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) A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six months. (4) Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs 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 of this Article, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an the enterprise is wholly or partly carried on. (2) . The term "permanent establishment" includes especiallyshall include: (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; and (g) an installation or structure used for the exploration of natural resources but only if so used for a period of more than 9 months. (3) A . The term "permanent establishment" likewise encompasses a building site or construction a construction, installation or installation project constitutes a permanent establishment assembly project, or supervisory activities in connection therewith only if it the site, project or activity lasts more than six 9 months. (4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise 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 enterprisesupply of information, any other activity of for scientific research or for similar activities which have a preparatory or auxiliary character;, for the enterprise; and (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs (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 of this Article2, where a person - -- other than an agent of an independent status to whom paragraph 6 of this Article applies - -- is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) For the purposes of this AgreementConvention, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) The term "“permanent establishment" ” includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, and f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six twelve months. (4) Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to include: a) the use of facilities solely for the purpose of storage, 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) 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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name on behalf of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an the enterprise is wholly or partly carried on. (2) . The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop, and; (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six 6 months. (4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs subparagraphs (a) to (e) 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 of this Article2, where a person - -- other than an agent of an independent status to whom paragraph 6 of this Article applies - -- is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "permanent establishment" includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, and; f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources.; and (3g) A a building site or construction site, a construction, assembly or installation project constitutes if such site, project, or activities continue for a permanent establishment only if it lasts period of more than six months. (4) 3. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display 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 through 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) 4. Notwithstanding the provisions of paragraphs 1 and 2 of this Article2, where a person - (other than an agent of an independent status to whom paragraph 6 of this Article applies - 5 applies) is acting in a Contracting State on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterpriseother Contracting State, that enterprise shall be deemed to have a permanent establishment in that the first-mentioned State in respect of any activities which that person undertakes for the enterprise, if such a person: a) has and habitually exercises in the first-mentioned State an authority to conclude contracts on behalf of the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article 3 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; 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. The foregoing provisions of this subparagraph shall apply only if it is proved that in order to avoid taxation in the first-mentioned State, such person undertakes not only the regular delivery of the goods or merchandise, but also undertakes virtually all the activities connected with the sale of the goods or merchandise except for the actual conclusion of the sales-contract itself. (6) 5. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent agent, or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) 6. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this AgreementConvention, the term "permanent establishment" means a fixed place of business through in 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 farm or plantation; (g) a mine, an oil or gas well, a quarry or any other place of extraction of or natural resources.; (3h) A a building site or construction or installation assembly project constitutes a permanent establishment only if it lasts which exists for more than six months. (4) Notwithstanding the preceding provisions of this Article, the 3. 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 for 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 4. An enterprise of a Contracting State, notwithstanding it has no fixed place of business solely in the other Contracting State, shall be deemed to have a permanent establishment in that other Contracting State if it carries on supervisory activities therein for any combination more than six months in connection with a construction, installation or assembly project which is being undertaken in that other Contracting State. 5. A person acting in a Contracting State on behalf of activities mentioned in sub-paragraphs a) to e) of this paragraph, provided that the overall activity an enterprise of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. other Contracting State (5) Notwithstanding the provisions of paragraphs 1 and 2 of this Article, where a person - other than an agent of an independent status to whom paragraph 6 applies), notwithstanding he has no fixed place of this Article applies - is acting on behalf of an enterprise and business in the former Contracting State, shall be deemed to be a permanent establishment therein if - (a) he has, and habitually exercises, exercises in a the former Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed unless his activities are limited to have a permanent establishment in that State in respect the purchase of any activities which that person undertakes goods or merchandise for the enterprise, unless ; or (b) he maintains in the activities former Contracting State a stock of such person are limited goods or merchandise belonging to those mentioned in paragraph 4 the enterprise from which he regularly fills orders on behalf of this Article 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 paragraphenterprise. (6) . An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other Contracting State through a broker, general commission agent or any other agent of an independent status, provided that where such persons are person is acting in the ordinary course of their his business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this AgreementConvention, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "“permanent establishment" ” includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, ; and f) a mine, an oil or gas well, a quarry or any other place of extraction of natural natu- ral resources. (3) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six 12 months. (4) . Activities of drilling rigs or ships used for the exploration and exploitation of natural resources constitute a permanent establishment only if they last more than 6 months. 5. Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise 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 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 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) 6. Notwithstanding the provisions of paragraphs 1 and 2 of this Article2, where a person - – other than an agent of an independent status to whom paragraph 6 of this Article 7 applies - – is acting on behalf be- half of an enterprise and has, and habitually exercises, in a Contracting State an authority authori- ty to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person per- son undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article 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. (6) 7. An enterprise shall not be deemed to have a permanent establishment in a Contracting Con- tracting State merely because it carries on business in that 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. (7) 8. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) For the purposes of this 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) A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six twelve months. (4) Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, 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) 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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) The term "permanent establishment" includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, , f) premises used as sales outlet; g) a farm or plantation; and fh) a mine, an oil or gas well, a quarry or any other place of exploration, extraction or exploitation of natural resources. (3) A The term "permanent establishment" also encompasses a building site or site, a construction assembly or installation project constitutes or any supervisory activity in connection with such site or project, but only where such site, project or activity continues for a permanent establishment only if it lasts period or periods aggregating more than six monthsmonths within any twelve month period. (4) Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character;; or 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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise, and conditions are made or imposed between that enterprise and the agent in their commercial and financial relations which differ from those which would have been made between independent enterprises, he will not be considered an agent of an independent status within the meaning of this paragraph. (7) The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) For the purposes of this 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) A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six twelve months. (4) Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, 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) 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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) The term "permanent establishment" includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, and f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six twelve months. (4) Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, 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) 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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) For the purposes of this AgreementConvention, the term "„permanent establishment" “ means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) The term "„permanent establishment" “ includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, and f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six twelve months. (4) Notwithstanding the preceding provisions of this Article, the term "„permanent establishment" “ shall be deemed not to include: a) the use of facilities solely for the purpose of storage, 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) 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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting in a Contracting State on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterpriseother Contracting State, that enterprise shall be deemed to have a permanent establishment in that the first-mentioned State in respect of any activities which that person undertakes for the enterprise, if such a person 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 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) For the purposes of this AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) The term "permanent establishment" includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, and f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six twelve months. (4) Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, 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) 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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "permanent establishment" includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, and f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) . A building site or construction construction, assembly or installation project constitutes a permanent establishment only if it lasts more than six twelve months. (4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, 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) 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 of this Article2, where a person - other than an agent of an independent status to whom the provisions of paragraph 6 of this Article applies apply - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . Notwithstanding the preceding provisions of this Article, an insurance enterprise of a Contracting State shall, except the cases of reinsurance, be considered as having a permanent establishment in the other Contracting State if it collects insurance premiums on the territory of that other State or insures risks situated therein through a person which is not an agent of an independent status. 8. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "“permanent establishment" ” includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, and; f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources; g) a building site, construction, installation or assembly project or supervisory activities in connection therewith, but only if such site, project or activities continue for a period of more than 6 months; h) the furnishing of services, including consultancy services, by a resident of a Contracting State through employees or other personnel in the other Contracting State for a period or periods aggregating more than 3 months in any twelve-month period. (3) A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six months. (4) . Notwithstanding the preceding provisions of this Article, the term "following kinds of activities shall not constitute a 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, 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 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) 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) 4. Notwithstanding the provisions of paragraphs 1 and 2 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article 5 applies - is acting in a Contracting State on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterpriseother Contracting State, that enterprise shall be deemed to have a permanent establishment in that the first-mentioned Contracting State in respect of any activities which that person undertakes for the enterprise, if such a person has and habitually exercises in that 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 of this Article 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) 5. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other Contracting State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) 6. 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) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six months. (4) . Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs subparagraphs (a) to (e) 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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, status provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) For the purposes of . In this Agreement, Agreement the term "a permanent establishment" means a any fixed place of business through which the business a resident of an enterprise is a Contracting State wholly or partly carried oncarries on any commercial activity in the other Contracting State. (2) . The term "permanent establishment" includes shall include especially: (a) a place of management; b) a branch; c(b) an office; (c) a building or construction site which exists for more than twelve months; (d) a factory; e) a workshop, and f) a mine, an oil installation or gas well, a quarry or any other place of extraction of natural resources. (3) A building site or construction or installation assembly project constitutes a permanent establishment only if it lasts which exists for more than six months. (4) 3. Notwithstanding the preceding provisions of this Articleparagraph 1, a permanent establishment in a Contracting State through which a person who is a resident of the term "permanent establishment" other Contracting State wholly or partly carries on any commercial activity 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 enterpriseresident; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise resident solely for the purpose of storage, display storage or deliverydisplay; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise resident solely for the purpose of processing by another enterpriseresident; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or for collecting and disseminating of collecting information, for the enterpriseresident; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterpriseresident, 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) 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) 4. Notwithstanding the provisions of paragraphs 1 and 2 sub-paragraph 2(c) a resident of this Articlea Contracting State shall be deemed to have a permanent establishment in the other Contracting State if it carries on solely supervisory activities in that other State for more than 6 months in connection with a construction, where a installation or assembly project which is being undertaken in that other State. 5. A person - (other than an a broker, general commission agent or any other agent of an independent status to whom paragraph 6 of this Article applies - is applies) acting in a Contracting State on behalf of an enterprise and a resident of the other Contracting State shall be deemed to have a permanent establishment in the first-mentioned State, if: (a) he has, and habitually exercisesexercises in the first-mentioned State, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any resident unless his activities which that person undertakes for the enterprise, unless the activities of such person are limited to those activities mentioned in paragraph 4 3; (b) he maintains in the first-mentioned State a stock of this Article which, if exercised through a fixed place goods or merchandise belonging to the resident from which he regularly fills orders on behalf of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraphresident; or (c) he processes in the first-mentioned State goods or merchandise belonging to the resident. (6) An enterprise . A resident of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided that 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 the resident, he shall not be considered an agent of an independent status if the transactions between the agent and the resident were not made under arm's length conditions. (7) . The fact that a company person (other than an individual) which is a resident of a Contracting State controls or is controlled by a company person (other than an individual) which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company person 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) A building site or construction site, a construction, assembly or installation project constitutes a permanent establishment only if it lasts more than six months. (4) Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs 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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this AgreementConvention, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "“permanent establishment" ” includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, ; and f) a mine, an oil or gas well, a quarry quarry, or any other place of extraction of natural resources. (3) . A building site or construction or installation project constitutes a permanent establishment only if it lasts for more than six twelve months. (4) . Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to include: a) the use of facilities solely for the purpose of storage, 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 the 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.character.‌ (5) . Notwithstanding the provisions of paragraphs 1 and 2 of this Article, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, has and habitually exercises, exercises in a Contracting State an authority to conclude contracts in the name of that are binding on the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that the person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article whichthat, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent agent, or any other agent of an independent status, provided that such persons are person is acting in the ordinary course of their businesshis business as an independent agent. (7) . The fact that a company which that is a resident of a Contracting State controls or is controlled by a company which that is a resident of the other Contracting State, or which that carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this AgreementConvention, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "“permanent establishment" ” includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, and; f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six 12 months. (4) . Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs 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 of this Article2, where a person - – other than an agent of an independent status to whom paragraph 6 of this Article applies - – is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) For the purposes of this AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) The term "permanent establishment" includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, and f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six twelve months. (4) Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, 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) 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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "permanent establishment" includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, and f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six months. (4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs subparagraphs a) to e) 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 of this Article, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "permanent establishment" includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, and workshop and f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six nine months. (4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing 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) 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 of this Article2, where a person - other -other than an agent of an independent status to whom paragraph 6 of this Article applies - applies- is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "permanent establishment" includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, and f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six months. (4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs 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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "“permanent establishment" ” includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop; f) a warehouse, in relation to a person providing storage facilities for others; and fg) 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 or construction site, a construction, assembly or installation project constitutes or supervisory activities in connection therewith, but only where such site, project or activities continue for a permanent establishment only if it lasts period of more than six 6 months; b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other engaged personnel in the other Contracting State, provided that such activities continue for the same project or a connected project for a period or periods aggregating more than 6 months within any 12 months period. (4) . Notwithstanding the preceding provisions of this Article, the 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-sub paragraphs a) to e) of this paragraph, provided 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 of this Article, where 2,where a person - other than an agent of an independent status to whom the provisions of paragraph 6 of this Article applies - apply is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that 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 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other Contracting State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise, he will not be considered an agent of an independent status within the meaning of this paragraph. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether State(whether through a permanent establishment or otherwise), shall 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 quarry, or any other place of extraction of natural resources. (3. a) A building site or construction or installation project constitutes a permanent establishment only if it lasts for more than six twelve months. (b) An installation used for the exploration for natural resources constitutes a permanent establishment in a Contracting State only if it lasts or the activity continues in that State for more than twelve months. 4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, 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 the activities mentioned in sub-paragraphs subparagraphs a) to through 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 of this Article2, where a person - -- other than an agent of an independent status to whom paragraph 6 of this Article applies - -- is acting on behalf of an enterprise and has, has and habitually exercises, exercises in a Contracting State an authority to conclude contracts in the name of that are binding on the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that the person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article whichthat, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent agent, or any other agent of an independent status, provided that such persons are acting in the ordinary course of their businessbusiness as independent agents. (7) . The fact that a company which that is a resident of a Contracting State controls or is controlled by a company which that is a resident of the other Contracting State, or which that carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute be taken into account in determining whether either company has a permanent establishment of the otherin that other State.

