periods aggregating more than 12 months within any 24-month period. 4. Notwithstanding the provisions of paragraphs 1 to 3 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, 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 of the other Contracting State and hasState, has and habitually exercises, exercises an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in the first-mentioned 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 the other Contracting state 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 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 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 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; g) exploration of natural resources including a drilling rig or ship; h) a warehouse, in relation to a person providing storage facilities for others. 3. The term “permanent establishment” likewise encompasses: (a) a building site, a construction, assembly site or construction or installation project or supervisory activities in connection therewith, but only where such site, project or activities continue for a period of if it lasts more than 12 months183 days; (b) the furnishing of services, including consultancy services, by an enterprise 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 country for a period or periods aggregating more than 12 months 90 days within any 24-12 month period. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 this Article, the term “permanent establishment” shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or occasional delivery 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 occasional 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. 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 for more than six months by, for or under contract with the enterprise. 6. 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—8 applies - is acting in a Contracting State on behalf of an enterprise of the other Contracting State and has, and habitually exercises, an authority to conclude contracts in the name of the enterpriseState, that enterprise shall be deemed to have a permanent establishment in the first-first- mentioned Contracting State in respect of any activities which that person undertakes for the enterprise, if such a person: a) has and habitually exercise 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. 67. Notwithstanding the preceding provisions of this Article, an insurance enterprise of a 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 Contracting State or insures risks situated therein through a person other an agent of an independent status to whom paragraph 8 applies. 8. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in the other Contracting state 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 where such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise, he will shall not be considered an agent of an independent status within the meaning of this paragraph, if it is shown that the transactions between the agent and the enterprise were not made under arms- length conditions. In such a case, the provisions of paragraph 6 shall apply. 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 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 " 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” likewise encompasses:, 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, assembly site or installation construction project or supervisory activities in connection therewith, but only where provided such site, project or activities continue activity continues for a period of more than 12 months183 days; (bk) an assembly or installation project which exists for more than 6 months; and (l) the furnishing of services, including consultancy services, services by an enterprise 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 country for a period or periods aggregating more than 12 3 months within any 24-twelve month period. 43. Notwithstanding the preceding provisions of paragraphs 1 to 3 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, 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—person - other than an agent of an independent status to whom 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, an authority to conclude contracts in the name of the enterpriseState, that enterprise shall be deemed to have a permanent establishment in 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 the other Contracting state 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 enterpriseenterprise 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” likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities 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 country for a period or periods aggregating more than 12 six months within any 24twelve-month period. 4. Notwithstanding the provisions of paragraphs 1 to 3 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 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—other than an agent of an independent status to whom the provisions of paragraph 6 applies—is acting in a Contracting State on behalf of an enterprise of the other Contracting State and has, and habitually exercises, in 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 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 the other Contracting state 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 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” likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities continue for a period of more than 12 six months; (b) the furnishing of services, including consultancy services, by an enterprise 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 country Contracting State for a period or periods aggregating more than 12 six months within any 24twelve-month periodperiod commencing or ending in the fiscal year concerned; (c) the performance of professional services or other activities of an independent character by an individual, but only where those services or activities continue within a Contracting State for a period or periods exceeding in the aggregate more than six months within any twelve-month period commencing or ending in the fiscal year concerned. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 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;; 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 2, where a person—person – other than an agent of an independent status to whom 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 Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in the first-mentioned Contracting 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 the other a Contracting state 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 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” " likewise encompasses: (a) a building site, site or a construction, assembly or installation project or supervisory activities in connection therewith, but only where such site, construction, assembly, project or activities 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 country other Contracting State for a period or periods aggregating more than 12 exceeding in the aggregate six months within any 24-twelve month period. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 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—person - other than an agent of an independent status to whom paragraph 6 applies—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 Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in the first-mentioned Contracting 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 Notwithstanding the foregoing provisions of this Article, an insurance enterprise of a Contracting State shall not shall, except in regard to reinsurance, be deemed to have a permanent establishment in the other Contracting state 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 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 business and that in their commercial or financial relations with the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise, he will conditions are not be considered an agent of an made or imposed that differ from those generally agreed to by independent status within the meaning of this paragraphagents. 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 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 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” likewise encompasses:resources ; (ag) a place of exploration of natural resources ; (h) a building site, a construction, assembly site or installation construction project or supervisory activities in connection therewith, but only where such site, project or activities continue activity continues for a period of more than 12 monthssix months ; (bi) the furnishing of servicesa warehouse, including consultancy services, by an enterprise through employees or other personnel engaged by the enterprise in relation to a person providing storage facilities for such purpose, but only where activities of that nature continue (for the same or a connected project) within the country for a period or periods aggregating more than 12 months within any 24-month periodothers. 43. Notwithstanding the preceding provisions of paragraphs 1 to 3 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, 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 the provisions of paragraphs 1 and 2, where a person—other than an agent of an independent status to whom paragraph 6 applies—is A person acting in a Contracting State on behalf of an enterprise of the other Contracting State and has, and habitually exercises, (other than an authority agent of an independent status to conclude contracts in the name of the enterprise, that enterprise whom paragraph 6 applies) shall be deemed to have be a permanent establishment in the first-mentioned Contracting State if : (a) he has, and habitually exercises in respect the 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 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 but habitually maintains in the other Contracting state merely because it carries on business in that other Contracting first-mentioned State through a broker, general commission agent stock of goods 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 merchandise from which he regularly delivers goods or almost wholly merchandise on behalf of that enterprisethe enterprise ; or (c) in so acting, 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 manufactures or is controlled by a company which is a resident of the other Contracting State, or which carries on business processes in that other Contracting State (whether through a permanent establishment for the enterprise goods or otherwise), shall not of itself constitute either company a permanent establishment of merchandise belonging to the otherenterprise.

