Common use of PERMANENT ESTABLISHMENT Clause in Contracts

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, 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 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 subparagraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this ConventionAgreement, 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 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 twelve six 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 six 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, 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 subparagraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - person—other than an agent of an independent status to whom paragraph 6 applies - 7 applies—is acting in a Contracting State on behalf of an enterprise and hasof the other Contracting State, has and habitually exercises, in a Contracting State exercises an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that the first-mentioned Contracting State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. 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 Contracting State or insures risks situated therein through a person other than an agent of an independent status to whom paragraph 7 applies. 7. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in 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. 78. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other Contracting State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this ConventionAgreement, the term “"permanent establishment” " means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term “"permanent establishment” includes " shall include especially: (a) a place of management; (b) a branch; (c) an office; (d) a 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 building site or construction, installation or assembly project, which exists for more than 6 months. 3. A building site or construction or installation project constitutes a permanent establishment only if it lasts more than twelve months. 4. Notwithstanding the preceding provisions of this Article, the 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 4. An enterprise of a fixed place of business solely Contracting State shall be deemed to have a permanent establishment in the other Contracting State if it carries on supervisory activities in that other State for any combination of activities mentioned more than 6 months in subparagraphs a) to e)connection with a building site or a construction, provided installation or assembly project which is being undertaken in that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary characterother State. 5. Notwithstanding the provisions of paragraphs 1 and 2, where Where a person - (other than an a broker, general commission agent or any other agent of an independent status to whom paragraph 6 applies - applies) is acting in a Contracting State on behalf of an enterprise and of the other Contracting State that enterprise shall be deemed to have a permanent establishment in the first-mentioned State if that person: (a) 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 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) maintains in the activities first-mentioned State a stock of such person are limited goods or merchandise belonging to those mentioned in paragraph 4 which, if exercised through a fixed place the enterprise 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 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 State through a broker, general commission agent or any other agent of an independent status, provided that where such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise, he shall not be considered an agent of an independent status if the transactions between the agent and the enterprise were not made under arm’s length conditions. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other 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 ConventionAgreement, 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" shall also include a building site or construction site, a construction, assembly or installation project constitutes a permanent establishment project, or supervisory activities in connection therewith, but only if it lasts such building site, project or activities last more than twelve 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 onadvertising, supplying information, scientific research or for the enterprise, any other activity of 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 subparagraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary characterenterprise. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 7 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. Notwithstanding the foregoing provisions of this Article, an insurance enterprise of a Contracting State shall, except in regard to reinsurance, be deemed to have a permanent establishment in the other Contracting State if it collects premiums in the territory of that other State or insures risks situated therein through a person other than an agent of an independent status to whom paragraph 7 applies. 7. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their businessbusiness and that in their commercial or financial relations with the enterprise, conditions are not made or imposed that differ from those generally agreed to by independent agents. 78. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, 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 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 subparagraphs sub-paragraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name on behalf of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 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 Convention, the term “permanent establishment” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term “permanent establishment” includes especially: a) a place of managementmanagement ; 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 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 subparagraphs sub-paragraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a the 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 Convention, 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 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 subparagraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name on behalf of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 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 purpose of this Convention, 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 mine, an oil or gas well, a quarry or any other place of extraction of natural resources.; 3. A g) a building site or construction or installation project constitutes a permanent establishment only if it lasts assembly project, which exists for more than twelve six months. 43. Notwithstanding the preceding provisions of this Article, the 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. A person acting in a Contracting State on behalf of a fixed place of business solely for any combination of activities mentioned in subparagraphs a) to e), provided that the overall activity an enterprise of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other Contracting State -other than an agent of an independent status to whom paragraph 6 5 applies - is acting on behalf of an enterprise and -shall be deemed to be a permanent establishment in the first-mentioned State if he has, and habitually exercisesexercises in that State, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise unless his activities are limited to the purchase of goods or merchandise for the enterprise. However, an insurance company of a Contracting State shall be deemed to have a permanent establishment in that the other Contracting State in respect of any activities which that person undertakes for the enterpriseprovided that, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of businessrepresentative other than the persons to whom paragraph 5 below applies, would not make this fixed place of business a permanent establishment under the provisions of it receives premium or insures risks in that paragraphother State. 65. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided that where such persons are acting in the ordinary course of their business. 76. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this ConventionAgreement, 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 twelve 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 pur- chasing 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) an installation or assembly project carried on by an enterprise of a Contracting State in the other Contracting State in connection with the delivery of machinery or equipment produced by that enterprise; g) the maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs a) to ef), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, 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 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 subparagraphs sub-paragraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a the 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 ConventionAgreement, 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 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 subparagraphs sub-paragraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - – other than an agent of an independent status to whom paragraph 6 applies - – is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name on behalf of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 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 ConventionAgreement, 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 premises used as sales outlet; g) a farm or plantation; h) a mine, an oil or gas well, a quarry or any other place of exploration, extraction or exploitation of natural resources. 3. A The term “permanent establishment” also encompasses a building site or construction site, a construction, assembly or installation project constitutes a permanent establishment or any supervisory activity in connection with such site or project, but only if it lasts where such site, project or activity continues for period or periods aggregating more than six months within any twelve monthsmonth 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 subparagraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 7 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. Notwithstanding the preceding provisions of this Article, an insurance enterprise of a Contracting State shall except in regard to reinsurance, be deemed to have a permanent establishment in the other Contracting State if it collects premiums on the territory of that other Contracting State or insures risks situated therein through a person, other than an agent of an independent status to whom paragraph 7 applies. 7. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise, and conditions are made or imposed between that enterprise and the agent in their commercial and financial relations which differ from those which would have been made between independent enterprises, he will not be considered an agent of an independent status within the meaning of this paragraph. 78. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, 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 twelve 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 subparagraphs sub-paragraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name on behalf of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 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 Convention, 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 twelve 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 subparagraphs (a) to (e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), ) shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this ConventionAgreement, 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 permanent sales exhibition. 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 twelve six months. 4. Notwithstanding the preceding provisions of this Articleparagraphs 1 to 3, the term “permanent establishment” shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or deliverystorage display; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or of 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 subparagraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - person–other than an agent of an independent status to whom paragraph 6 applies - 7 applies–is acting in a Contracting State on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterpriseother Contracting State, that enterprise shall be deemed to have a permanent establishment in that the first-mentioned Contracting State in respect of any activities which that person undertakes for the enterprise, if such a person: (a) has and habitually exercises in that State an authority to conclude contracts in the name of the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph; or (b) has no such authority, but habitually maintains in the first-mentioned State a stock of goods or merchandise from which he regularly delivers goods or merchandise on behalf of the enterprise. 6. Notwithstanding the preceding provisions of this Article, an insurance enterprise of a Contracting State shall, except in regard to reinsurance, be deemed to have a permanent establishment in the other Contracting State if it collects premiums in the territory of that other State or insures risks situated therein through a person other than an agent of an independent status to whom paragraph 7 applies. 7. An enterprise 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. 78. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other Contracting State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this ConventionAgreement, 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 premis used as sales outlet; (g) a farm or plantation; (h) a mine, an oil or gas well, a quarry or any other place of extraction extraction, exploitation or exploration of natural resources; and (i) a building site, a construction, assembly or installation project or any supervisory activity in connection with such site or project, but only where such site, project or activity continues for a period of more than (6) six months. 3. A building site or construction or installation project constitutes a permanent establishment only if it lasts 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, as long as it is not considered a sale; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery, as long as it is not considered a sale; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character;; and (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs (a) to (e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 54. Notwithstanding the provisions of paragraphs 1 (1) and (2), where a person - other than an agent of an independent status to whom paragraph 6 (6) applies - is acting on behalf of an enterprise and has, and habitually exercisesexercise, in a Contracting State an and 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 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. 5. Notwithstanding the proceeding provisions of this Article, an insurance enterprise of a Contracting State except in regard to reinsurance, of a Contracting State, be deemed to have a permanent establishment in the other Contracting State if it collects premiums on the territory of that other Contracting State or insures risks situated therein through a person, other than an agent of an independent status to whom paragraph (6) applies. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, when the activities of such 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. 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 Convention, 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 project, or an installation or drilling rig or ship used for the explora- tion of natural resources, constitutes a permanent establishment only if it lasts or the activity continues for more than twelve months. 4. Notwithstanding the preceding provisions of this ArticleArti- cle, 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 be- longing to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storagestor- age, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing pro- cessing 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 subparagraphs subpara- graphs a) to through e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - -- other than an agent of an independent status to whom paragraph 6 applies - -- is acting on behalf of an enterprise and has, 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 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 Con- tracting 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 estab- lishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this ConventionAgreement, 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 site, construction or installation project constitutes a permanent establishment only if it lasts 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 subparagraphs sub-paragraphs a) to e)) of this paragraph, provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - – other than an agent of an independent status to whom paragraph 6 applies - – is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State territory 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 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 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 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. 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 ConventionAgreement, the term “permanent establishment” means a fixed place of business through which the business of an the enterprise is wholly or partly carried on. 2. The term “permanent establishment” includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop; and; f) a warehouse, in relation to a person providing storage facilities for others; g) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources.; 3. A h) a building site or construction or installation assembly 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 twelve 6 months. 43. Notwithstanding the preceding provisions of this Article, the term “permanent establishment” shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise 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 subparagraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 54. Notwithstanding the provisions of paragraphs 1 and 2, where a person - (other than an agent of an independent status to whom paragraph 6 applies - 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 3 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. 65. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 76. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other 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 ConventionAgreement, 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 a farm, a ;lantation of a vineyard. 3. The term “permanent establishment” likewise encompasses: A building site or construction site, a construction, an 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 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 subparagraphs sub-paragraphs (a) to (e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 applies - is acting in a Contracting State on behalf of an enterprise and hasof the other Contracting State, has and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that the first-mentioned Contracting State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise, he will not be considered an agent of an independent status within the meaning of this paragraph. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, Convention 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 building site or construction or installation project constitutes a permanent establishment only if it lasts more than twelve 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, 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) the f. The maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs sub-paragraphs (a) to (e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 (1) and (2), where a person - other than an agent of an independent status to whom paragraph 6 (6) 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 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 Convention, 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 twelve 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, 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;; and f) the maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs (a) to (e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 applies - is acting in a Contracting State on behalf of an enterprise and 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, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1. ) For the purposes of this ConventionAgreement, 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) 1. a place of management; b) 2. a branch; c) 3. an office; d) 4. a factory; e) 5. a workshop; and f) , and 6. 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 twelve months. (4. ) Notwithstanding the preceding provisions of this Article, the term “permanent establishment” shall be deemed not to include: a) 1. the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) 2. the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) 3. the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) 4. 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) 5. 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) 6. the maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs a1) to e5), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. (5. ) Notwithstanding the provisions of paragraphs 1 and 2, where a person - — other than an agent of an independent status to whom paragraph 6 applies - — is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. (6. ) An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. (7. ) The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, 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 , g) a construction or installation project constitutes a permanent establishment only if it assembly site, which lasts for more than twelve months. 43. Notwithstanding the preceding provisions of this Article, the 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 enterpriseproviding information, any other activity of a conducting scientific research which is preparatory or auxiliary character; f) the maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs a) to e)nature, provided that these activities are carried out by the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary characterenterprise itself. 54. Notwithstanding the provisions of paragraphs 1 and 2, where Where a person - person--other than an agent of an independent status to whom paragraph 6 applies - is acting 5 applies--has the authority to enter into agreements in a Contracting State on behalf of an enterprise and has, and habitually exercises, in a from the other Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that the first- mentioned State in respect of any activities which that person undertakes for the enterprise, enterprise unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place the purchase of business, would not make this fixed place of business a permanent establishment under goods or assets for the provisions of that paragraphsame enterprise. 65. 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. 76. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.. Chapter III. Taxation of Income