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 quarry, or any other place of extraction of natural resources. (3) A . The term "permanent establishment" also includes a building site or construction or installation project constitutes a permanent establishment project, but only if it lasts more than six 6 months. (4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display 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 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 the 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 of this Article2, where a person - (other than an agent of an independent status to whom paragraph 6 of this Article applies - applies) is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent agent, or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, where the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise, and where the conditions between the agent and the enterprise differ from those which would be made between independent persons, such agent shall not be considered an agent of independent status within the meaning of this paragraph. In such case the provisions of paragraph 5 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 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) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six twelve months. (4) . Notwithstanding the preceding provisions of this Article, Article the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; e) the maintenance of a fixed place of business solely for the purpose of carrying 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) 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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, State or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this AgreementConvention, the term "“permanent establishment" ” means a fixed place of business through which the business of an the enterprise is wholly or partly carried on. (2) . The term "“permanent establishment" ” includes 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.; (3g) A a building site or construction site, a construction, assembly or installation project constitutes or supervisory activities in connection therewith, but only where such site, project or activity continues for a permanent establishment only if it lasts period of more than six months; h) 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 six months within any twelve-month period. (4) 3. Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; e) the maintenance of a fixed place of business solely for the purpose of carrying onadvertising, for the enterprisesupply of information, any other activity of for scientific research or for similar activities which have a preparatory or auxiliary character, for the enterprise; f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs 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. 4. A person acting in a Contracting State on behalf of an enterprise of the other Contracting State (5) Notwithstanding the provisions of paragraphs 1 and 2 of this Article, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise 5 applies) shall be deemed to have a permanent establishment in the first-mentioned State if: a) he has, and habitually exercises in that State in respect State, an authority to conclude contracts on behalf of any activities which that person undertakes for the enterprise, unless the his activities of such person are limited to those mentioned in paragraph 4 3 of this Article whichArticle; 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. (6) 5. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of the enterprise, he shall not be considered an agent of an independent status within the meaning of this paragraph. (7) 6. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), ) shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop, and; (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources; (g) a farm or plantation; (h) a warehouse, in relation to a person providing storage facilities for others; (i) a building site, a construction, installation or assembly project or supervisory activities in connection therewith, where such site, project or activities continue for a period of more than 6 months; (j) the furnishing of services including consultancy services by a resident of one of the Contracting States through employees or ther personnel, where activities of that nature continue for the same or a connected project within the other Contracting State for a period or periods aggregating more than 6 months within any twelve-month period. (3) A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six months. (4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, storage or display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display storage or 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; f) , for 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 characterenterprise. (5) 4. Notwithstanding the provisions of paragraphs 1 and 2 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting in a Contracting State, on behalf of an the enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterpriseother Contracting State, that the enterprise shall be deemed to have a permanent establishment in that State the first-mentioned Contracting State, if such a person: (a) has and habitually exercises in respect the first- mentioned State, an authority to conclude contracts on behalf of any activities which that person undertakes for the enterprise, unless the his activities of such person are limited to those the purchase of goods or merchandise for the enterprise; (b) has no such authority, but habitually maintains in the 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 authority, but habitually secures orders in paragraph 4 the first-mentioned State wholly or almost wholly for the enterprise or for the enterprise and other enterprises which are controlled by it or have a controlling interest in it. 5. Notwithstanding the preceding provisions of this Article whichArticle, if exercised through an insurance enterprise of a fixed place of businessContracting State shall, would not make this fixed place of business except in regard to reinsurance, be deemed to have a permanent establishment under in the provisions other State if it collects premiums in the territory of that paragraphother State or insures risks situated therein through an employee or through a representative who is not an agent of an independent status within the meaning of paragraph 6 of this Article. (6) . An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise or on behalf of that enterprise and other enterprises, which are controlled by it or have a controlling interest in it, he will not be considered an agent of independent status within the meaning of this paragraph. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether 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.; and (3g) A a building site site, a construction, or construction assembly or installation project constitutes a permanent establishment only if it lasts more than six (6) months. (4) 3. Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to include: a) the use of facilities solely for the purpose of storage, storage or display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display storage or deliverydisplay; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise 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) 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) 4. Notwithstanding the provisions of paragraphs 1 and 2 of this Article2, where a person - other -other than an agent of an independent status to whom paragraph 6 of this Article applies - 5 applies- is acting in a Contracting State on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterpriseother Contracting State, that enterprise shall be deemed to have a permanent establishment in that the first- mentioned Contracting State in respect of any activities which that person undertakes for the enterprise, if such a person: a) has, and habitually exercises in that State an authority to conclude contracts on behalf of the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article 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; b) has no such authority, but habitually maintains in the 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 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 controlled by it or have a controlling interest in it. (6) 5. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise, he will not be considered an agent of an independent status within the meaning of this paragraph. (7) 6. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "permanent establishment" includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, and f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six months. (4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs 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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - applies, is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State Party an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State Party in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State Party merely because it carries on business in that State Party through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State Party controls or is controlled by a company which is a resident of the other Contracting StateParty, or which carries on business in that other State Party (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other. Note 7: The Isle of Man and Malta have reserved the right for the entirety of Articles 12, 13, 14 and 15 not to apply to this Agreement so there have been no changes to this Article.

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) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six twelve months. (4) . Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to include: a) the use of facilities solely for the purpose of storage, 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) 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 of this Article2, where a person - other than an agent of an independent status to whom the provisions of paragraph 6 of this Article applies apply - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that 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 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that Contracting State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other Contracting State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) For the purposes of this 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) A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six twelve months. (4) Notwithstanding the preceding provisions of this Article, the term "„permanent establishment" “ shall be deemed not to include: a) the use of facilities solely for the purpose of storage, 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) 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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop, and; (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. The term “permanent establishment” likewise encompasses: (3a) A a building site or construction site, a construction, assembly or installation project constitutes or supervisory activities in connection therewith, but only where such site, project or activities continue for a permanent establishment only if it lasts period of more than six twelve months. (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other engaged personnel in the other Contracting State, provided that such activities continue for the same project or a connected project for a period or periods aggregating more than twelve months within any twenty-four-month period. 4) . Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying onadvertising, for the enterprisesupply of information, any other activity of for scientific research or for similar activities which have a preparatory or auxiliary character; f) , for 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 characterenterprise. (5) . Notwithstanding the provisions of paragraphs 1 and 2 of this Article2, where a person - person—other than an agent of an independent status to whom the provisions of paragraph 6 of this Article applies - apply—is acting in a Contracting State on behalf of an enterprise and hasof the other Contracting State, has and habitually exercises, in a Contracting State exercises an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that the first-mentioned Contracting State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other Contracting State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other Contracting State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this 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) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six twelve months. (4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, 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 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) 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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "permanent establishment" includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, and f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six months. (4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs 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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise, he will not be considered an agent of an independent status within the meaning of that paragraph. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop, ; and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six months. (4) . A person carrying on activities offshore in a Contracting State in connection with the exploration or exploitation of the sea bed and subsoil and their natural resources situated in that Contracting State shall be deemed to be carrying on a business through a permanent establishment in that Contracting State. 5. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs subparagraphs (a) to (e) 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) 6. Notwithstanding the provisions of paragraphs 1 and 2 of this Article, where a person - other than an agent of an independent status to whom paragraph 6 7 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 5 of this Article 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) 7. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) 8. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this 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) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six twelve months. (4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, 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) 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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "“permanent establishment" ” includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, and f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six twelve months. (4) . Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to include: a) the use of facilities solely for the purpose of storage, 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) 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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name on behalf of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an the enterprise is wholly or partly carried on. (2) The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop, and; (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six 6 months. (4) Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise 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) 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 (1) and 2 (2) of this Article, where a person - (other than an agent of an independent status to whom paragraph 6 (6) of this Article applies - applies) is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name on behalf of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 (4) of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) An enterprise shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided that where such persons are acting in the ordinary course of their business. (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) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six twelve months. (4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, 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) 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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "permanent establishment" includes especially: a) a. a place of management; b) b. a branch; c) c. an office; d) d. a factory; e) e. a workshop, and f) and f. a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six twelve months. (4) . Notwithstanding the preceding provisions of this Article, the term "permanent 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 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; f) f. the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs a) a. to e) of this paragraphe., 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 of this Article2, where a person - – other than an agent of an independent status to whom paragraph 6 of this Article applies - – is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) The term "permanent establishment" includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, and f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) A The term "permanent establishment" also includes: a) a building site, a construction, installation or assembly project, but only where such site or construction or installation project constitutes continue for a permanent establishment only if it lasts period of more than six 12 months; b) the furnishing of services, including supervisory activities and consultancy services, by an enterprise through employees or other personnel engaged by the enterprise for such purpose for a period or periods exceeding in the aggregate 183 days within any twelve-month period. (4) Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs (a) to (e) 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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this AgreementConvention, the term "«permanent establishment" » means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "«permanent establishment" » includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, ; and f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) . A building site or construction or installation project constitutes a permanent establishment es- tablishment only if it lasts more than six 9 (nine) months. (4) . Notwithstanding the preceding provisions of this Article, the term "«permanent establishment" » shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise enter- prise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise enter- prise solely for the purpose of processing by another enterprise; d) the maintenance of a fixed place of business solely for the purpose of purchasing pur- chasing goods or merchandise or of collecting information, for the enterpriseenter- prise; e) the maintenance of a fixed place of business solely for the purpose of carrying carry- ing 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) of this paragraph), 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 of this Article, where a person - – other than an agent of an independent status to whom paragraph 6 of this Article applies - – is acting on behalf of an enterprise and has, has and habitually exercises, exercises in a Contracting State an authority to conclude con- clude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes un- dertakes for the enterprise, unless the activities of such person are limited to those mentioned men- tioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting Con- tracting State merely because it carries on business in that 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. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this Agreement, the term "“permanent establishment" “ means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "“permanent establishment" “ includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, and f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six months. (4. Notwithstanding the provisions of paragraphs 1, 2 and 3, where an enterprise of a territory: a) carries on supervisory activities for more than six months in connection with a building site or construction or installation project which is being undertaken in the other territory, or b) during a period or periods exceeding in the aggregate 183 days in any twelve-month period, performs services for the same project or for connected projects through one or more individuals who are performing such services in that territory, these supervisory activities or services shall be deemed to be performed through a permanent establishment that the enterprise has in the other territory, unless these supervisory activities or services are limited to those mentioned in paragraph 5 which, if performed through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 5. Notwithstanding the preceding provisions of this Article, 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 similar activities which have a preparatory or auxiliary charactercharacter for the enterprise; f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs subparagraphs a) to e) 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) 6. Notwithstanding the provisions of paragraphs 1 and 2 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article 7 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State territory an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State territory 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 the purchase of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under goods or merchandise for the provisions of that paragraphenterprise. (6) 7. An enterprise shall not be deemed to have a permanent establishment in a Contracting State territory merely because it carries on business in that State territory through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) 8. The fact that a company which is a resident of a Contracting State territory controls or is controlled by a company which is a resident of the other Contracting Stateterritory, or which carries on business in that other State territory (whether through a permanent establishment or otherwise), shall not of itself constitute 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) . A building site or construction or installation assembly project constitutes a permanent establishment only if it lasts more than six twelve months. (4) Notwithstanding . Nothwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, exercises in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) For the purposes of this AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) The term "permanent establishment" includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, and f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) A The term "permanent establishment" likewise encompasses: a) a building site or construction a construction, or installation project constitutes but only where such site, or project continue for a permanent establishment only if it lasts period of more than six twelve months; b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through its employees or other personnel engaged by the enterprise for such purpose, provided that such activities continue for the same project or a connected project for a period of more than twelve months. (4) Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, 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) 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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "“permanent establishment" ” includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, and f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six months. (4) . Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs subparagraphs a) to e) 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 of this Article, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this AgreementConvention, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop, and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six months. (4) . Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, storage or display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display storage or deliverydisplay; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of not listed in subparagraphs (a) to (d), provided that this activity has 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) 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. Paragraph 4 shall not apply to a fixed place of business that is used or maintained by an enterprise if the same enterprise or a closely related enterprise carries on business activities at the same place or at another place in the same Contracting State and (5a) that place or other place constitutes a permanent establishment for the enterprise or the closely related enterprise under the provisions of this Article, or (b) the overall activity resulting from the combination of the activities carried on by the two enterprises at the same place, or by the same enterprise or closely related enterprises at the two places, is not of a preparatory or auxiliary character, provided that the business activities carried on by the two enterprises at the same place, or by the same enterprise or closely related enterprises at the two places, constitute complementary functions that are part of a cohesive business operation. 6. Notwithstanding the provisions of paragraphs 1 and 2 but subject to the provisions of this Articleparagraph 7, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting in a Contracting State on behalf of an enterprise and hasand, in doing so, habitually concludes contracts, or habitually plays the principal role leading to the conclusion of contracts that are routinely concluded without material modification by the enterprise, and habitually exercises, in a Contracting State an authority to conclude these contracts are (a) in the name of the enterprise, or (b) for the transfer of the ownership of, or for the granting of the right to use, property owned by that enterprise or that the enterprise has the right to use, or (c) for the provision of services by that enterprise, that enterprise shall be deemed to have a permanent establishment in that Contracting State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of businessbusiness (other than a fixed place of business to which paragraph 5 would apply), would not make this fixed place of business a permanent establishment under the provisions of that paragraphparagraph 4. (6) An enterprise 7. Paragraph 6 shall not be deemed to have a permanent establishment apply where the person acting in a Contracting State merely because it on behalf of an enterprise of the other Contracting State carries on business in that the first- mentioned Contracting State through a broker, general commission agent or any other agent of as an independent status, provided that such persons are acting agent and acts for the enterprise in the ordinary course of their that business. Where, however, a person acts exclusively or almost exclusively on behalf of one or more enterprises to which it is closely related, that person shall not be considered to be an independent agent within the meaning of this paragraph with respect to any such enterprise. (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. 9. For the purposes of this Article, a person or enterprise is closely related to an enterprise if, based on all the relevant facts and circumstances, one has control of the other or both are under the control of the same persons or enterprises. In any case, a person or enterprise shall be considered to be closely related to an enterprise if one possesses directly or indirectly more than 50 per cent of the beneficial interest in the other (or, in the case of a company, more than 50 per cent of the aggregate vote and value of the company’s shares or of the beneficial equity interest in the company) or if another person or enterprise possesses directly or indirectly more than 50 per cent of the beneficial interest (or, in the case of a company, more than 50 per cent of the aggregate vote and value of the company’s shares or of the beneficial equity interest in the company) in the person and the enterprise or in the two enterprises.