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” likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities 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 country project for a period or periods aggregating more than 12 six months within any 24twelve-month period. 4. Notwithstanding the provisions of paragraphs 1 to 3 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 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—–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 hasState, has and habitually exercises, exercises an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in 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 the other Contracting state 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” likewise encompasses" also includes: (a) a building site, a construction, installation or assembly or installation project project, or supervisory activities in connection connected therewith, but only where such site, project or activities continue lasts 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 country other Contracting State for a period or periods aggregating more than 12 months within 183 days in any 2412-month period. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 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—person - other than an agent of an independent status to whom 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 Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in the first-mentioned Contracting 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 the other a Contracting state 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 (a) Notwithstanding the provisions of paragraphs 1 and 2, the term “permanent establishment” likewise encompasses: (a) shall include a building site, a construction, assembly or installation project or project, as well as supervisory activities in connection therewith, but only where such site, project or activities continue for a period of more than 12 months; (b) the furnishing of services, services including consultancy services, services by an enterprise 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 country for a period or periods aggregating of more than 12 months within any 24-month periodthree months. (b) However, in 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 paragraphs 1 to 3 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, 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 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 otherwise maintained for any of the other Contracting State and has, and habitually exercises, an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in 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 paragraphArticle. 6. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in one of the other Contracting state States 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 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 of the other State, that enterprise shall be deemed to have a permanent establishment in 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. 8. Subject to the preceding provisions of this Article, 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 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 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 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” likewise encompassesalso includes: (a) a building site, a construction, assembly or installation project or a supervisory activities in connection or consultancy activity connected therewith, but only where if such site, project or activities continue 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 country other Contracting State for a period or periods aggregating more than 12 9 months within any 24twelve-month period. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 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. 5. 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—applies − 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 the first-mentioned Contracting 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 the other a Contracting state 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. a place of management; (b) b. a branch; (c) c. an office; (d) d. a factory; (e) e. a workshop, and; (f) f. a mine, an oil or gas well, a quarry or any other place of extraction of natural resources, including an installation or structure used for the exploration or exploitation of natural resources; and g. a warehouse, in relation to a person providing storage facilities for others. 3. The term “permanent establishment” likewise encompasses: (a) a A building site, a construction, installation or assembly or installation project or any supervisory activities activity in connection therewith, but with such site or project constitutes a permanent establishment only where such site, project or activities continue for a period of if it lasts more than 12 six months; (b) the furnishing of services, including consultancy services, by an enterprise 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 country for a period or periods aggregating more than 12 months within any 24-month period. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 this Article, the term “permanent establishment” establishment shall be deemed not to include: (a) a. the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) b. the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c) c. the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) 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) 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;; and (f) 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 paragraph 1 and 2, where a person—---other than an agent of an independent status to whom paragraph 6 applies—---is acting in a Contracting State on behalf of an enterprise of the other Contracting State 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 the first-mentioned Contracting 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 the other a Contracting state 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 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 or exploitation of natural resources. 3. The term “"permanent establishment” " likewise encompasses: (a) encompasses a building site, a construction, assembly or installation project or any supervisory activities activity in connection therewithwith such site or project, but only where such site, project or activities continue activity continues for a period of more than 12 six months; (b) the furnishing of services, including consultancy services, by an enterprise 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 country for a period or periods aggregating more than 12 months within any 24-month period. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 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;; 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 2, where a person—person - other than an agent of an independent status to whom 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 Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in the first-mentioned Contracting 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 the other a Contracting state 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” likewise also encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where if such site, project or activities continue for a period of last more than 12 six months; (b) the furnishing of services, including consultancy services, by an enterprise 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 country a Contracting Party for a period or periods aggregating more than 12 months 183 days within any 24-twelve- month period. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 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—person – other than an agent of an independent status to whom 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 Contracting Party an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in the first-mentioned Contracting State that 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 of a Contracting State shall not be deemed to have a permanent establishment in the other a Contracting state Party merely because it carries on business in that other Contracting 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. 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 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 Contracting 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; (g) a permanent sales exhibition. 