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, 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 mine, an oil or gas well, a quarry or any other place of extraction of natural resources.; 3. A (g) a building site or construction or installation assembly project constitutes a permanent establishment only if it lasts which exists for more than twelve six months. 43. Notwithstanding the preceding provisions of this Article, the 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. A person acting in a Contracting State on behalf of a fixed place of business solely for any combination of activities mentioned in subparagraphs a) to e), provided that the overall activity an enterprise of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other Contracting State -- other than an independent agent of an independent status to whom paragraph 6 applies - is acting on behalf of an enterprise and -- shall be deemed to be a permanent establishment in the first-mentioned State if he has, and habitually exercisesexercises in that State, in a Contracting State an authority to conclude contracts in the name of the enterprise, that unless his activities are limited to the purchase of goods or merchandise for the enterprise. 5. An insurance enterprise of a Contracting State shall be deemed to have a permanent establishment in the other Contracting State if it collects premiums or insures risks in that other State in respect of any activities which that through a person undertakes for the enterprise, unless the activities of such person are limited other than those referred to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph6. 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 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 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 Convention, 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 includes, especially: a) a place offices or places of managementmanagement or business headquarters; b) a branchbranches and agencies; c) an officefactories, plants, workshops, and farming establishments; 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 construction, installation or assembly site or construction or installation project only constitutes a permanent establishment only if it lasts 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 ondoing, for the enterprise, any other activity of a auxiliary or preparatory or auxiliary character; f) the maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs a) to e)the preceding paragraphs, provided that the overall activity of the fixed place of business resulting from this combination is of a retains its auxiliary or preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - person--other than an agent of an independent status to whom paragraph 6 applies - applies--is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of in itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this ConventionAgreement, the term “" permanent establishment” " means a fixed place of business activities through which the business of an enterprise of a Contracting State is wholly or partly carried onon in the other Contracting State. 2. The term “"permanent establishment” " includes 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 or supervisory activities in connection therewith, constitutes a permanent establishment only if it lasts continues for a period of more than 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 onadvertising, for the enterprisesupply of information, any other activity of scientificic research or similar activities which have a preparatory or auxiliary character, for the enterprise; f) the maintenance of a stock of goods displaed by the resident in a stock fair or an exhibition which is to be sold after the conclusion: g) the maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs subparagraph a) to ef), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 applies - is acting in a Contracting State on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterpriseother Contracting State, that enterprise shall be deemed to have a permanent establishment in that the first mentioned Contracting State in respect of any activities which that person undertakes for the enterprise, if such a person has and habitually exercises in that State an authority to conclude contracts in the name of the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. 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 Convention, 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 mine, an oil or gas well, a quarry or any other place of extraction of natural resources.; 3. A (g) a building site or construction or installation assembly project constitutes a permanent establishment only if it lasts which exists for more than twelve months. 43. Notwithstanding the preceding provisions of this Article, the 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 of a fixed place of business solely for any combination of activities mentioned 4. A person acting in subparagraphs a) to e), provided that the overall activity one of the fixed place States on behalf of business resulting from this combination is an enterprise of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other State--other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf of an enterprise and 5 applies--shall be deemed to be a permanent establishment in the first-mentioned State if he has, and habitually exercisesexercises in that State, in a 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 the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 65. An enterprise of one of the States shall not be deemed to have a permanent establishment in a Contracting the other State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided that where such persons are acting in the ordinary course of their business. 76. The fact that a company which is a resident of a Contracting State one of the States controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.. Chapter III Taxation of Income