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 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) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six 12 months. (4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs 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 of this Article2, where a person - other -other than an agent of an independent status to whom paragraph 6 of this Article applies - applies- is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop, ; and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six three months. (4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs (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 of this Article2, where a person - – other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "permanent establishment" includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, and f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six nine months. (4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing 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) 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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "permanent establishment" includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, and workshop and f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six nine months. (4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing 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) 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 of this Article, where a person - other -other than an agent of an independent status to whom paragraph 6 of this Article applies - applies- is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "“permanent establishment" ” includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, ; and f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six twelve months. (4) . Notwithstanding the provisions of paragraphs 1, 2 and 3, where an enterprise of a Contracting State performs services in the other Contracting State for a period or periods exceeding in the aggregate 183 days in any 12 month period commencing or ending in the fiscal year concerned, and these services are performed for the same project or connected projects through one or more individuals who are present and performing such services in that other State, the activities carried on in that other State in performing these services shall be deemed to be carried on through a permanent establishment of the enterprise situated in that other State, unless these services are limited to those mentioned in paragraph 5 which, if performed through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. For the purposes of this paragraph, services performed by an individual on behalf of one enterprise shall not be considered to be performed by another enterprise through that individual unless that other enterprise supervises, directs or controls the manner in which these services are performed by the individual. 5. Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of collecting information, for the enterprise; e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs a) to e) 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) 6. Notwithstanding the provisions of paragraphs 1 and 2 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article 7 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name on behalf of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article 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. (6) 7. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) 8. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this Agreement, the term "permanent 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 refinery; (g) a sales outlet; (h) a warehouse in relation to a person providing storage facilities for others; (i) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources.; (3j) A a building site or construction or assembly or installation project constitutes or supervisory activity connected therewith where such site, project or activity continues for a permanent establishment only if it lasts period of more than six twelve months.; (4) 3. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs 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) 4. Notwithstanding the provisions of paragraphs 1 and 2 of this Article2, where a person - other -other than an agent of an independent status to whom paragraph 6 of this Article applies - 5 applies- is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article 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) 5. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (6. Notwithstanding the provisions of paragraphs 4 and 5, an insurance enterprise of a Contracting State shall, except with regard to reinsurance, be deemed to have a permanent establishment in the other State if it collects premiums in that other State, or insures risks situated therein, through an agent established there but not including an agent of an independent status mentioned in paragraph 5 unless he has, and habitually exercises, an authority to conclude contracts in the name of the enterprise. 7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop, and; (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six months. (4) An enterprise of a territory shall be deemed to have a permanent establishment in the other territory if: (a) it carries on supervisory activities in that other territory for more than six months in connection with a building site or construction or installation project which is being undertaken in that other territory; or (b) it furnishes services, including consultancy services, but only where activities of that nature continue, for the same or a connected project, through employees or other personnel or persons engaged by the enterprise for such purpose in the other territory for a period or periods aggregating more than six months within any twelve month period. (5) Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs (a) to (e) 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. (56) Notwithstanding the provisions of paragraphs 1 (1) and 2 (2) of this Article, where a person - is acting in a territory on behalf of an enterprise of the other territory – other than an agent of an independent status to whom paragraph 6 (7) of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in – the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State the first-mentioned territory in respect of any activities which that person undertakes for the enterprise if the person has, and habitually exercises in that territory, an authority to conclude contracts on behalf of the enterprise, unless the person’s activities of such person are limited to those mentioned in paragraph 4 (5) 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. (67) An enterprise shall not be deemed to have a permanent establishment in a Contracting State territory merely because it carries on business in that State territory through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) 8) The fact that a company which is a resident of a Contracting State territory controls or is controlled by a company which is a resident of the other Contracting Stateterritory, or which carries on business in that other State territory (whether through a permanent establishment or otherwise), shall not of itself constitute 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, workshop and; f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six months. (4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise 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) 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 of this Article2, where a person - other -other than an agent of an independent status to whom paragraph 6 of this Article applies - applies- is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) For the purposes of this AgreementConvention, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop, ; and (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six twelve months. (4) Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, 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) 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 (1) and 2 (2) of this Article, where a person - – other than an agent of an independent status to whom paragraph 6 (6) of this Article applies - – is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name on behalf of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 (4) of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "permanent establishment" includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, and f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3. The term "permanent establishment" also includes: a) A a building site or construction or installation project constitutes a permanent establishment or assembly project, or supervisory services connected therewith, but only if it such site or project lasts for more than twelve months, or such services continue for more than twelve months; and b) an installation or structure used for the exploration of natural resources, or supervisory services connected therewith, or a drilling rig, but only if such use lasts for more than six months, or such services continue for more than six months; and c) the furnishing of services, including consultancy services, through employees or other personnel engaged for such purposes, but only where the activities of that nature continue (for the same or a connected project) within the country for more than twelve months. (4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, 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) 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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business activities of an the enterprise of one State is wholly or partly carried onon in the other State. (2) . The term "permanent establishment" includes especiallyshall include: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; (f) a warehouse, andin relation to a person providing storage facilities for others; f(g) a mine, an oil or of gas well, a quarry or any other place of extraction of natural resources, and (h) an installation used for the exploration of natural resources. 3. The term "permanent establishment" likewise encompasses: (3a) A a building site or construction a construction, installation or installation project constitutes a permanent establishment assembly project, or supervisory activities in connection therewith only if it the site, project or activity lasts more than six 12 months; (b) the furnishing of services including consultancy services by an enterprise of a Contracting State through employees or other personnel engaged in the other Contracting State, provided that such activities continue for the same or a connected project for a period or periods aggregating to more than 6 months within any 12 month period. (4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, storage or display or delivery of goods good 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 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; and (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 of this Article2, where a person - acting in a Contracting State on behalf of an enterprise of the other Contracting State (other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf applies) notwithstanding that he has no fixed place of an enterprise and business in the first-mentioned State shall be deemed to be a permanent establishment that State if: (a) he has, and habitually exercises, a general authority in a Contracting the first-mentioned State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed unless his activities are limited to have a permanent establishment in that State in respect the purchase of any activities which that person undertakes goods or merchandise for the enterprise, unless ; or (b) he maintains in the activities first-mentioned state a stock of such person are limited goods or merchandise belonging to those mentioned in paragraph 4 the enterprise from which he regularly delivers goods or merchandise on behalf of this Article 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 paragraphenterprise. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "permanent establishment" includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, and f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six twelve months. (4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, 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) 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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other. 1. Income derived by a resident of a Contracting State from immovable property (including income from agriculture or forestry) situated in the other Contracting State may be taxed in that other State. 2. The term "immovable property" shall have the meaning which it has under the law of the Contracting State in which the property in question is situated. The term shall in any case include property accessory to immovable property, livestock and equipment used in agriculture and forestry, rights to which the provisions of general law respecting landed property apply, usufruct of immovable property and rights to variable or fixed payments as consideration for the working of, or the right to work, mineral deposits, sources and other natural resources; ships 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. Where the ownership of shares or other rights directly or indirectly entitles the owner of such shares or rights to the enjoyment of immovable property, the income from the direct use, letting or use in any other form of such right to the enjoyment may be taxed in the Contracting State in which the immovable property is situated. 5. The provisions of paragraphs 1, 3 and 4 shall also apply to the income from immovable property of an enterprise.