3. The term “"permanent establishment” " likewise encompasses: (a) encompasses a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities continue for a period of more than 12 six months; (b) the furnishing of services, including consultancy services, by an enterprise 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 country for a period or periods aggregating more than 12 months within any 24-month period. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 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. 5. 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—applies is acting in a Contracting State on behalf of an enterprise of the other Contracting State and has, and habitually exercises, an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in 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. However, if a person occasionally maintains in the first-mentioned State a stock of goods or merchandise from which he seldom delivers goods or merchandise on behalf of the enterprise, that person shall not constitute a permanent establishment for such enterprise. 6. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in the other Contracting state 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” likewise " also encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where if such site, project or activities continue for a period of 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 country other Contracting State for a period or periods aggregating more than 12 months 183 days within any 24twelve-month period. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 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—person - other than an agent of an independent status to whom paragraph 6 applies—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 Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in the first-mentioned Contracting 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 Notwithstanding the preceding provisions of this Article, an insurance enterprise of a Contracting State shall not shall, except in regard to re-insurance, be deemed to have a permanent establishment in the other Contracting state 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 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, 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 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 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” likewise encompasses" also includes: (a) a building site, a construction, assembly site or construction or installation project or supervisory activities in connection therewith, but therewith constitutes a permanent establishment only where such site, project or activities continue for a period of if it lasts more than 12 twelve months;, (b) the furnishing of services, including consultancy services, or managerial services by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, purpose but only where activities of that nature continue (for in the same or a connected project) within territory of the country other Contracting State for a period or periods aggregating exceeding in the aggregate more than 12 6 months within any 24twelve-month period. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 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, or 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 2 of this Article a person—other than an agent of an independent status to whom paragraph 6 applies—is person acting in a Contracting State on behalf of an enterprise of the other Contracting State and has, and habitually exercises, - other than an authority agent of an independent status to conclude contracts in the name whom paragraph 6 of the enterprise, that enterprise this Article applies - shall be deemed to have be a permanent establishment of the enterprise in the first-mentioned Contracting State if (a) he has, and habitually exercises in respect the first-mentioned State authority to conclude contracts for, or on behalf of, such enterprise, or (b) he maintains in the first-mentioned State a stock of any activities goods or merchandise belonging to the enterprises from which that person undertakes for the he regularly sells goods or merchandise for, or on behalf of, such 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 Notwithstanding the preceding provisions of this Article, an insurance enterprise of a Contracting State shall not shall, except in regard to reinsurance, be deemed to have a permanent establishment in the other Contracting state 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 other Contracting State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in vin 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 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 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” " likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities continue for a period of more than 12 six months; (b) the furnishing of services, including consultancy services, services by an enterprise 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 country for a period or periods aggregating more than 12 three months within any 24-twelve- month period. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 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, 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—person - other than an agent of an independent status to whom paragraph 6 applies—7 applies - is acting in a Contracting State on behalf of an enterprise of the other Contracting State and has, and habitually exercises, an authority to conclude contracts in the name of the enterpriseState, that enterprise shall be deemed to have a permanent establishment in 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 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 the other Contracting state 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, unless he demonstrates that transactions have been made under arms' length conditions. 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 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” likewise also encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where if such site, project or activities continue for a period of last more than 12 six months; (b) the furnishing of services, including consultancy services, by an enterprise 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 country a Contracting Party for a period or periods aggregating more than 12 months 183 days within any 24twelve-month period. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 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. 5. 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—applies - is acting in a Contracting State on behalf of an enterprise of the other Contracting State and has, and habitually exercises, in a Contracting Party an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in the first-mentioned Contracting State that 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 of a Contracting State shall not be deemed to have a permanent establishment in the other a Contracting state Party merely because it carries on business in that other Contracting 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. 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 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 Contracting 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” likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities activieies continue 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 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 country project for a period or periods aggregating more than 12 months within any 24-month periodtwelve months. 4. Notwithstanding the provisions of paragraphs 1 to 3 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 enterpriseenterprises; (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 the provisions of paragraph 6 appliesapply—is acting in a Contracting State on behalf of an enterprise of the other Contracting State and hasState, has and habitually exercises, exercises an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in 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 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. 6. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in the other Contracting state 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 shall not be considered an agent of an independent status within the meaning of this paragraphparagraph if the transactions between the agent and the enterprise were not made under arm’s length conditions. 