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, 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 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 subparagraphs sub-paragraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - – other than an agent of an independent status to whom paragraph 6 applies - – is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), ) shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1. ) For the purposes of this Conventionagreement, 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; 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.resources including timber or other forest produce 3. A (g) a farm or plantation (h) a building site or construction construction, installation or installation assembly project constitutes a permanent establishment only if it lasts which exists for more than twelve six months. 4. (3) 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 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 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) An enterprise of a contracting state shall be deemed to have a permanent establishment in the other Contracting state if it carries on supervisory activities in that other state for more than 6 months in connection with a construction, installation or assembly project which is being undertaken in that other State. (5. Notwithstanding the provisions of paragraphs 1 and 2, where a ) A person - (other than an a broker, general commission agent or any other agent of an independent status to whom paragraph 6 applies - is (6) applies) acting in a contracting state on behalf of an enterprise and of the other Contracting state shall be deemed to be 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 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 (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 which, if exercised through a fixed place the enterprise 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 paragraph.enterprise (6. ) An enterprise of a contracting state shall not be deemed to have a permanent establishment in a Contracting State the other contracting state merely because it carries on business in that State 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 contracting state controls or is controlled by a company which is a resident of the other Contracting Statecontracting state, or which carries on business in that other State 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 ConventionAgreement, 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 permanent sales outlet; g) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources; and h) an agricultural, pastoral or forestry property. 3. A The term “permanent establishment” also encompasses: 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 twelve monthssix month; 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 connected project) within the country for a period or periods aggregating more than three month. 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, 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 subparagraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 7 applies - is acting in a Contracting State on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterpriseother Contracting State, that enterprise shall be deemed to have a permanent establishment in that the first-mentioned Contracting State in respect of any activities which that person undertakes for the enterprise, if such a person: a) Has and habitually exercises in that State an authority to conclude contracts in the name of the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph; or b) Has no such authority, but habitually maintains in the first-mentioned State a stock of goods or merchandise from which he regularly delivers goods or merchandise on behalf of the enterprise. 6. Notwithstanding the preceding provisions of this Article, an insurance enterprise of a Contracting State shall, except in regard to re-insurance, be deemed to have a permanent establishment in the other Contracting State if it collects premiums in the territory of that other State or insures risks situated therein through a person other than an agent of an independent status to whom paragraph 7 applies. 7. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise, and conditions are made or imposed between that enterprise and the agent in their commercial and financial relations which differ from those which would have been made between independent enterprises, he will not be considered an agent of an independent status within the meaning of this paragraph. 78. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, 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 Convention, the term “permanent establishment” means a fixed place of business through in which the business of an enterprise the enterprise-is wholly or partly carried on. 2. The term “term” permanent establishment” includes shall include especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop; and; f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources.; 3. A g) a building site or construction or installation assembly project constitutes a permanent establishment only if it lasts which exists for more than twelve months. 43. Notwithstanding the preceding provisions of this Article, the 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. A person acting in a Contracting State on behalf of a fixed place of business solely for any combination of activities mentioned in subparagraphs a) to e), provided that the overall activity an enterprise of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other Contracting State-- other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf of an enterprise and 5 applies--shall be deemed to be a permanent establishment in the first-mentioned State if he has, and habitually exercisesexercises in that State, in a 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 the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 65. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided that where such persons are acting in the ordinary course of their business. 76. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.. Chapter III Taxation of Income

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, 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(1) a place of management; b(2) a branch; c(3) an office; d(4) a factory; e(5) a workshop; , and f(6) 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 twelve months. 4. Notwithstanding the preceding provisions of this Article, the term “,,permanent establishment” '' shall be deemed not to include: a(1) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b(2) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c(3) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d(4) 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(5) 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(6) the maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs asub-paragraphs (1) to e), (5) provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - – other than an agent of an independent status to whom paragraph 6 applies - – is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), ) shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, Convention the term “"permanent establishment” " means a fixed place of business through in 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 3. A g) a building site or construction or installation project constitutes a permanent establishment only if it lasts which exists for more than twelve 12 months. 43. Notwithstanding the preceding provisions of this Article, the term “"permanent establishment” " shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise;of 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 subparagraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 54. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 5 applies - is acting principally 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 person shall be deemed to have be a permanent establishment of the enterprise in that the first-mentioned State in respect of any activities which that person undertakes for the enterprise, enterprise unless the activities of such person are limited to those mentioned in paragraph 4 3 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 65. An enterprise 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 where such persons are acting in the ordinary course of their business. 76. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, 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 relating to the exploration for or the exploitation of natural resources. 3. A building site or construction or installation project constitutes a permanent establishment only if it lasts more than twelve months. 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 ctivitiy of a preparatory or auxiliary character; f6) the maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs asub-paragraphs 1) to e5), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - – other than an agent of an independent status to whom paragraph 6 applies - – is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of on behalfof the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, 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 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 subparagraphs sub-paragraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other -other than an agent of an independent status to whom paragraph 6 applies - applies- is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, 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" shall 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.; 3. A (g) a farm, plantation or other place where agricultural, forestry, plantation or related activities are carried on; (h) a building site or construction or installation assembly project constitutes a permanent establishment only if it lasts which exists for more than twelve six months; (i) the provision of supervisory activities for more than six months on a building site or construction or assembly project. 43. Notwithstanding the preceding provisions of this Article, the The term “"permanent establishment” " shall not be deemed not to include: (a) the use of facilities solely for the purpose purposes 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 purposes of storage, display storage or deliverydisplay; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose purposes of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose purposes 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 purposes 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. A person acting in a Contracting State on behalf of a fixed place of business solely for any combination of activities mentioned in subparagraphs a) to e), provided that the overall activity an enterprise of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other Contracting State -- other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf of an enterprise and -- shall be deemed to be a permanent establishment in the first-mentioned State if: (a) he has, and habitually exercisesexercises in that State, in a Contracting State an authority to conclude contracts in the name of the enterprise, unless his activities are limited to the purchase of goods or merchandise for the enterprise; or (b) he has no such authority, but habitually maintains in the first-mentioned State a stock of goods or merchandise from which he regularly delivers goods or merchandise on behalf of that enterprise. 5. An insurance enterprise of a Contracting State shall be deemed to have a permanent establishment in the other Contracting State if it collects premiums or insures risks in that other State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through an employee or through a fixed place representative who is not an agent of business, would not make this fixed place an independent status within the meaning of business a permanent establishment under the provisions of that paragraphparagraph 6. 6. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other 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, where the activities of such an agent are devoted wholly or mainly to that enterprise he would not be considered an agent of an independent status within the meaning of this paragraph, but in such cases the provisions of paragraph 4 would 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 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 Convention, 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 mine, an oil or gas well, a quarry or any other place of extraction of natural resources.; 3. A g) a building site or construction or installation assembly project constitutes a permanent establishment only if it lasts which exists for more than twelve 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. f4) the maintenance A person acting in a Contracting State on behalf of a fixed place of business solely for any combination of activities mentioned in subparagraphs a) to e), provided that the overall activity an enterprise of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other Contracting State -- other than an agent of an independent status to whom paragraph 6 5 applies - is acting on behalf of an enterprise and -- shall be deemed to be a permanent establishment in the first mentioned State if he has, and habitually exercisesexercises in that State, in a 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 the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. 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 where 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 for either company a permanent establishment of the other.. Chapter III Taxation of Income