PERMANENT ESTABLISHMENT. (1) For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) The term "permanent establishment" includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, and f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resourcesre­ sources. (3) A building site or construction or installation project constitutes a permanent establishment establish­ ment only if it lasts more than six nine months. (4) Notwithstanding the preceding provisions of this Article, the term "permanent establishmentestablish­ ment" 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) 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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise en­ terprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business busi­ ness a permanent establishment under the provisions of that paragraph. (6) An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, State or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this AgreementConvention, the term "permanent establishment" means a fixed place of business through in 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 exploitation of natural resources.; (3g) A a building site or construction or installation project constitutes a permanent establishment only if it lasts more than six the duration of which exceeds 12 months. (4) Notwithstanding the preceding provisions of this Article, the term "3. A permanent establishment" 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 use of a fixed place of business business, for the enterprise, solely for the purpose of carrying onadvertising, for the enterprisesupply of information, any other activity of for scientific research or for similar activities which have a preparatory or auxiliary character; (f) the maintenance an enterprise of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs a) to e) of this paragraphContracting State, provided that the overall activity of the fixed place of business resulting from this combination which is of a preparatory or auxiliary character. (5) Notwithstanding not governed by the provisions of paragraphs 1 2 and 2 4, restricts itself in the other Contracting State to letting, leasing or giving the right to use goods or rights referred to in paragraph 3 of this Article, where a Article 12. 4. A person - other than an agent of an independent status referred to whom in paragraph 6 of this Article applies 5 - is acting in a Contracting State on behalf of an enterprise and has, of the other Contracting State is deemed to be a permanent establishment of the enterprise in the first-mentioned State if he has and habitually exercises, exercises in a Contracting that State an the authority to conclude contracts in the name of the enterprise, unless his activities are limited to the purchase of goods or merchandise for that enterprise. 5. An enterprise shall be of a Contracting State is not deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) An enterprise shall not be deemed to have a permanent establishment in a other Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) 6. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) The term "permanent establishment" includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, and f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) A building site or construction or installation or assembly project constitutes a permanent establishment only if it lasts more than six nine months. (4) Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing 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) 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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, State or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried onSee treaty text. (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) A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six months. (4) Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the The use of facilities solely for the purpose purposes of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the The maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the The maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) the 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;; and e) the The maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, on any other activity of a preparatory or auxiliary character; f) . To apply this Article, it is necessary to be able to make a distinction between functions that are core to a business and those that are merely preparatory or auxiliary. What constitutes core functions will vary from one business to the maintenance of a next. However, any fixed place of business solely from which the business is partly managed will constitute a permanent establishment even if its function otherwise appears to be preparatory or auxiliary. Also, if services are rendered to other companies within the corporate group or to third party customers then this would not be preparatory or auxiliary because activities only count as preparatory or auxiliary if they are carried on “for any combination of activities mentioned the enterprise” itself. This Treaty follows the UN Model in sub-paragraphs a) to e) of this paragraphspecifically providing that services provided by an enterprise may result in a permanent establishment, provided that the overall activity of the even though there is no fixed place of business resulting from this combination business. The furnishing of consultancy and management services, whether through an enterprise's own employees or by other personnel hired for the purpose where a project (and any connected project) lasts for more than 18 months in aggregate. This is far longer than the norm in Chinese treaties of a six months. There is no rule as the overall period in which the services are provided. In most UN based treaties, the rule is “six months in aggregate in any 12 month period”. It appears that the 18 months must be aggregated over the entire life of the enterprise, so that cumulative careful records must be kept of periods during which services are provided in the other State. Where the services are merely preparatory or auxiliary character. (5) Notwithstanding the provisions of paragraphs 1 and 2 of this Articleauxiliary, where as set out above, no permanent establishment will arise. Dependent agents may constitute a permanent establishment. Where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise a resident of a Contracting State and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterpriseresident, that enterprise shall be resident is deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterpriseother State, unless the activities of such person the agent are limited to those mentioned in paragraph 4 of this Article 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. (6listed at a) An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.to

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) . A building site or construction or assembly or installation project constitutes a permanent establishment only if it lasts more than six nine months. (4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing 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) 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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise, and conditions are made or imposed between the enterprise and the agent in their commercial and financial relations which differ from those which would have been made between independent enterprises, he will not be considered an agent of an independent status within the meaning of this paragraph. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this 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) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six months. (4) . Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise 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 characteractivity; (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 such activity or, in the case of subparagraph (f), the overall activity of the fixed place of business resulting from this combination business, is of a preparatory or auxiliary character. (5) . Notwithstanding the provisions of paragraphs 1 and 2 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State Party an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State Party in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State Party merely because it carries on business in that State Party through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State Party controls or is controlled by a company which is a resident of the other Contracting StateParty, or which carries on business in that other State Party (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) For the purposes of this 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) A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six nine months. (4) Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing 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) 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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article 7 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) Notwithstanding the preceding provisions of this Article, an insurance enterprise of a Contracting State shall, except in regard to re-insurance, be deemed to have a permanent establishment in the other Contracting State if it collects premiums in the territory of that other State or insures risks situated therein through a person other than agent of an independent status to whom paragraph 7 applies. (7) An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise, he will not be considered an agent of an independent status within the meaning of this paragraph. (7) 8) The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "permanent establishment" includes especially: a1) a place of management; b2) a branch; c3) an office; d4) a factory; e5) a workshop, ; and f6) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3. The term “permanent establishment” also includes: 1) A a building site or construction or installation project constitutes a permanent establishment only if it lasts more than six twelve months; 2) the carrying on of activities in a Contracting State in connection with the exploration or exploitation of the seabed and subsoil and their natural resources situated in that Contracting State, if such activities are carried on for a period or periods exceeding in the aggregate 30 days in any twelve month period. (4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a1) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b2) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c3) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d4) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; e5) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; f6) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs asubparagraphs 1) to e) of this paragraph5), 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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "permanent establishment" includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, and f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six twelve months. (4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, 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 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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this AgreementConvention, the term a "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) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six twelve months. (4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to includeinclude : a) the use of facilities solely for the purpose of storage, 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-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 of this Article2, where a person - other -other than an agent of an independent status to whom paragraph 6 of this Article applies - applies- is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this AgreementConvention, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "“permanent establishment" ” includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, and f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) A . a building site or construction or installation assembly project constitutes shall be regarded as a permanent establishment only if it lasts for more than six (6) months. (4) . Notwithstanding the preceding foregoing provisions of this Article, the term "“permanent establishment" ” shall not be deemed not to include: a) the use of facilities solely for the purpose of storage, 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 use 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 use of a fixed place of business solely for the sole purpose of carrying onout, 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) 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 of this Article, where a person - person--other than an agent of an independent status to whom paragraph 6 of this Article applies - applies--is acting in a Contracting State on behalf of an enterprise and has, and habitually exercises, in a Contracting that State an the authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterpriseit, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article 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 this paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this AgreementConvention, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "“permanent establishment" ” includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, and; f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (. 3) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six 12 months. (4) . Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs 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 of this Article2, where a person - – other than an agent of an independent status to whom paragraph 6 of this Article applies - – is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is of a Contracting State wholly or partly carried oncarries on the business in the other Contracting State. (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 exploration, exploitation and extraction of natural resources. (3) A . The term “permanent establishment” likewise encompasses: a building site or construction site, a construction, assembly or installation project constitutes or supervisory activities in connection therewith, but only where such site, project or activities continue for a permanent establishment only if it lasts period of more than six twelve months. (4) . Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to include: a) the use of facilities solely for the purpose of storage, 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 deliverydisplay; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-sub paragraphs a) to e) of this paragraph, provided 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 of this Article, where 2,where a person - person—other than an agent of an independent status to whom paragraph 6 of this Article applies - applies—is acting in a Contracting State on behalf of an enterprise and hasof the other Contracting State, has and habitually exercises, in a Contracting State exercises an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that the first mentioned Contracting State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise, he shall not be considered an agent of an independent status within the meaning of this paragraph. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether State(whether through a permanent establishment or otherwise), shall 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 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.; (3g) A a warehouse in relation to a person providing storage facilities for others; (h) a farm, plantation or other place where agriculture, forestry, plantation or related activities are carried on; (i) a premises used as a sales outlet or for receiving or soliciting orders; (j) an installation or structure used for the exploration of natural resources provided that the activities are carried on for a period or periods of 183 days or more in any twelve-month period; (k) a building site or construction construction, installation or installation assembly project constitutes or supervisory activities in connection therewith, where such site, project or activities (together with other such sites, projects or activities, if any) continue for a permanent establishment only if it lasts more than six monthsperiod of 183 days or more. (4) 3. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to includeinclude : (a) the use of facilities solely for the purpose of storage, storage or display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display storage or deliverydisplay; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of collecting information, for the enterprise;; and (e) the maintenance of a fixed place of business solely for the purpose of carrying onadvertising; for the supply of information, for the enterprisescientific research, any or for other activity of 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) of this paragraph, provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary characterenterprise. (5) 4. Notwithstanding the provisions of paragraphs 1 and 2 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - 5 applies—is acting in a Contracting State on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterpriseother Contracting State, that enterprise shall be deemed to have a permanent establishment in the first-mentioned State, if— (a) he has and habitually exercises in that State in respect an authority to conclude contracts on behalf of any activities which that person undertakes for the enterprise, unless the his activities of such person are limited to those the purchase of goods or merchandise for the enterprise; (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) he habitually secures orders in paragraph 4 of this Article whichthe first-mentioned State wholly or almost wholly for the enterprise itself or for the enterprise and other enterprises controlling, if exercised through a fixed place of businesscontrolled by, would not make this fixed place of business a permanent establishment under or subject to the provisions of same common control, as that paragraphenterprise. (6) 5. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise itself or on behalf of that enterprise and other enterprises controlling, controlled by, or subject to the same common control, as that enterprise, he will not be considered an agent of an independent status within the meaning of this paragraph. (7) 6. 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: a1) a place of management; b2) a branch; c3) an office; d4) a factory; e5) a workshop, and f6) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3. The term "permanent establishment" likewise encompasses: 1) A a building site or construction or installation project constitutes a permanent establishment only if it such site or project lasts more than six nine months; 2) activities carried in a Contracting State in connection with the exploration or exploitation of the sea bed and its sub-soil and their natural recourses situated in that State, if such activities are carried on for a period or periods exceeding in the aggregate 30 days in any twelve month period. (4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a1) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b2) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c3) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d4) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; e5) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; f6) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs a1) to e) of this paragraph5), 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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this AgreementConvention, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "“permanent establishment" ” includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, ; and f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) . A building site or construction or installation project constitutes a “permanent establishment establishment” only if it lasts more than six twelve months. (4) . Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to include: a) the use of facilities solely for the purpose of storage, 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) 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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other another agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this Agreement, 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) a f. A mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) A . The term “permanent establishment” also includes: a. a building site site, a construction, installation or construction assembly project, or installation supervisory activities in connection therewith, but only where such site, project constitutes a permanent establishment only if it lasts or activities last more than six 6 months; b. the furnishing of services, including consultancy services but excluding services referred to in subparagraph (a), by an enterprise of a Contracting State through employees or other personnel in the other Contracting State for a period or periods aggregating more than 3 months within any twelve-month period. (4) . Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to include: a) 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 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;for f) the 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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "permanent establishment" includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, ; and f) a mine, an oil or gas well, a quarry quarry, or any other place of extraction of natural resources. (3. a) A building site or construction or installation project constitutes a permanent establishment only if it lasts for more than six twelve months. (b) An installation used for the exploration for natural resources constitutes a permanent establishment in a Contracting State only if it lasts or the activity continues in that State for more than twelve months. 4) . Notwithstanding the preceding provisions of this ArticleArti­cle, 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 be­longing to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storagestor­age, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing 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 the activities mentioned in sub-paragraphs subpara­graphs a) to through 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 of this Article2, where a person - ‑- other than an agent of an independent status to whom paragraph 6 of this Article applies - ‑- is acting on behalf of an enterprise and has, has and habitually exercises, exercises in a Contracting State an authority to conclude contracts in the name of that are binding on the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that the person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article whichthat, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent agent, or any other agent of an independent status, provided that such persons are acting in the ordinary course of their businessbusiness as independent agents. (7) . The fact that a company which that is a resident of a Contracting Con­tracting State controls or is controlled by a company which that is a resident of the other Contracting State, or which that carries on business in that other State (whether through a permanent establishment estab­lishment or otherwise), shall not of itself constitute be taken into account in determining whether either company has a permanent establishment of the otherin that other State.

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) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six 12 months. (4) . Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs 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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) For the purposes of this AgreementConvention, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop, and; (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources; and (g) a farm, plantation or other place where agricultural, forestry, plantation or other related activities are carried on. (3) A building site or construction or installation or assembly project or supervisory activities in connection therewith constitutes a permanent establishment only if it lasts more than six nine months. (4) Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing 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-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 (1) and 2 of this Article(2), where a person - person, other than an agent of an independent status to whom paragraph 6 of this Article applies - (6) applies, is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article (4) which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "permanent establishment" includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, and f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six 6 (six) months., (4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs 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 l and 2 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "permanent establishment" includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop; f) premises used as a sales outlet, and fg) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six months. (4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs 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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "permanent establishment" includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, ; and f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six twelve months. (4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, 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-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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - applies- is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "permanent establishment" includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, and workshop and f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six months. (4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise 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) 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 of this Article2, where a person - other -other than an agent of an independent status to whom paragraph 6 of this Article applies - applies- is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "permanent establishment" includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, and f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six 6 months. (4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishmentestab- lishment" 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) 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 of this Article, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment estab- lishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried onSee treaty text. (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) A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six months. (4) Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the The use of facilities solely for the purpose purposes of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the The maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the The maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) the 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 The maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, on any other activity of a preparatory or auxiliary character;; and f) the maintenance of a fixed place of business solely for any Any combination of activities mentioned in sub-paragraphs a) to e) of this paragraph, provided the above providing 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 of . To apply this Article, it is necessary to be able to make a distinction between functions that are core to a business and those that are merely preparatory or auxiliary. What constitutes core functions will vary from one business to the next. However, any fixed place of business from which the business is partly managed will constitute a permanent establishment even if its function otherwise appear to be preparatory or auxiliary. Also, if services are rendered to other companies within the corporate group or to third party customers then this would not be preparatory or auxiliary because activities only count as preparatory or auxiliary if they are carried on “for the enterprise” itself. Note that despite incorporating many features of the UN Model Convention, this Article at paragraph 4(b), unlike the UN Model, excludes “delivery of goods or merchandise” from the definition of what may be considered a permanent establishment. Thus a warehouse would not normally be considered a permanent establishment under this Treaty. This Treaty follows the UN Model in specifically providing that services provided by an enterprise may result in a permanent establishment, even though there is no fixed place of business. The furnishing of consultancy and other services, whether through an enterprise's own employees or by other personnel hired (for the same project or any connected project) will give rise to a permanent establishment where the activities last for more than six months within any 12-month period. There is little guidance available as to what is meant by “same or connected” but Commentary on the OECD Model suggests that commercial connections rather than geographic connections are paramount. Where the services are merely preparatory or auxiliary, as set out above, no permanent establishment will arise. Dependent agents may constitute a permanent establishment. Where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise a resident of a Contracting State and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterpriseresident, that enterprise shall be resident is deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterpriseother State, unless the activities of such person the agent are limited to those mentioned in paragraph 4 of this Article 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. (6listed at a) An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.to