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 AgreementConvention, 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 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 relating to the exploration for or the exploitation of natural resources. 3. The term “permanent establishment” likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities continue for a period of more than 12 six months; (b) the furnishing of services, including consultancy services, by an enterprise through employees or other personnel engaged by the enterprise for such purpose, but only where such activities of that nature continue (for the same or a connected project) within the country for a period or periods aggregating more than 12 six months within any 24-twelve month period. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 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. 5. Notwithstanding the provisions of paragraphs 1 1, 2 and 23, where a person—person - other than an agent of an independent status to whom paragraph 6 applies—applies - is acting in a Contracting State on behalf of an enterprise of the other a Contracting State and has, and habitually exercises, exercises in the other Contracting State an authority to conclude contracts contacts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in the first-mentioned Contracting that other State 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 of a Contracting State shall not be deemed to have a permanent establishment in the other Contracting state 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. III. TAXATION OF INCOME Article 6 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. For the purposes of this Convention, the term “immovable property” shall have the meaning which it has under the applicable taxation law of the Contracting State in which the property in question is situated and shall include any option or similar right in respect thereof. The term shall in any case include property accessory to immovable property, livestock and equipment used in agriculture and forestry, tights 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 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 and to income from the alienation of such property. 4. The provisions of paragraphs 1 and 3 shall also apply to the income from immovable property of an enterprise and to income from immovable property used for the performance of independent personal services.

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 or exploitation of natural resources. 3. The term “permanent establishment” likewise encompasses: (a) encompasses a building site, a construction, assembly or installation project or any supervisory activities activity in connection therewithwith such site or project, but only where such site, project or activities continue activity continues for a period of more than 12 six months; (b) the furnishing of services, including consultancy services, by an enterprise 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 country for a period or periods aggregating more than 12 months within any 24-month period. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 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;; 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 2, where a person—person - other than an agent of an independent status to whom 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 Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in the first-mentioned Contracting 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 the other a Contracting state 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” likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities 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 country for a period or periods aggregating more than 12 six months within any 24twelve-month period. 4. Notwithstanding the provisions of paragraphs 1 to 3 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 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 appliesapply—is acting in a Contracting State on behalf of an enterprise of the other a Contracting State and has, and habitually exercises, in 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 the firstlast-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 the other Contracting state 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” likewise encompasses" also includes: (a) a building site, site or a construction, construction or assembly or installation project or supervisory activities in connection therewith, but only where if such site, project or activities continue for a period of 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 country other Contracting State for a period or periods aggregating more than 12 months within 183 days in any 24twelve-month period. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 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—person - other than an agent of an independent status to whom 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, an authority to conclude contracts in the name of the enterpriseState, that enterprise shall be deemed to have a permanent establishment in 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 the other Contracting state 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” likewise also encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where if such site, project or activities continue for a period of last more than 12 six months; (b) the furnishing of services, including consultancy services, by an enterprise 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 country a Contracting Party for a period or periods aggregating more than 12 months 183 days within any 24twelve-month period. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 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—person – other than an agent of an independent status to whom 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 Contracting Party an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in the first-mentioned Contracting State that 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 of a Contracting State shall not be deemed to have a permanent establishment in the other a Contracting state Party merely because it carries on business in that other Contracting 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. 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 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 Contracting 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” likewise also encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where if such site, project or activities continue for a period of last more than 12 nine months; (b) the furnishing of services, including consultancy services, by an enterprise 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 country a Contracting Party for a period or periods aggregating more than 12 months 270 days within any 24twelve-month period. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 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—person - other than an agent of an independent status to whom 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 Contracting Party an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in the first-mentioned Contracting State that 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 of a Contracting State shall not be deemed to have a permanent establishment in the other a Contracting state Party merely because it carries on business in that other Contracting 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. 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 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 Contracting 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 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” likewise encompasses: (a) a building site, or a construction, assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities 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 country other Contracting State for a period or periods aggregating more than 12 exceeding in the aggregate six months within any 24-twelve month period. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 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—person - other than an agent of an independent status to whom 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 Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in the first-mentioned Contracting 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 the other a Contracting state 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 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” likewise encompasses:; (ag) an agricultural, pastoral or forestry property; (h) a building site, or a construction, installation or assembly or installation project or supervisory activities in connection therewithproject, but only where such site, project or activities continue which exists for a period of more than 12 months; (b) the furnishing of services, including consultancy services, by an enterprise 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 country for a period or periods aggregating more than 12 months within any 24-month period. 43. Notwithstanding the provisions of paragraphs 1 to 3 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, 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;scientific research; or (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-subparagraphs (paragraphs (a) to (e), provided that ) if the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 4. 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: (a) it carries on supervisory activities in that State for more than 12 months in connection with a building site, or a construction, installation or assembly project, which is being undertaken in that State by another enterprise; or (b) substantial equipment is used in that State for more than 12 months by, for or under contract with the enterprise. 5. Notwithstanding A person acting in one of the provisions Contracting States on behalf of paragraphs 1 and 2, where a personan enterprise of the other Contracting State—other than an agent of an independent status to whom paragraph 6 applies—is acting shall be deemed to be a permanent establishment of that enterprise in a Contracting the firstmentioned State on behalf of an enterprise of if: (a) the other Contracting State and person has, and habitually exercisesexercises in that 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 the first-mentioned Contracting 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 paragraphState for the enterprise goods or merchandise belonging to the enterprise. 6. An enterprise of a one of the Contracting State States shall not be deemed to have a permanent establishment in the other Contracting state State merely because it carries on business in that other Contracting State 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 business. However, when the activities of person’s business as such an agent are devoted wholly a broker or almost wholly on behalf of that enterprise, he will not be considered an agent of an independent status within the meaning of this paragraphagent. 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 Contracting State (whether through a permanent establishment or otherwise), shall not of itself constitute make 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) premises used as sales outlets; (d) an office; (de) a factory; (ef) a workshop, and; (fg) a mine, an oil or gas well, a quarry or any other place of extraction of natural resourcesresources including timber or other forest produce; and (h) a farm or plantation. 3. The term “"permanent establishment” " likewise encompasses: (a) encompasses a building site, a construction, assembly or installation project or supervisory activities in connection therewith, therewith but only where such site, project or activities continue for a period of more than 12 six months; (b) the furnishing of services, including consultancy services, by an enterprise 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 country for a period or periods aggregating more than 12 months within any 24-month period. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 this Article, the term “"permanent establishment” " shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or occasional delivery of goods or merchandise belonging to the enterpriseenterprise and deriving no profits; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or deliveryoccasional delivery and deriving no profits; (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 activities 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, 2 where a person—person – other than an agent of an independent status to whom paragraph 6 applies—7 applies -- is acting in a Contracting State on behalf of an enterprise of the other Contracting State and has, and habitually exercises, an authority to conclude contracts in the name of the enterpriseState, that enterprise shall be deemed to have a permanent establishment in 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 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. 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 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 of a Contracting State shall not be deemed to have a permanent establishment in the other Contracting state 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. 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 Contracting State (whether through a permanent establishment or otherwise), ) shall not of itself constitute either company a permanent establishment of the other.. Chapter III

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” " likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities continue for a period of more than 12 months183 days; (b) the furnishing of services, including consultancy services, services by an enterprise 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 country for a period or periods aggregating more than 12 three months within any 24twelve-month period. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 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, 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—person -- other than an agent of an independent status to whom paragraph 6 applies—7 applies -- is acting in a Contracting State on behalf of an enterprise of the other Contracting State and has, and habitually exercises, an authority to conclude contracts in the name of the enterpriseState, that enterprise shall be deemed to have a permanent establishment in 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 of a Contracting State shall not be deemed to have a permanent establishment (b) has no such authority, but habitually maintains in the other Contracting state merely because it carries on business in that other Contracting first- mentioned State through a broker, general commission agent stock of goods 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 merchandise from which he regularly delivers goods or almost wholly merchandise on behalf of that the 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 ; 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” " likewise encompasses: includes: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities continue for a period of more than 12 months; 183 days; (b) the furnishing of services, including consultancy services, by an enterprise 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 country Contracting State for a period or periods aggregating more than 12 months 91 days within any 24-month periodcontinuous period of twelve months. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 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, 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 the provisions of paragraphs 1 and 2, where a person—other than an agent of an independent status to whom paragraph 6 applies—is 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 the provisions of paragraph 7 of the Article apply, shall be deemed to be a permanent establishment in the first-mentioned State and if: (a) he has, and habitually exercisesexercises in that 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 first-mentioned other Contracting State if it collects premiums in respect the territory 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 other State 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 the other Contracting state State merely because it carries carried on business in that other Contracting State through a broker, general commission agent or any other agent of an independent status, provided that where such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf to the business of that enterprise, he will 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 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” likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities 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 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 country project for a period or periods aggregating more than 12 6 months within any 24-12 month period. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 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. 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 appliesapply—is acting in a Contracting State on behalf of an enterprise of the other Contracting State and hasState, has and habitually exercises, exercises an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in 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 the other Contracting state 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 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” likewise encompasses:h) a farm or any other place of agricultural activity; (ai) a building site, a construction, construction assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities continue for a period of more than 12 months90 days; (bj) the furnishing of services, including consultancy services, by an enterprise 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 country other Contracting State for a period or periods aggregating more than 12 months 90 days within any 24twelve-month period. 43. Notwithstanding the preceding provisions of paragraphs 1 to 3 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, 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—, other than an agent of an independent status to whom paragraph 6 5 applies—, is acting in a Contracting State on behalf of an enterprise of the other Contracting State and has, and habitually exercises, an authority to conclude contracts in the name of the enterpriseState, that enterprise shall be deemed to have a permanent establishment in the first-first- mentioned Contracting State if: a) he has, and habitually exercises in respect that 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 the other Contracting state State merely because it carries on business in that other Contracting 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. 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. 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 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 " shall include especially: (a) a place of management; (b) a branch; (c) premises used as sales outlets; (d) an office; (de) a factory; (ef) a workshop, and; (fg) a mine, an oil or gas well, a quarry or any other place of extraction of natural resourcesresources including timber or other forest produce; and (h) a farm or plantation. 3. The term “"permanent establishment” " likewise encompasses: (a) encompasses a building site, a construction, assembly or installation project or supervisory activities in connection therewith, therewith but only where such site, project or activities continue for a period of more than 12 six months; (b) the furnishing of services, including consultancy services, by an enterprise 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 country for a period or periods aggregating more than 12 months within any 24-month period. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 this Article, the term “"permanent establishment” " shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or occasional delivery of goods or merchandise belonging to the enterpriseenterprise and deriving no profits; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or deliveryoccasional delivery and deriving no profits; (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 activities 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, 2 where a person—person -- other than an agent of an independent status to whom paragraph 6 applies—7 applies -- is acting in a Contracting State on behalf of an enterprise of the other Contracting State and has, and habitually exercises, an authority to conclude contracts in the name of the enterpriseState, that enterprise shall be deemed to have a permanent establishment in 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 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. 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 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 of a Contracting State shall not be deemed to have a permanent establishment in the other Contracting state 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. 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 Contracting State (whether through a permanent establishment or otherwise), ) shall not of itself constitute either company a permanent establishment of the other.. Chapter III

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” " likewise encompasses: (a) a building site, or a construction, assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities 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 country other Contracting State for a period or periods aggregating more than 12 exceeding in the aggregate six months within any 24twelve-month period. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 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 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 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 Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in the first-mentioned Contracting 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 the other a Contracting state 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 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” likewise encompasses:h) a farm or any other place of agricultural activity; (ai) a building site, a construction, construction assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities continue for a period of more than 12 months90 days; (bj) the furnishing of services, including consultancy services, by an enterprise 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 country other Contracting State for a period or periods aggregating more than 12 months 90 days within any 24twelve-month period. 43. Notwithstanding the preceding provisions of paragraphs 1 to 3 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, 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—, other than an agent of an independent status to whom paragraph 6 5 applies—, is acting in a Contracting State on behalf of an enterprise of the other Contracting State and has, and habitually exercises, an authority to conclude contracts in the name of the enterpriseState, that enterprise shall be deemed to have a permanent establishment in the first-first- mentioned Contracting State if: a) he has, and habitually exercises in respect that 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 the other Contracting state State merely because it carries on business in that other Contracting 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. 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. 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 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” likewise also encompasses: (a) a building site, site or a construction, construction or assembly or installation project or supervisory activities in connection therewith, but only where if such site, site or project or activities continue for a period of last more than 12 6 months; (b) the furnishing of services, including consultancy services, by an enterprise 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 country a Contracting State for a period or periods aggregating more than 12 6 months within any 24twelve-month period. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 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. 5. 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—applies – 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 the first-mentioned Contracting 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 the other Contracting state 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, 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 Contracting 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 Contracting 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 including the breeding and cultivation of fish 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 shall also be considered as “immovable property”. 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 and to income from the immovable property used for the performance of independent personal services.