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, 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 twelve 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 subparagraphs sub-paragraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - – other than an agent of an independent status to whom paragraph 6 applies - – is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, the term “"permanent establishment” " means a fixed place of business through which the business of an the enterprise is wholly or partly carried on. 2. The term “"permanent establishment” includes " shall include especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop; and; f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources.; 3. A g) a building site or construction or installation assembly project constitutes a permanent establishment only if it lasts which exists for more than twelve months. 43. Notwithstanding the preceding provisions of this Article, the The term “"permanent establishment” " shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of for collecting information, for the enterprise; e) the maintenance of a fixed place of business solely for the purpose of carrying onadvertising, for the enterprisesupply of information, any other activity of for scientific research or for similar activities which have a preparatory or auxiliary character;character for the enterprise. f) the maintenance 4. A person acting in a Contracting State on behalf of a fixed place of business solely for any combination of activities mentioned in subparagraphs a) to e), provided that the overall activity an enterprise of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person other Contracting State - other than an agent of an independent status to whom paragraph 6 5 applies - is acting on behalf of an enterprise and shall be deemed to be a permanent establishment in the first-mentioned State if he has, and habitually exercisesexercises in that State, in a 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 the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 65. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided that where such persons are acting in the ordinary course of their business. 76. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes purpose of this Convention, 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 mine, an oil or gas well, a quarry or any other place of exploration or extraction of natural resources.; 3. A g) a building site or construction or installation project constitutes a permanent establishment only if it lasts assembly project, which exists for more than twelve 6 months; h) a warehouse, in relation to a person providing storage facilities for others. 43. Notwithstanding the preceding provisions of this Article, the 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 storage or deliverydisplay; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of for collecting information, for the enterprise; 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. A person acting in a Contracting State on behalf of a fixed place of business solely for any combination of activities mentioned in subparagraphs a) to e), provided that the overall activity an enterprise of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other Contracting State – other than an agent of an independent status to whom paragraph 6 5 applies - is acting on behalf of an enterprise and – shall be deemed to be a permanent establishment in the first-mentioned State if he has, and habitually exercisesexercises in that State, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall unless his activities are limited to the purchase of goods or merchandise for the enterprise. However, an insurance company of a Contracting State shall, except in regard to reinsurance, be deemed to have a permanent establishment in the other Contracting State provided that State it receives premium or insures risks in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraphother State. 65. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided that where such persons are acting in the ordinary course of their business. 76. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this ConventionAgreement, the term “"permanent establishment” establishment means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term “permanent establishment” " includes 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 twelve 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 subparagraphs sub-paragraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 applies - is -is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State Party an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State Party in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State Party merely because it carries on business in that State Party through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State Party controls or is controlled by a company which is a resident of the other Contracting StateParty, or which carries on business in that other State Party (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other. Note 7: Luxembourg decided to apply some of the changes dealt with in Part IV of the MLI; however, the Isle of Man 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 ConventionAgreement, 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 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 subparagraphs sub-paragraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, 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 twelve 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 subparagraphs (a) to (e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - – other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), ) shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. ) For the purposes of this Convention, 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 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 subparagraphs sub-paragraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. ) Notwithstanding the provisions of paragraphs 1 and 2, where a person - (other than an agent of an independent status to whom paragraph 6 applies - applies) is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name on behalf of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 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 ConventionAgreement, 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 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 subparagraphs (a) to (e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - – other than an agent of an independent status to whom paragraph 6 applies - – is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this ConventionAgreement, 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 twelve months. 4. Notwithstanding the preceding provisions of this Article, 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 subparagraphs sub-paragraphs "a) " to "e)", provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 54. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 5 applies - is acting in a Contracting State on behalf of an enterprise 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 3 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 65. An enterprise of a Contracting 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. 76. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other Contracting State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, 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 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 subparagraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - – other than an agent of an independent status to whom paragraph 6 applies - – is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1. ) For the purposes of this ConventionAgreement, the term “‘permanent establishment” ’, in relation to an enterprise, means a fixed place of business through which the business of an the enterprise is wholly or partly carried on. (2. ) The term “‘permanent establishment” includes ’ shall include especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources.; 3. A (g) an agricultural, pastoral or forestry property; Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income (h) a building site or construction construction, installation or installation assembly project, or supervisory activities in connection with such a site or project, where that site or project constitutes a permanent establishment only if it lasts exists, or those activities are carried on, for more than twelve months. 4. Notwithstanding the preceding provisions of this Article, the term “permanent establishment” (3) An enterprise shall not be deemed not to includehave a permanent establishment merely by reason of: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of for collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, activities which have a preparatory or auxiliary character for the enterprise, any other activity of a preparatory such as advertising or auxiliary character;scientific research. f(4) the maintenance of a fixed place of business solely for any combination of activities mentioned A person acting in subparagraphs a) to e), provided that the overall activity one of the fixed place Contracting States on behalf of business resulting from this combination is an enterprise of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other Contracting State—other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf (5) applies—shall be deemed to be a permanent establishment of an that enterprise and in the first-mentioned State if: (a) he has, and habitually exercisesexercises in that State, in a Contracting State an authority to conclude contracts in the name on behalf of the enterprise, that enterprise shall be deemed unless his activities are limited to have a permanent establishment the purchase of goods or merchandise for the enterprise; or (b) in so acting, he manufactures or substantially processes in that State in respect of any activities which that person undertakes for the enterprise goods or merchandise belonging to the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under provided that the provisions of that paragraphthis sub-paragraph shall apply only in relation to the goods or merchandise so manufactured or processed. 6. (5) An enterprise of one of the Contracting States shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided where that such persons are person is acting in the ordinary course of their businesshis business as such a broker or agent. 7. (6) The fact that a company which is a resident of a one of the Contracting State States controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute make either company a permanent establishment of the other. (7) The principles set forth in the preceding paragraphs of this Article shall be applied in determining for the purposes of this Agreement whether there is a permanent establishment outside both Contracting States, and whether an enterprise, not being an enterprise of one of the Contracting States, has a permanent establishment in one of the Contracting States.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, 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 exploration and extraction of natural resources; g) a sales outlet; and h) a warehouse put at the disposal of a person providing storage facilities for others. 3. A The term “permanent establishment” also encompasses: a) a building site or construction site, a construction, assembly or installation project constitutes or supervisory activities in connection therewith, but only if such site, project or activities lasts more than six months; b) the furnishing of services, including consultancy services, by an enterprise through employees or other personnel engaged by the enterprise for such purpose, but only if activities of that nature continue (for the same or a connected project) within a Contracting State for a period or periods aggregating more than three months within any twelve-month period; c) a person carrying on activities in a Contracting State in connection with the exploration for, the extraction of or exploitation of natural resources situated in that Contracting State, including the exploration or exploitation of the seabed and subsoil and the extraction of their natural resources, shall be deemed to be carrying on a business through a permanent establishment only if it lasts more than twelve monthsin that Contracting State. For the purposes of this paragraph "activities" shall include the provision of any services or facilities or supply of plant or machinery on hire used or to be used, in connection with the exploration for, the extraction of or the exploitation of natural resources. 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, 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 subparagraphs sub-paragraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - – other than an agent of an independent status to whom paragraph 6 applies - – is acting in a Contracting State on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterpriseother Contracting State, that enterprise shall be deemed to have a permanent establishment in that the first-mentioned Contracting State in respect of any activities which that person undertakes for the enterprise, if such a person: a) has and habitually exercises in that State an authority to conclude contracts in the name of the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph; or b) has no such authority, but habitually maintains in the first-mentioned State a stock of goods or merchandise from which he regularly delivers goods or merchandise on behalf of the enterprise. 6. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in 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, 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 Convention, 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 twelve months. 4. Notwithstanding the preceding provisions of this Article, the term “permanent establishment” shall be deemed not to include:term (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 purposes of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character;; and (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs (a) to (e), ) of this paragraph provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name on behalf of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 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 Convention, 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 assembly site only constitutes a permanent establishment only if it lasts more than twelve provided its duration exceeds eight 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 subparagraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 one and 2two, where a person - other than an agent of an independent status to whom paragraph 6 six 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 four 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.. Chapter III Taxation of Income