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) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six months. (4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs subparagraphs a) to e) 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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "permanent establishment" includes 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 resourcesresources ; (g) a warehouse in relation to a person providing storage facilities for others ; (h) a premises used as a sales outlet ; (i) an installation or structure used for the exploration of natural resources provided that the activities continue for more than 183 days. (3) . A building site or construction construction, installation or installation assembly project constitutes a permanent establishment only if it lasts where such site or project continues for a period of more than six months. (4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to includeinclude : (a) the use of facilities solely for the purpose of storage, storage or display or delivery of goods or merchandise belonging to the enterpriseenterprise ; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, 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 enterpriseenterprise ; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterpriseenterprise ; (e) the maintenance of a fixed place of business solely for the purpose of carrying onadvertising, for the enterprisesupply of information, any for scientific research, or for other activity of 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) 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 of this Article, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting in one of the Contracting States on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterpriseother Contracting State, that enterprise shall be deemed to have a permanent establishment in the first-mentioned Contracting State, if : (a) he has and habitually exercises in that Contracting State in respect an authority to conclude contracts on behalf of any activities which that person undertakes for the enterprise, unless the unless, his activities of such person are limited to those the purchase of goods or merchandise for the enterprise ; or (b) he has no such authority, but habitually maintains in the first-mentioned in paragraph 4 Contracting State a stock of this Article which, if exercised through a fixed place goods or merchandise from which he regularly delivers goods or merchandise on behalf of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraphenterprise. (6) . An enterprise of one of the Contracting States shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other 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 if it is shown that the transactions between the agent and the enterprise were not made under at arm's length conditions. (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 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) A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six twelve months. (4) Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, 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) 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 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, State or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "“permanent establishment" ” includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, and workshop and f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) . A building site or construction or assembly or installation project constitutes a permanent establishment only if it lasts more than six twelve months. (4) . Notwithstanding the preceding provisions of this Article, Article the term "“permanent establishment" ” shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; e) the maintenance of a fixed place of business solely for the purpose of carrying 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) of this paragraph), provided that the overall activity of the fixed place of business resulting from this the combination is of a preparatory or auxiliary character. (5) . Notwithstanding the provisions of paragraphs 1 and 2 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this AgreementConvention, the term "«permanent establishment" » means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "«permanent establishment" » includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, and f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) . A building site or construction or installation project constitutes a permanent establishment only if it lasts for more than six nine months. (4) . Notwithstanding the preceding provisions of this Article, the term "«permanent establishment" » shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing 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) 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 of this Article, where a person - other than an agent of an independent status to whom paragraph 6 of this Article 7 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article 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 and the provisions of Article 14, a person who is a resident of a Contracting State and carries on activities in connection with preliminary surveys, exploration, extraction or exploitation of natural resources situated in the other Contracting State shall be deemed to be carrying on in respect of those activities a business in that other Contracting State through a permanent establishment or a fixed base situated therein, unless such activities are carried on for a period or periods not exceeding 60 days in the aggregate in any twelve-month period. However, for the purposes of this paragraph: a) where an enterprise carrying on activities in the other State is related to another enterprise and that other enterprise continues as part of the same project the same activities that are or were being carried on by the first-mentioned enterprise, and the activities carried on by both enterprises exceed - when added together - a period of 60 days, then each enterprise shall be deemed to be carrying on its activities for a period exceeding 60 days in a twelve-month period. b) two enterprises shall be deemed to be related if one is controlled directly or indirectly by the other, or both are controlled directly or indirectly by a third person. 7. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) 8. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "permanent establishment" includes especially: a) a. 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. (3) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six months. (4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) 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) 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) 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 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; f) 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 businesss resulting from this combination is of a preparatory or auxiliary character. (5) . Notwithstanding the provisions of paragraphs 1 and 2 of this Article2, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, - provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) The term "“permanent establishment" ” includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, and f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) A building site or construction or assembly or installation project constitutes a permanent establishment only if it lasts more than six nine months. (4) Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to includeinclude : a) the use of facilities solely for the purpose of storage, storage or display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display storage or deliverydisplay; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise 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) 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 1, 2 and 2 of this Article3, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting in a Contracting State on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterpriseother Contracting State, that enterprise shall be deemed to have a permanent establishment in that the first-mentioned Contracting State in respect of any activities which that person undertakes for the enterprise, if such a person: a) has, and habitually exercises in that State an authority to conclude contracts in the name of the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article 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 shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their businessbusiness and no conditions are made or imposed between them in their commercial and financial relations, which differ from those usually agreed between independent persons. (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 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) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six months. (4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs 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 of this Article2, where a person - ‐‐ other than an agent of an independent status to whom paragraph 6 of this Article applies - ‐‐ is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other. 1. Income derived by a resident of a Contracting State from immovable property (including income from agriculture or forestry) situated in the other Contracting State may be taxed in that other State. 2. The term "immovable property" shall have the meaning which it has under the law of the Contracting State in which the property in question is situated. The term shall in any case include property accessory to immovable property, livestock and equipment used in agriculture and forestry, rights to which the provisions of general law respecting landed property apply, any option or similar right to acquire immovable property, 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, as well as income from the alienation of immovable property. 4. Where the ownership of shares or other corporate rights in a company entitles the owner of such shares or corporate rights to the enjoyment of immovable property held by the company, the income from the direct use, letting, or use in any other form of such right to enjoyment may be taxed in the Contracting State in which the immovable property is situated. 5. The provisions of paragraphs 1, 3 and 4 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 of natural resources. (3. The term „permanent establishment” also includes: a) A a building site or construction site, a construction, assembly or installation project constitutes or supervisory activities in connection therewith, but only where such site, project or activities continue for a permanent establishment only if it lasts period of more than six 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 activities of that nature continue (for the same or a connected project) within the country for a period or periods aggregating more than 6 months within any 12-month period. (4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, storage or display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display storage or deliverydisplay; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; f) the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs subparagraphs a) to e) of this paragraph), provided that such activity or, in the case of subparagraph f), the overall activity of the fixed place of business resulting from this combination combination, is of a preparatory or auxiliary character. (5) . Notwithstanding the provisions of paragraphs 1 and 2 of this Article but subject to the provisions of paragraph 6 of this Article, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting in a Contracting State on behalf of an enterprise and hasand: a) habitually concludes contracts, or habitually plays the principal role leading to the conclusion of contracts that are routinely concluded without material modification by the enterprise, and habitually exercises, in a Contracting State an authority to conclude these contracts are in the name of the enterprise, or for the transfer of the ownership of, or for the granting of the right to use, property owned by that enterprise or that the enterprise has the right to use, or for the provision of services by that enterprise, or b) habitually maintains in that State a stock of goods or merchandise belonging to the enterprise from which he regularly delivers goods or merchandise on behalf of the enterprise, that enterprise shall be deemed to have a permanent establishment in that Contracting State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article 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 . Paragraph 5 of this Article shall not be deemed to have a permanent establishment apply where the person acting in a Contracting State merely because it on behalf of an enterprise of the other Contracting State carries on business in that the first- mentioned Contracting State through a broker, general commission agent or any other agent of as an independent status, provided that such persons are acting agent and acts for the enterprise in the ordinary course of their that business. Where, however, a person acts exclusively or almost exclusively on behalf of one or more enterprises to which it is closely related, that person shall not be considered to be an independent agent within the meaning of this paragraph with respect to any such enterprise. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "permanent establishment" includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop, and workshop and f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. (3) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six months. (4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishmentestab- lishment" 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) 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 of this Article, where a person - other -other than an agent of an independent status to whom paragraph 6 of this Article applies - applies- is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2) . The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop, and, (f) a warehouse in relation to a person providing storage facilities for others; (g) a store or other sales outlet; (h) a farm or plantation; (i) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used for exploration or exploitation of natural resources. (3) . A building site or construction site, a construction, assembly or installation project or supervisory activities in connection therewith, constitutes a permanent establishment only if it such site, project or activities lasts more than six months. (4) . Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, storage or display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display storage or 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 advertising, or for the supply of information; (f) 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 , provided there is no 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 characterany such activities. (5) . Notwithstanding the provisions of paragraphs 1 and 2 of this Article2, where a person - -- other than an agent of an independent status to whom paragraph 6 of this Article 7 applies - -- is acting in a Contracting State on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterpriseother Contracting State, that enterprise shall be deemed to have a permanent establishment in that the first-mentioned Contracting State in respect of any activities which that person undertakes for the enterprise, if such a person: (a) has and habitually exercises in that State an authority to conclude contracts in the name of the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article 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 or; (c) he habitually secures orders in the first-mentioned State, wholly or almost wholly for the enterprise 6. Notwithstanding the preceding provisions of this Article, an insurance enterprise of a Contracting State shall, except in regard to re-insurance, be deemed to have a permanent establishment in the other Contracting State if it collects premiums in the territory of that other State or insures risks situated therein through a person other than an agent of an independent status to whom paragraph 7 applies. (6) 7. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, when the activities of such person 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) 8. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1) . For the purposes of this 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 wellxxxxx, a quarry or any other place of extraction of natural resources. (3) . A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six nine (9) months. (4) . Notwithstanding the preceding provisions of this Article, the term "«permanent establishment" » shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise 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) of this paragraph), provided that the overall activity of the fixed place of business resulting from this the combination is of a preparatory or auxiliary character. (5) . Notwithstanding the provisions of paragraphs 1 and 2 of this Article, where a person - other than an agent of an independent status to whom paragraph 6 of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6) . An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, status provided that such persons are acting in the ordinary course of their business. (7) . The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.