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” likewise encompasses: (a) encompasses a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities continue for a period of more than 12 six months; (b) the furnishing of services, including consultancy services, by an enterprise 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 country for a period or periods aggregating more than 12 months within any 24-month period. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 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 doing advertising, supplying information, performing scientific research, preparing the placement of loans or 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 subsup-paragraphs (a) to (e), provided that the overall activity of the fixed place of business resulting from this combination is of a retains its 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 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 the first-mentioned Contracting 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 Notwithstanding the preceding provisions of this Article, an insurance business of a Contracting State shall, except in regard to re-insurance, 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 a person other than an agent of an independent status to whom the following paragraph applies. 7. An enterprise shall not be deemed to have a permanent establishment in the other a Contracting state 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. Howeverbusiness and, when in their commercial or financial relations with the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise, he will they are not be considered an agent of an bound by accepted or imposed conditions which differ from those generally agreed to by independent status within the meaning of this paragraphagents. 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 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 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” " likewise encompasses: (a) a building site, or a construction, assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities 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 country other Contracting State for a period or periods aggregating more than 12 exceeding in the aggregate six months within any 24-month twelve -month period. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 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 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 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 Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in the first-mentioned Contracting 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 the other a Contracting state 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 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” likewise encompasses:h) a farm or any other place of agricultural activity; (ai) a building site, a construction, construction assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities continue for a period of more than 12 months90 days; (bj) the furnishing of services, including consultancy services, by an enterprise 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 country other Contracting State for a period or periods aggregating more than 12 months 90 days within any 24twelve-month period. 43. Notwithstanding the preceding provisions of paragraphs 1 to 3 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, 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—, other than an agent of an independent status to whom paragraph 6 5 applies—, is acting in a Contracting State on behalf of an enterprise of the other Contracting State and has, and habitually exercises, an authority to conclude contracts in the name of the enterpriseState, that enterprise shall be deemed to have a permanent establishment in the first-first- mentioned Contracting State if: a) he has, and habitually exercises in respect that 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 the other Contracting state State merely because it carries on business in that other Contracting 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. 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. 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 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, Agreement the term “"permanent establishment” " means a fixed place of business 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; (ca) an office; (db) a factory; (ec) a workshop, and; (fd) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources.; 3. The term “permanent establishment” likewise encompasses: (ae) a building site, site or a construction, construction or an assembly or installation project or supervisory activities in connection therewith, ; but only where such site, project or activities continue activity continues for a period of more than 12 nine months; (b) the furnishing of services, including consultancy services, by an enterprise 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 country for a period or periods aggregating more than 12 months within any 24-month period. 43. Notwithstanding the preceding provisions of paragraphs 1 to 3 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; (a) the maintenance of a stock of goods or merchandise belonging to the enterprise 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 fixed place of business solely for the purpose of purchasing 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, 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—person - other than an agent of an independent status to whom paragraph 6 applies—5 applies 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 on behalf of the enterprise, that enterprise shall be deemed to have a permanent establishment in the first-mentioned Contracting 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 of this Article, 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. 65. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in the other Contracting state 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. 76. The fact that a company company, which is a resident of a Contracting State controls or is controlled by a company 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 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” " likewise encompassesincludes : (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities continue for a period of more than 12 months183 days; (b) the furnishing of services, including consultancy services, by an enterprise 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 country Contracting State for a period or periods aggregating more than 12 months 91 days within any 24-month periodcontinuous period of twelve months. (4. ) Notwithstanding the preceding provisions of paragraphs 1 to 3 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, 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 the provisions of paragraphs 1 and 2, where a person—other than an agent of an independent status to whom paragraph 6 applies—is ) 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 the provisions of paragraph (7) of this Article apply, shall be deemed to be a permanent establishment in the first-mentioned State and if : (a) he has, and habitually exercisesexercises in that 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 first-mentioned other Contracting State if it collects premiums in respect of any activities which the territory or that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised other State 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 the other Contracting state State merely because it carries carried on business in that other Contracting State through a broker, general commission agent or any other agent of an independent status, provided that where such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf to the business of that enterprise, he will 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 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” likewise also encompasses: (a) a A building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where if such site, project or activities continue for a period of last more than 12 six months; (b) the The furnishing of services, including consultancy services, by an enterprise 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 country a Contracting State for a period or periods aggregating more than 12 six months within any 24-month twelvemonth period. (4. ) Notwithstanding the preceding provisions of paragraphs 1 to 3 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—person - other than an agent of an independent status to whom 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 Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in the first-mentioned Contracting 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 the other a Contracting state 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, 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” likewise " also encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where if such site, project or activities continue for a period of lasts more than 12 months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting 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 country other Contracting Party for a period or periods aggregating more than 12 months within 365 days in any 2415-month period. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 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—person - other than an agent of an independent status to whom 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 Contracting Party an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in the first-mentioned Contracting State that 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 of a Contracting State shall not be deemed to have a permanent establishment in the other a Contracting state Party merely because it carries on business in that other Contracting 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. 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 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 Contracting 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) and  a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term “"permanent establishment” " likewise encompasses: (: a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities continue for a period of more than 12 months; (sixmonths; b) the furnishing of services, including consultancy services, by an enterprise 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 country Contracting State for a period or periods aggregating more than 12 six months within any 24twelve-month period. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 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, 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 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 Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in the first-mentioned Contracting 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 the other Contracting state 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” 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” likewise encompassesestablishment » also includes : (a) a building site, a construction, installation or assembly or installation project project, or supervisory activities in connection connected therewith, but only where such site, project or activities continue last 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 (for the same or a connected project) within the country other Contracting State for a period or periods aggregating more than 12 months within 183 days in any 24-twelve month periodperiod commencing or ending in the taxable period concerned. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 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, 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 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 Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in the first-mentioned Contracting 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 the other a Contracting state 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 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” likewise encompasses: (ag) a building site, a construction, installation or assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities continue for a period of more than 12 six months; (bh) the furnishing of services, services including consultancy services, services by an enterprise a resident of a Contracting State 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) within project in the country other Contracting State for a period or periods aggregating more than 12 six months within in any 24-twelve month period. 43. Notwithstanding the preceding provisions of paragraphs 1 to 3 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 for collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying onadvertising, for the supply of information, for scientific research or for similar activities which are ofa preparatory or auxiliary character, 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 subparagraph (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—applies - is acting in a Contracting State on behalf of an enterprise of the other Contracting State and has, and habitually exercises, an authority to conclude contracts in the name of the enterpriseState, that enterprise shall be deemed to have a permanent establishment in the first-first - mentioned Contracting State, if such a person has, and habitually exercises, in the first- mentioned State in respect an authority to conclude contracts on behalf 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 Notwithstanding the preceding provisions of this Article, an insurance enterprise of a Contracting State shall not shall, except in regard to re-insurance, be deemed to have a permanent establishment in the other Contracting state 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 6. 6. An enterprise shall not be deemed to have a permanent establishment in a 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 shall 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 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” likewise encompasses: (a) a A building site, a or construction, assembly assembly, or installation project or supervisory activities in connection therewith, but constitutes a permanent establishment only where such site, project or activities continue for a period of if it lasts 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 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 country a Contracting State for a period or periods aggregating more than 12 months 183 days within any 24twelve-month period. 45. Notwithstanding the preceding provisions of paragraphs 1 to 3 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—person -- other than an agent of an independent status to whom paragraph 6 applies—7 applies -- is acting in a Contracting State on behalf of an enterprise of the other Contracting State State, and has, and habitually exercises, in 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 the first-mentioned 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 the other Contracting state 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. 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 Contracting 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 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” likewise encompasses:resources ; (ag) a place of exploration of natural resources ; (h) a building site, a construction, assembly site or installation construction project or supervisory activities in connection therewith, but only where such site, project or activities continue activity continues for a period of more than 12 monthssix months ; (bi) the furnishing of servicesa warehouse, including consultancy services, by an enterprise through employees or other personnel engaged by the enterprise in relation to a person providing storage facilities for such purpose, but only where activities of that nature continue (for the same or a connected project) within the country for a period or periods aggregating more than 12 months within any 24-month periodothers. 43. Notwithstanding the preceding provisions of paragraphs 1 to 3 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, 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 the provisions of paragraphs 1 and 2, where a person—other than an agent of an independent status to whom paragraph 6 applies—is A person acting in a Contracting State on behalf of an enterprise of the other Contracting State and (other than an agent of an independent status to whom paragraph 6 applies) shall be deemed to be a permanent establishment in the first-mentioned State if : (a) he has, and habitually exercisesexercises in the State, an authority to conclude contracts in the name on behalf of the enterprise, unless his activities are limited to those mentioned in paragraph 3 of this Article ; or (b) he 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 ; or (c) in so acting, he manufactures or processes in that State for the enterprise shall goods or merchandise belonging to the enterprise. 5. An insurance enterprise of a Contracting State shall, except in regard to reinsurance, be deemed to have a permanent establishment in the first-mentioned Contracting other State if it collects premiums in respect the territory 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 State or insures risks situated therein through an employee or through a fixed place representative who is not agent of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraphan independent status. 6. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in the other a Contracting state 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 the enterprise, he will shall not be considered an agent of an independent status within the meaning of this paragraphparagraph if it is shown that the transactions between the agent and the enterprise were not made under arms-length conditions. In such a case, the provisions of paragraph 4 shall apply. 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 for 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” likewise encompassesalso includes: (a) a building site, a construction, assembly or installation project or a supervisory activities in connection or consultancy activity connected therewith, but only where if such site, project or activities continue 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 country other Contracting State for a period or periods aggregating more than 12 9 months within any 24twelve-month period. 4. Notwithstanding the preceding provisions of paragraphs 1 to 3 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. 5. 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—applies -- 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 the first-mentioned Contracting 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 the other a Contracting state 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.