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, Convention 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. a place of management; b) b. a branch; c) c. an officeoffice ; 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 g. a building site or construction or installation assembly project constitutes a permanent establishment only if it lasts which exists for more than twelve twenty-four months. 43. Notwithstanding the preceding provisions of this Article, the 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) a. the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) b. the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) c. 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) d. 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;character for the enterprise. f) the maintenance of 4. A person acting in a fixed place of business solely for any combination of activities mentioned in subparagraphs a) to e), provided that the overall activity Contracting State on behalf of the fixed place enterprise of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other Contracting State – other than an agent of an independent status to whom paragraph 6 5 applies - is acting on behalf of an enterprise and – shall be deemed to be a permanent establishment in the first-mentioned State if he has, and habitually exercisesexercises in that State, in a 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 the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 65. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent statusstate, provided that where such persons are person is acting in the ordinary course of their his business. 76. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, 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 ConventionAgreement, 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; and f(g) a mine, an oil or gas well, a quarry or any other place of exploration for or extraction of natural resources. 3. A The term “permanent establishment” also encompasses: (a) a building site or construction site, a construction, assembly or installation project constitutes a permanent establishment or supervisory activities in connection therewith, but only if it lasts such site, project or activities last more than twelve six months; and (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 if activities of that nature continue (for the same or a connected project) within a Contracting State for a period or periods aggregating more than six months within any twelve-month period. 4. Notwithstanding the preceding provisions of this Article, the term “permanent establishment” shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, 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, information for the enterprise;; and (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 subparagraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 22 of this Article, where a person - other than an agent of an independent status to whom paragraph 6 applies - is acting in a Contracting State on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterpriseother Contracting State, that enterprise shall be deemed to have a permanent establishment in that the first-mentioned Contracting State in respect of any activities which that person undertakes for the enterprise, if such a person: (a) has and habitually exercises in that State an authority to conclude contracts in the name of the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph; or (b) has no such authority, but habitually maintains in the first-mentioned State a stock of goods or merchandise from which he regularly delivers goods or merchandise on behalf of the enterprise. 6. An enterprise of a Contracting State shall not be deemed to have a permanent establishment 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, and conditions are made or imposed between that enterprise and the agent in their commercial and financial relations which differ from those which would have been made between independent enterprises, he will not be considered an agent of an independent status within the meaning of this paragraph. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other Contracting State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, 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 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 subparagraphs sub-paragraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - person--other than an agent of an independent status to whom paragraph 6 applies - applies--is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this ConventionAgreement, 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 mine, an oil or gas well, a quarry or any other place of extraction of natural resources.; 3. A (g) a farm, plantation or other place where agricultural, forestry, plantation or related activities are carried on; (h) a building site or construction or installation assembly project constitutes a permanent establishment only if it lasts which exists for more than twelve six months; (i) the provision of supervisory activities for more than six months on a building site or construction or assembly project. 43. Notwithstanding the preceding provisions of this Article, the 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 fixed place of business solely for any combination of activities mentioned Contracting State shall be deemed to have a permanent establishment in subparagraphs a) to e), provided that the overall other Contracting State if it carries on the activity of providing the fixed place services within that other Contracting State of business resulting from this combination is of a preparatory public entertainers or auxiliary characterathletes referred to in Article 19. 5. Notwithstanding A person acting in a Contracting State on behalf of an enterprise of the provisions of paragraphs 1 and 2, where a person - other Contracting State -- other than an agent of an independent status to whom the provisions of paragraph 6 applies - is acting on behalf 7 of an enterprise and this Article apply -- shall be deemed to be a permanent establishment in the first-mentioned State if: (a) he has, and habitually exercisesexercises in that State, in a Contracting State an authority to conclude contracts in the name of the enterprise, unless his activities are limited to the purchase of goods or merchandise for the enterprise; or (b) he maintains in that former State a stock of goods or merchandise belonging to the enterprise from which he regularly fulfils orders on behalf of that enterprise. 6. An insurance enterprise of a Contracting State shall be deemed to have a permanent establishment in the other Contracting State if it collects premiums in that other State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised or insures risks therein through an employee or through a fixed place representative who is not an agent of business, would not make this fixed place independent status within the meaning of business a permanent establishment under the provisions of that paragraphparagraph 7. 67. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided that where such persons are acting in the ordinary course of their business. An agent shall not, however, be deemed to be an agent of an independent status within the meaning of this paragraph if his activities are devoted wholly or almost wholly to the business of that enterprise. 78. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting Cont racting 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 ConventionAgreement, 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 twelve 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 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 22 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 ConventionAgreement, 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 warehouse; (h) a permanent sales exhibition; and (i) premises for receiving and soliciting orders. 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 twelve three months. 4. Notwithstanding the preceding provisions of this Articleparagraphs 1 to 3, the term “"permanent establishment” " shall be deemed not to include: (a) the use of facilities facilities, solely for the purpose of storage, or display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display storage or deliverydisplay; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying onadvertising, for the enterprise, any other activity supply of information or for similar activities which have a preparatory or auxiliary character; f) , for the maintenance enterprise and which are performed free of a fixed place charge and not for purpose of business solely for any combination of activities mentioned in subparagraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary characterprofits. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - person--other than an agent of an independent status to whom paragraph 6 applies - 7 applies--is acting in a Contracting State on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterpriseother Contracting State, that enterprise shall be deemed to have a permanent establishment in that the first-mentioned Contracting State in respect of any activities which that person undertakes for the enterprise, if such a person: (a) has and habitually exercises in that State an authority to conclude, contracts in the name of the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that this paragraph; or (b) has no such authority, but habitually maintains in the first-mentioned State a stock of goods or merchandise from which he regularly delivers goods or merchandise on behalf of the enterprise. 6. Notwithstanding the preceding provisions of this Article, an insurance enterprise of a Contracting State shall, except in regard to re-insurance, be deemed to have a permanent establishment in the other Contracting State if it collects premiums in the territory of that other State or insures risks situated therein through a person other than an agent of an independent status to whom paragraph 7 applies. 7. An enterprise 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. 78. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), ) shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, 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 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 subparagraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom the provisions of paragraph 6 applies apply - is acting 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 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 ConventionAgreement, 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 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 subparagraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - – other than an agent of an independent status to whom paragraph 6 applies - – is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise, he will not be considered an agent of an independent status within the meaning of this paragraph. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, 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 mine, an oil or gas well, a quarry or any other place of extraction of natural resources.; 3. A g) a building site or construction or installation assembly project constitutes a permanent establishment only if it lasts which exists for more than twelve six months. 43. Notwithstanding the preceding provisions of this Article, the 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. A person acting in a Contracting State on behalf of a fixed place of business solely for any combination of activities mentioned in subparagraphs a) to e), provided that the overall activity an enterprise of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other Contracting State -- other than an agent of an independent status to whom paragraph 6 5 applies - is acting on behalf of an enterprise and -- shall be deemed to be a permanent establishment in the first mentioned State if he has, and habitually exercisesexercises in that State, in a 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 the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 65. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided that where such persons are acting in the ordinary course of their business. 76. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute for either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this ConventionAgreement, 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 refinery; h) a sales outlet; and i) a warehouse in relation to a person providing storage facilities for others. 3. A building site or construction or installation project constitutes a permanent establishment only if it lasts more than twelve months. 4. An enterprise shall be deemed to have a permanent establishment in a Contracting Party and to carry on business through that permanent establishment if in that Party it carries on any activity which is directly 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 subparagraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 56. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State Party an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State Party in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 5 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 67. An enterprise shall not be deemed to have a permanent establishment in a Contracting State Party merely because it carries on business in that State Party through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 78. The fact that a company which is a resident of a Contracting State Party controls or is controlled by a company which is a resident of the other Contracting StateParty, or which carries on business in that other State Party (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.. Chapter III Taxation of Income Article 6

PERMANENT ESTABLISHMENT. 1. For the purposes of this ConventionAgreement, 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 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 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 subparagraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this ConventionAgreement, 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 twelve 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 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 subparagraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State 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 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 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. 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 purpose of this Convention, 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 especiallybut is not limited to: 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 or construction site, a construction, assembly or installation project, or supervisory activities in connection therewith, but only where such site, project constitutes or activities continue for a permanent establishment only if it lasts period of more than twelve six months; b) the furnishing of services, including consultancy services, by an enterprise through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (for the same or a connected project) within a Contracting State for a period or periods aggregating more than six months within any 12-month period; c) a person acting in one of the two Contracting States on behalf of an enterprise of the other Contracting State – other than an agent of an independent status to whom the provisions of paragraph 5 of this Article apply – if this person has in the first mentioned Contracting State an authority to conclude contracts in the name of that enterprise and habitually exercises such authority in it, in respect of any activities which that person undertakes for the enterprise. 4. Notwithstanding the preceding provisions of this Article, the term “Article a permanent establishment” shall be deemed establishment does not to include: a) the use of facilities solely for the sole 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 sole purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the sole purpose of processing by another enterprise; d) the maintenance of a fixed place of business solely for the sole purpose of purchasing goods or merchandise or of collecting information, information for the enterprise; e) the maintenance of a fixed place of business solely for the sole purpose of carrying onadvertising, conducting scientific research, or similar activities of preliminary or auxiliary nature 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 subparagraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf of an An enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name one of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise two 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 State through a broker, general commission agent or any other agent of an independent status, provided that such persons are this broker or agent is acting in the ordinary course of their his business. 6. An enterprise in one of the two Contracting States shall not be deemed to have a permanent establishment in the other Contracting State merely because it carries on at the end of a trade exhibition or 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.. Chapter III Taxation of Income Article 6

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, 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 mine, an oil or gas well, a quarry or any other place of extraction of natural resources.; 3. A (g) a building site or construction or installation assembly project constitutes a permanent establishment only if it lasts which exists for more than twelve six months. 43. Notwithstanding the preceding provisions of this Article, the The term “permanent establishment” shall not be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of 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. A person acting in a Contracting State on behalf of a fixed place of business solely for any combination of activities mentioned in subparagraphs a) to e), provided that the overall activity an enterprise of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person other Contracting State - other than an agent of an independent status to whom paragraph 6 5 applies - is acting on behalf of an enterprise and shall be deemed to be a permanent establishment in the first-mentioned State if he has, and habitually exercisesexercises in that State, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise unless his activities are limited to the purchase of goods or merchandise for the enterprise. However, an insurance company of a Contracting State shall be deemed to have a permanent establishment in that the other Contracting State in respect of any activities which that person undertakes for the enterpriseprovided that, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of businessrepresentative other than persons to whom paragraph 5 below applies, would not make this fixed place of business a permanent establishment under the provisions of it receives premium or insures risks in that paragraphother State. 65. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided that where such persons are acting in the ordinary course of their business. 76. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this ConventionAgreement, 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 twelve (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 subparagraphs sub-paragraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

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

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, 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 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 twelve months. 4. Notwithstanding the preceding provisions of this Articleparagraphs 1 and 2, the term “permanent establishment” shall include a building site or construction or assembly project only if it exists for more than a) six months, in the case of installation or setting up of plant equipment or machinery including the auxiliary construction as is necessary for such installation; b) three months, in all other cases. 4. 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; f) , for the maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary characterenterprise. 5. Notwithstanding A person acting in one of the provisions States on behalf of paragraphs 1 and 2, where a person - an enterprise of the other State – other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf of an enterprise and – shall be deemed to be 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 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; or b) he habitually maintains in the first-mentioned State a stock of goods or merchandise belonging to the enterprise from which he regularly fills orders on behalf of the enterprise; or c) he habitually secures orders in the first-mentioned State, unless wholly or almost wholly for the activities of such person enterprise itself, or for the enterprise and other enterprises which are limited to those mentioned controlled by it or have a controlling interest in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraphit. 6. An enterprise of one of the States shall not be deemed to have a permanent establishment in a Contracting the other State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided that where such persons are acting in the ordinary course of their business. This shall not apply if such broker or agent carries on in that other State an activity described in paragraph 5 wholly or almost wholly for the enterprise itself or for the enterprise and other enterprises which are controlled by or have a controlling interest in it. 7. The fact that a company which is a resident of a Contracting State one of the States controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.. Chapter III Taxation of Income Article 6

PERMANENT ESTABLISHMENT. 1. For the purposes of this ConventionAgreement, the term “permanent establishment” ―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” ―permanent establishment‖ includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) warehouse, in relation to a person providing storage facilities for others; (g) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources.; 3. A (h) a building site or construction or installation assembly 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 twelve 6 months. 43. Notwithstanding the preceding provisions of this Article, the term “permanent establishment” ―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 subparagraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 54. Notwithstanding the provisions of paragraphs 1 and 2, where a person - (other than an agent of an independent status to whom paragraph 6 applies - 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 3 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. 65. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 76. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other 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 Convention, the term “permanent establishment” means a fixed place of business through which the business of an the enterprise is wholly or partly carried on. 2. The term “permanent establishment” includes shall include especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources.; 3. A (g) a building site or construction or installation assembly project constitutes a permanent establishment only if it lasts which exists for more than twelve months. 43. Notwithstanding the preceding provisions of this Article, the The term “permanent establishment” shall not be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying 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) character for the maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary characterenterprise. 54. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 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 3 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 65. An enterprise of a Contracting 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. 76. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), ) shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, the term “"permanent establishment” " means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term “"permanent establishment” includes " shall include especially: a) a place of management; b) a branch; c) a store or other sales outlet; d) an office; de) a warehouse, in relation to a person providing storage facilities for others; f) a factory; eg) a workshop; and; fh) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources.; and 3. A (i) a building site or construction or installation assembly project constitutes a permanent establishment only if it lasts which exists for more than twelve six months. 43. Notwithstanding the preceding provisions of this Article, the 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. f) the maintenance of a fixed place of business solely for any combination of activities mentioned 4. A person acting in subparagraphs a) to e), provided that the overall activity one of the fixed place Contracting States on behalf of business resulting from this combination is an enterprise of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person other Contracting State - other than an agent of an independent status to whom paragraph 6 5 applies - is acting on behalf of an enterprise and shall be deemed to be a permanent establishment in the first-mentioned Contracting State; a) if he has, and habitually exercisesexercises in that first-mentioned Contracting State, in a 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; or b) if he maintains in that first-mentioned Contracting State a stock of goods or merchandise belonging to the enterprise from which he habitually fills orders or makes deliveries on behalf of the enterprise; or c) if he maintains in that first-mentioned Contracting State equipment or machinery for rental or other purposes within such State for a period, unless or periods, exceeding in the activities aggregate six months during the year of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under income or the provisions of that paragraphtaxation year as the case may be. 65. An enterprise of one of the Contracting States shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided that where such persons are acting in the ordinary course of their business. 76. The fact that a company which is a resident of a one of the Contracting State States controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, 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 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. 4. A building site or construction constriction or installation project constitutes a permanent establishment only if it lasts more than twelve months. 45. Notwithstanding the preceding provisions of this Article, the term “permanent establishment” shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; f) the maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs (a) to (e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 56. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 7 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State 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 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 67. An enterprise shall not be deemed to have a permanent establishment in a Contracting State 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. 78. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, 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 twelve 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 subparagraphs sub-paragraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, 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 mine, an oil or gas well, a quarry or any other place of extraction of natural resources.; 3. A (g) a building site or construction or installation project constitutes a permanent establishment only if it lasts which exists for more than twelve 12 months; (h) premises used as sales outlet. 43. Notwithstanding the preceding provisions of this Article, the 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; f) , for the maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary characterenterprise. 54. Notwithstanding the provisions of paragraphs 1 and 2, where a A person - (other than an agent of an independent status to whom paragraph 6 applies - is 5 applies) acting in a Contracting State on behalf of an enterprise and of the other Contracting State shall be deemed to be a permanent establishment in the first-mentioned State if he has, and habitually exercisesexercises in that State, in a 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 the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 65. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided that where such persons are acting in the ordinary course of their business. 76. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other. 7. Notwithstanding the provisions of subparagraph (d) of paragraph 3 and those of paragraph 4, an enterprise of a Contracting State shall be deemed to have a permanent establishment in the other Contracting State if it maintains in that other State a fixed place of business or an agent referred to in paragraph 4 for the purposes of purchasing agricultural or mineral products or livestock.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, 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" shall include especially : (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a warehouse; (g) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources.; 3. A (h) a building site or construction or installation assembly project constitutes a permanent establishment only if it lasts or the like which exists for more than twelve months183 days. 43. Notwithstanding the preceding provisions of this Article, the The term “"permanent establishment” " shall not be deemed not to include: (a) the use of facilities solely for the purpose purposes of storage, storage or display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display storage or deliverydisplay; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of for collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying onadvertising, for the enterprise, any other activity supply of information for scientific research or for similar activities which have a preparatory or auxiliary character; f) character for the maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary characterenterprise. 54. Notwithstanding the provisions of paragraphs 1 and (1) & (2), where a person - other than an agent of an independent status status, to whom paragraph 6 (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, if— (a) he has, and habitually exercises, in the first-mentioned State in respect a general authority to conclude contracts for or on behalf of any the enterprise, unless his activities which that person undertakes are limited to the purchase of goods or merchandise for the enterprise, unless or (b) he habitually maintains in the activities first-mentioned State a stock of such goods or merchandise belonging to the enterprise from which that person regularly delivers goods or merchandise for or on behalf of the enterprise, or (c) he habitually secures orders in the first-mentioned State, wholly or almost wholly, for the enterprise itself, or for the enterprise or other enterprises which are limited to those mentioned controlled by it or have controlling interest in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraphit. 65. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided that where such persons are acting in the ordinary course of their businessbusiness and their activities do not fall within the scope of paragraph (4)(c) above. 76. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), ) shall not of itself constitute make either company a permanent establishment of the other. 7. An enterprise of a Contracting State shall be deemed to have a permanent establishment in the other Contracting State if it carries on a business which consists of providing the services of public entertainers (such as stage, motion picture, radio or television artists and musicians) or athletes in that other Contracting State unless such services are provided within the scope of a cultural or sports exchange programme agreed to by both the Contracting States. CHAPTER III

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, 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 twelve 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 subparagraphs sub-paragraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other. 8. Notwithstanding the preceding provisions of this Article and the provisions of Article 14 (Independent Personal Services), 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. . The provisions of paragraph 8 shall not apply where the activities are carried on for a period or periods not exceeding 30 days in the aggregate in any 12 months' period. However, for the purpose of this paragraph, activities carried on by an enterprise related to another enterprise within the meaning of Article 9 (Associated Enterprises) shall be regarded as carried on by the enterprise to which it is related if the activities in question are substantially the same as those carried on by the last-mentioned enterprise.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, 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 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 subparagraphs sub-paragraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this ConventionAgreement, the term “permanent establishment” means a fixed place of business through which the business of an the enterprise is wholly or partly carried on. 2. The term “permanent establishment” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a warehouse, in relation to a person providing storage facilities for others; (g) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources.; 3. A (h) a building site or construction or installation assembly 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 twelve 6 months. 43. Notwithstanding the preceding provisions of this Article, the term “permanent establishment” shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise 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 subparagraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 54. Notwithstanding the provisions of paragraphs 1 and 2, where a person - (other than an agent of an independent status to whom paragraph 6 applies - 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 3 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. 65. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 76. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other 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 Convention, 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 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 subparagraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, 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 twelve months. 4. Notwithstanding the preceding provisions of this Article, the term “permanent establishment” shall be he 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, 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 subparagraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 22 of this Article, where a person - -- 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 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. A person engaged in a Contracting State in exploration of the seabed and its subsoil or in exploitation of natural resources situated there, as well as in activities which are complementary or auxiliary to such activities, shall be deemed to exercise such activities through a permanent establishment in that State. However, this provision shall not apply where these activities are carried on in the other Contracting State for a period not exceeding 30 days. 7. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 78. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, 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 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 subparagraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 22 but subject to the provisions of paragraph 6, where a person - other than an agent of an independent status to whom paragraph 6 applies - is acting in a Contracting State on behalf of an enterprise and hasin 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, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.or

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, Agreement 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. 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. g. A building site or construction or installation assembly project constitutes a permanent establishment only if it lasts which exists for more than twelve six months. 43. Notwithstanding the preceding provisions of this Article, the The term “permanent establishment” shall not 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 merchandise, or of for collecting information, for the enterprise; e) the 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. A person acting in a Contracting State on behalf of a fixed place of business solely for any combination of activities mentioned in subparagraphs a) to e), provided that the overall activity an enterprise of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person other Contracting State - other than an agent of an independent status to whom paragraph 6 (5) applies - is acting on behalf of an enterprise and shall be deemed to be a permanent establishment in the first-mentioned State if he has, and habitually exercisesexercises in that State, in a 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 the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 65. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided that where such persons are acting in the ordinary course of their business. 76. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute make either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, 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 g) a building site or construction or installation project constitutes a permanent establishment project, only if it lasts more than twelve months. 43. Notwithstanding the preceding provisions of this Article, the term “permanent establishment” shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; f) the maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs sub-paragraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 54. Notwithstanding the provisions of paragraphs 1 and 2, where a person - person--other than an agent of an independent status to whom paragraph 6 applies - 5 applies--is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the 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 3 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 65. An enterprise 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. 76. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, the term “"permanent establishment” " means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term “"permanent establishment” " includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop; and , and f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. 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. 4. A building site or construction or installation project constitutes a permanent establishment only if it lasts more than twelve months. 45. Notwithstanding the preceding provisions of this Article, the term “"permanent establishment” " shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; f) the maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs (a) to (e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 56. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 7 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State 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 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 67. An enterprise shall not be deemed to have a permanent establishment in a Contracting State 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. 78. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, 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 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 subparagraphs sub-paragraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - – other than an agent of an independent status to whom paragraph 6 applies - – is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this ConventionAgreement, 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, including an installation or structure used for the exploration or exploitation of natural resources; and (g) a warehouse, in relation to a person providing storage facilities for others. 3. A building site, a construction, installation or assembly project or any supervisory activity in connection with such site or construction or installation project constitutes a permanent establishment only if it lasts more than twelve 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 for collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character;; and (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs (a) to (e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - -- other than an agent of an independent status to whom paragraph 6 applies - -- is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this ConventionAgreement, 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 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 subparagraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - – other than an agent of an independent status to whom paragraph 6 applies - – is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State Party an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State Party in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State Party merely because it carries on business in that State Party through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State Party controls or is controlled by a company which is a resident of the other Contracting StateParty, or which carries on business in that other State Party (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this ConventionAgreement, 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 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 subparagraphs (a) to (e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.. Chapter III Taxation of Income

PERMANENT ESTABLISHMENT. (1. ) For the purposes of this ConventionAgreement, the term “‘permanent establishment” ’, in relation to an enterprise, means a fixed place of business through which the business of an the enterprise is wholly or partly carried on. (2. ) The term “‘permanent establishment” includes ’ shall include especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources.; 3. A (g) an agricultural, pastoral or forestry property; (h) a building site or construction construction, installation or installation assembly project, or supervisory activities in connection with such a site or project, where that site or project constitutes a permanent establishment only if it lasts exists, or those activities are carried on, for more than twelve months. 4. Notwithstanding the preceding provisions of this Article, the term “permanent establishment” (3) An enterprise shall not be deemed not to includehave a permanent establishment merely by reason of: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of for collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, activities which have a preparatory or auxiliary character for the enterprise, any other activity of a preparatory such as advertising or auxiliary character;scientific research. f(4) the maintenance of a fixed place of business solely for any combination of activities mentioned A person acting in subparagraphs a) to e), provided that the overall activity one of the fixed place Contracting States on behalf of business resulting from this combination is an enterprise of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other Contracting State—other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf (5) applies—shall be deemed to be a permanent establishment of an that enterprise and in the first-mentioned State if: (a) he has, and habitually exercisesexercises in that State, in a Contracting State an authority to conclude contracts in the name on behalf of the enterprise, that enterprise shall be deemed unless his activities are limited to have a permanent establishment the purchase of goods or merchandise for the enterprise; or (b) in so acting, he manufactures or substantially processes in that State in respect of any activities which that person undertakes for the enterprise goods or merchandise belonging to the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under provided that the provisions of that paragraphthis sub-paragraph shall apply only in relation to the goods or merchandise so manufactured or processed. 6. (5) An enterprise of one of the Contracting States shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided where that such persons are person is acting in the ordinary course of their businesshis business as such a broker or agent. 7. (6) The fact that a company which is a resident of a one of the Contracting State States controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute make either company a permanent establishment of the other. (7) The principles set forth in the preceding paragraphs of this Article shall be applied in determining for the purposes of this Agreement whether there is a permanent establishment outside both Contracting States, and whether an enterprise, not being an enterprise of one of the Contracting States, has a permanent establishment in one of the Contracting States.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, 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 mine, an oil or gas well, a quarry or any other place of extraction of natural resources.; 3. A (g) a building site or construction or installation assembly project constitutes a permanent establishment only if it lasts which exists for more than twelve months183 days; (h) the furnishing of services, including consultancy services, by an enterprise through employees or other personnel, where activities of that nature continue within the country for a period or periods aggregating more than 183 days within any twelve-month period. 43. Notwithstanding the preceding provisions of this Article, the 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;character for the enterprise. f) the maintenance 4. A person acting in a Contracting State on behalf of a fixed place of business solely for any combination of activities mentioned in subparagraphs a) to e), provided that the overall activity an enterprise of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person other Contracting State - other than an agent of an independent status to whom paragraph 6 5 applies - is acting on behalf of an enterprise and shall be deemed to be a permanent establishment in the first-mentioned State if he has, and habitually exercisesexercises in that State, in a 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 the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 65. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that 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. 76. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other. Article 6 - Income from immovable property 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 be defined in accordance with 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 shall also be considered as "immovable property". Ships, boats and aircraft shall not be regarded as immovable property. 3. The provisions of paragraph 1 shall apply to income derived from the direct use, letting, or use in any other form of immovable property. 4. The provisions of paragraphs 1 and 3 shall also apply to the income from immovable property of an enterprise and to income from immovable property used for the performance of independent personal services.

PERMANENT ESTABLISHMENT. 1. For the purposes of this ConventionAgreement, 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 twelve 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 subparagraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - – other than an agent of an independent status to whom paragraph 6 applies - – is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State Party an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State Party in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State Party merely because it carries on business in that State Party through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State Party controls or is controlled by a company which is a resident of the other Contracting StateParty, or which carries on business in that other State Party (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, 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 twelve 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, 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 subparagraphs sub-paragraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 applies - is acting in a Contracting State on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterpriseother Contracting State, that enterprise shall be deemed to have a permanent establishment in that the first-mentioned Contracting State in respect of any activities which that person undertakes for the enterprise, if such a person: a) has and habitually exercises in that State an authority to conclude contracts in the name of the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph; or b) has no such authority, but habitually maintains, in the first mentioned State a stock of goods or merchandise from which he regularly delivers goods or merchandise on behalf of the enterprise. 6. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in 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. 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 Convention, 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 mine, an oil or gas well, a quarry or any other place of extraction of natural resources.; 3. A (g) a building site or construction or installation assembly project constitutes a permanent establishment only if it lasts which exists for more than twelve months. 43. Notwithstanding the preceding provisions of this Article, the The term “"permanent establishment” " shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying onadvertising, for the enterprisesupply of information, any other activity of for scientific research or for similar activities which have a preparatory or auxiliary character;character for the enterprise. f) the maintenance 4. A person acting in a Contracting State on behalf of a fixed place of business solely for any combination of activities mentioned in subparagraphs a) to e), provided that the overall activity an enterprise of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person other Contracting State - other than an agent of an independent status to whom paragraph 6 5 applies - is acting on behalf of an enterprise and shall be deemed to be a permanent establishment in the first-mentioned State if he has, and habitually exercisesexercises in that State, in a 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 the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 65. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided that where such persons are acting in the ordinary course of their business. 76. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), ) shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, 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 twelve 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 subparagraphs sub-paragraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - – other than an agent of an independent status to whom paragraph 6 applies - – is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name on behalf of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 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 Convention, 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 twelve 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 subparagraphs sub-paragraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - person--other than an agent of an independent status to whom paragraph 6 applies - applies--is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, the term “permanent establishment” means a fixed place of business through which the business of an enterprise is wholly or partly carried on, and whose purpose is to generate profit. 2. The term “permanent establishment” includes especially: a) an office, a main administrative office or place of management; b) a branchbranch or representative office; c) an officea manufacturing facility, factory, a manufacturing or assembly shop, or agricultural operation; 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 e) a building site or construction or installation project constitutes a permanent establishment project, only if it lasts more than twelve six months. 3. A person acting in one State on behalf of an enterprise in the other State shall be deemed to constitute a permanent establishment in the first-mentioned State if that person has, and habitually exercises therein, an authority to conclude contracts in the name of the enterprise, unless the activities of such person are limited to the purchase of goods or merchandise for that enterprise. 4. Notwithstanding the preceding provisions of this Article, the 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; ec) the maintenance of a fixed place of business solely for the purpose of carrying onadvertising, collecting information, scientific research or for the enterprise, any other activity purpose of carrying on similar activities of a preparatory or auxiliary character; f) the maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs a) to e), provided that the overall activity such activities are carried out on behalf of the fixed place of business resulting from this combination is of a preparatory or auxiliary characterenterprise itself. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 76. The fact that a company which is domiciled in a resident of a Contracting State controls or is controlled by a company which is a resident of domiciled in 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 Convention, 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 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 characteractivity; f) the maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs a) to e) provided that such activity or, in the case of subparagraph f), provided that 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, where a person - other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Convention, Convention 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 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 charactercharacter (such as the simple preparation of contracts); (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs sub-paragraphs (a) to (e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - -- other than an agent of an independent status to whom paragraph 6 applies - -- is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that Contracting State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, 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 Convention, 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 mine, an oil or gas welloilwell, a quarry or any other place of extraction of natural resources.; 3. A (g) a farm, plantation or other place where agricultural forestry plantation or related activities are carried on; (h) a building site or construction or installation assembly project constitutes a permanent establishment only if it lasts which exists for more than twelve six months; (i) the provision of supervisory activities for more than six months on a building site or construction or assembly project. 43. Notwithstanding the preceding provisions of this Article, the 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 storage or deliverydisplay; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of for collecting information, 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;character for the enterprise. f) the maintenance 4. A person acting in a Contracting State for or on behalf of a fixed place of business solely for any combination of activities mentioned in subparagraphs a) to e), provided that the overall activity an enterprise of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other Contracting State -- other than an agent of an independent status to whom the provisions of paragraph 6 applies - is acting on behalf of an enterprise and apply -- shall be deemed to be a permanent establishment in the first mentioned State if: (a) he has, and habitually exercisesexercises in that State, in a Contracting State an authority to conclude contracts in the name for or on behalf of the enterprise, unless his activities are limited to the purchase of goods or merchandise for the enterprise; or (b) he maintains in that first mentioned State a stock of goods or merchandise belonging to that enterprise from which he regularly fulfills orders on behalf of that enterprise. 5. An insurance enterprise of a Contracting State shall be deemed to have a permanent perma nent establishment in the other Contracting State if it collects premiums in that other State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised or insures risks therein through an employee or through a fixed place representative who is not an agent of business, would not make this fixed place independent status within the meaning of business a permanent establishment under the provisions of that paragraphparagraph 6. 6. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other 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, where the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise he would 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 company, a permanent establishment of the other.