Common use of PERMANENT ESTABLISHMENT Clause in Contracts

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used for exploration of natural resources. 3. The term “permanent establishment” also encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only if such site, project or activities last more than 9 months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only if activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 days in any 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 activity not listed in subparagraphs (a) to (d), provided that this activity has a preparatory or auxiliary character; or (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 Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig resources including timber or working ship used for exploration of natural resourcesother forest production; (g) a farm or plantation. 3. The term “permanent establishment” also likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only if where such site, project or activities last continue for a period of more than 9 six months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by in the enterprise for other Contracting State, Provided that such purpose, but only if activities of that nature continue (for the same project or a connected project) within the other Contracting State project for a period or periods aggregating more than 183 days in six months within any 12twelve-month period. 4. Notwithstanding the preceding provisions of this Articleparagraphs 1 to 3, the term "“permanent establishment" ” shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise 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 not listed in subparagraphs (a) to (d), provided that this activity has a preparatory or auxiliary character; or (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 the provisions of paragraph 6 applies - apply—is acting in a Contracting State on behalf of an enterprise and hasof the other Contracting State, has and habitually exercises, in a Contracting State exercises an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that the first-mentioned State in respect of any activities which that person undertakes for the enterprise, unless the his activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise, he shall not be considered an agent of an independent status within the meaning of this paragraph. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources; and (g) a warehouse, drilling rig or working ship used in relation to a person providing storage facilities for exploration of natural resourcesothers. 3. The term “permanent establishment” shall also encompassesinclude: (a) a building site, a construction, installation or assembly or installation project or supervisory activities in connection therewith, but only if where such site, project or activities last more than 9 12 months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only if where activities of that nature continue (for the same or a connected project) project within the other Contracting State for a period or periods aggregating more than 183 days in within any 12twelve-month period. 4. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; or; (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 State in respect of any activities which that person undertakes for the enterprise, if such a person: (a) has and habitually exercises in the first-mentioned State, an authority to conclude contracts in the name of the enterprise; unless the his activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph; 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 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 independent status within the meaning of this paragraph. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig resources including timber or working ship used for exploration of natural resourcesother forest produce; (g) a farm or plantation. 3. The term “"permanent establishment” also " likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only if where such site, project or activities last continue for a period of more than 9 six months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by in the enterprise for other Contracting State, provided that such purpose, but only if activities of that nature continue (for the same project or a connected project) within the other Contracting State project for a period or periods aggregating more than 183 days in six months within any 12-twelve- month period. 4. Notwithstanding the preceding provisions of this Articleparagraphs 1 to 3, the term "permanent establishment" shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of 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 not listed in subparagraphs (a) to (d), provided that this activity has a preparatory or auxiliary character; or (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 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 State in respect of any activities which that person undertakes for the enterprise, unless the his activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise, he shall not be considered an agent of an independent status within the meaning of this paragraphs. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used for exploration of natural resources. 3. The term “"permanent establishment” " also encompassesincludes: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only if such site, project or activities last which exists for more than 9 twelve months; (b) the furnishing of services, including consultancy services, by an enterprise a resident of a Contracting State 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 in the other Contracting State for a period or periods aggregating more than 183 days in three months within any 12twelve-month period. 4. An enterprise of a Contracting State shall be deemed to have a permanent establishment in the other Contracting State if (a) it carries on supervisory activities in that other Contracting State for a period or periods aggregating more than six months within any twelve-month period in connection with a construction, installation or assembly project or any combination of them which are being undertaken in that other Contracting State; (b) it carries on a business where the operations or part thereof consists of providing the services of public entertainers of the kind referred to in Article 17 in that other Contracting State. 5. Notwithstanding the preceding provisions of paragraphs 1, 2, 3 and 4 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 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 activity not listed in subparagraphs (a) to (d), provided that this activity has scientific research or similar activities which have a preparatory or auxiliary character; or, for the enterprise. (f) the maintenance 6. 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 2other Contracting State, where a person - other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf of an 7 applies, shall be deemed to be a permanent establishment for the enterprise and in the first- mentioned Contracting State if he has, and habitually exercisesexercises in the first-mentioned Contracting State, in a Contracting State an authority to conclude contracts in the name for or 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 exercise of such person are authority is 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 the provisions of goods or merchandise for that paragraphenterprise. 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 AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an the enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction or of natural resources; (g) a place of exploration of natural resources, drilling rig or working ship used for exploration of natural resources. 3. The term “permanent establishment” also encompasses:; (ah) a building site, a site or construction, installation or assembly or installation project project, or supervisory activities in connection therewith, but only if therewith where such site, project or activities last activity continues for more than 9 six months; (bi) premises used as a sales outlet; (j) a warehouse, in relation to a person providing storage mainly for some other person or persons; (k) A place for the furnishing of services, including consultancy services, services by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only if where activities of that nature continue (for the same or a connected project) within the other Contracting State country for a period or periods aggregating more than 183 days in within any 12-twelve month period. 43. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to 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 not listed in subparagraphs (a) to (d), provided that this activity has a preparatory or auxiliary character; or (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 A person acting in a Contracting State on behalf of an enterprise of the provisions of paragraphs 1 and 2, where a person - other Contracting State (other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf 5 applies) shall be deemed to be a permanent establishment of an that enterprise and has, 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 on behalf of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any unless his activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place the purchase of business, would not make this fixed place of business a permanent establishment under the provisions of goods or merchandise for that paragraphenterprise. 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. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of the enterprise, he shall not be considered as agent of an independent status within the meaning of this paragraph if the transactions between the agent and the enterprise were not made under arms-length conditions. In such a case, the provisions of paragraph 4 shall apply. 76. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" includes especially” shall include specifically: (a) a place of management; (b) a branch; (c) an office; (d) a factoryfactory ; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources; (g) a farm or plantation ; (h) a permanent warehouse, drilling rig or working ship used in relation to a person providing storage facilities for exploration of natural resourcesothers. 3. The term “permanent establishment” also likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only if where such site, project or activities last continue for a period of more than 9 6 months;. (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by in the enterprise for other Contracting State, provided that such purpose, but only if activities of that nature continue (for the same project or a connected project) within the other Contracting State project for a period or periods aggregating more than 183 days in any 12-month period6 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 storage ordisplay of goods or merchandise belonging to the enterpriseenterprise ; (b) the maintenance of a stock of goods or merchandise belonging merchandisebelonging to the enterprise solely for the purpose of storage, storage or display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterpriseenterprise ; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of for collecting information, information for the enterpriseenterprise ; (e) the maintenance of a fixed place of business solely for the purpose thepurpose of carrying onadvertising, for the enterprisesupply of information, any activity not listed in subparagraphs (a) to (d), provided that this activity has for scientific research or for similar activities which have a preparatory or auxiliary character; or (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 applies - is acting in a Contracting State, on behalf of an the enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterpriseother Contracting State, that the enterprise shall be deemed to have a permanent establishment in that State the first-mentioned Contracting State, if such a person : (a) has and habitually exercises in respect the first-mention State, an authority to conclude contracts on behalf of any the a enterprise unless his activities which that person undertakes for the enterprise, unless the activities of such person are limited to those the purchase of goods or merchandise for the enterprise ; (b) has no such authority, but habitually maintains in the first- mentioned State a stock of goods or merchandise belonging to the enterprise from which he regularly fills orders or makes deliveries on behalf of the enterprise ; or (c) has no such authority, but habitually secures orders in paragraph 4 which, if exercised through the first-mentioned State wholly or almost wholly for the enterprise or for the enterprise and other enterprises which are controlled by it or have a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraphcontrolling interest in it. 6. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise or on behalf of that enterprise and other enterprises, which are controlled by it or have a controlling interest in it, he will not be considered an agent of independent status within the meaning of this paragraph. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig ; and (g) a warehouse or working ship other structure used for exploration of natural resourcesas a sales outlet. 3. The term “"permanent establishment” " also encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only if such site, project or activities last more than 9 twelve months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only if activities of that nature continue (for the same or a connected project) within the other a Contracting State for a period or periods aggregating more than 183 days in six months within any 12twelve-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 not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; or; (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 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 AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used for exploration of natural resources. 3. The term “permanent establishment” also encompasses:; (ag) a farm or plantation; (h) a warehouse, in relation to a person providing storage facilities for others; (i) a building site, a construction, installation or assembly or installation project or supervisory activities in connection therewith, but only if where such site, project or activities last continue for a period or periods aggregating more than 9 6 months; (bj) the furnishing of services, services including consultancy services, services by an enterprise a resident of a one of the Contracting State States through employees or other personnel engaged by the enterprise for such purposepersonnel, but only if where activities of that nature continue (for the same or a connected project) project within the other Contracting State for a period or periods aggregating more than 183 days in 6 months within any 12-month twelve·month period. 43. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, storage or display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, 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 onadvertising, for the enterprisesupply of information, any activity not listed in subparagraphs (a) to (d), provided that this activity has for scientific research or for similar activities which have a preparatory or auxiliary character; or, for the enterprise; (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs insub·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 on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name on behalf of the enterpriseenterprise of the other Contracting State, that the enterprise shall be deemed to have a permanent establishment in that the first·mentioned Contracting State if such a person: (a) has and habitually exercises in respect the first·mentioned State an authority to conclude contracts on behalf of any activities which that person undertakes for the enterprise, unless the his activities of such person are limited to those mentioned the purchase of goods or merchandise for the enterprise; (b) has no such authority, but habitually maintains in paragraph 4 whichthe first·mentioned State a stock of goods or merchandise belonging to the enterprise from which he regularly fills orders or makes deliveries on behalf of the enterprise; or (c) has no such authority, if exercised through but habitually secures orders in the first·mentioned State wholly or almost wholly for the enterprise or for the enterprise and other enterprises which are controlled by it or have a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraphcontrolling interest in it. 65. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise or on behalf of that enterprise and other enterprises, which are controlled by it or have a controlling interest in it, he will not be considered an agent of independent status within the meaning of this paragraph. 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 AgreementConvention, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; , and (f) a mine, an oil or gas well, a quarry or any other place of extraction relating to the exploration for or exploration of natural resources, drilling rig or working ship used for exploration the exploitation of natural resources. 3. The term “permanent establishment” shall also encompassesinclude: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewithwith such site or project, but only if such site, project or activities last more than 9 six months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the an enterprise for such purpose, but only if where activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than exceeding in the aggregate 183 days in any 12twelve-month periodperiod commencing or ending in the fiscal year concerned; (c) the performance of professional services or of other activities of an independent character in a Contracting State by an individual, if that individual is present in that Contracting State for a period or periods exceeding in the aggregate 183 days in any twelve-month period commencing or ending in the fiscal year concerned. 4. Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to include: (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 advertising, supplying information or carrying on, out scientific research for the enterprise, any activity not listed in subparagraphs (a) to (d), provided that this activity has a preparatory or auxiliary character; or (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 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. Notwithstanding the preceding provisions of this Article, an insurance enterprise of a Contracting State shall, except in the case of 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 if it insures risks situated therein through a representative other than an agent of 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 the conditions that are made or imposed in their commercial or financial relations with the enterprise do not differ from those which would be generally made 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 Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used for exploration exploitation of natural resources. 3. The term “permanent establishment” also likewise encompasses: (a) a building site, a construction, assembly or installation project or any supervisory activities activity in connection therewithwith such site or project, but only if where such site, project or activities last activity continues for a period of more than 9 six months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the an enterprise for such purpose, but only if where activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than exceeding in the aggregate 183 days in any 12twelve-month periodperiod commencing or ending in the fiscal year concerned; (c) the performance of professional services or other activities of an independent character by an individual, but only where those services or activities continue within a Contracting State for a period or periods exceeding in the aggregate 183 days in any twelve-month period commencing or ending in the fiscal year concerned. 4. Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to include: (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 not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; orand (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 re-insurance, be deemed to have a permanent establishment in the other Contracting State if it collects premiums in the territory of that other State or insures risks situated therein through a person other than an agent of an independent status to whom paragraph 7 applies. 7. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 78. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes 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 or exploration of natural resources; and (g) a warehouse, drilling rig or working ship used in relation to a person providing storage facilities for exploration of natural resourcesothers. 3. The term “permanent establishment” also encompasses: (a) a A building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only if such site, project or activities last more than 9 six months; (b) the The furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only if activities of that nature continue (for the same or a connected project) within the other a Contracting State Party for a period or periods aggregating more than 183 days in six months within any 12-twelve–month period. 4. Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to includeinclude : (a) the use of facilities solely for the purpose of storage, storage or display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display storage or deliverydisplay; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; or; (f) the maintenance of a fixed place of business solely for any combination of the 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 in a Contracting Party, on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterpriseother Contracting Party, that enterprise shall be deemed to have a permanent establishment in that State the first-mentioned Contracting Party in respect of any activities which that person undertakes for the enterprise, if such a person : (a) has and habitually exercises in a Contracting Party an authority to conclude contracts in the name of the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph; (b) has no such authority, but habitually maintains in the first-mentioned Contracting Party a stock of goods or merchandise belonging to the enterprise from which he regularly delivers on behalf of the enterprise ; or (c) has no such authority, but habitually secures orders in the first-mentioned Contracting Party wholly or almost wholly for the enterprise or for the enterprise and other enterprises which are controlled by it or have a controlling interest in it. 6. An enterprise of a Contracting Party shall not be deemed to have a permanent establishment in a the other Contracting State Party merely because it carries on business in that State other Contracting Party through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise, 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 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 Contracting Party (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. (1. ) For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2. ) The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a warehouse; (g) a sales outlet; (h) a mine, an oil or gas well, a quarry or any other place of exploration, extraction or exploration of natural resources, drilling rig or working ship used for exploration exploitation of natural resources. (3. The term “permanent establishment” also encompasses: (a) a A building site, a construction, assembly or installation project or supervisory activities in connection therewith, but therewith constitute a permanent establishment only if such site, project or activities last more than 9 months;six months in any twelve month period commencing or ending in the tax year concerned. (b4) the furnishing of services, including consultancy services, by A permanent establishment shall be deemed to exist where: (a) an enterprise of a Contracting State furnishes services through employees or other personnel engaged by the enterprise for such purpose, but only if the activities of that nature continue (for the same or a connected project) within the other a Contracting State for a period or periods aggregating more than 183 days in any 12-twelve month periodperiod commencing or ending in the tax year concerned; (b) an enterprise through an individual resident in a Contracting State performs services in the other Contracting State and the individual’s stay in that other Contracting State is for a period aggregating more than 183 days in any twelve month period commencing or ending in the tax year concerned. 4. (5) Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; or; (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. (6) Notwithstanding the provisions of paragraphs 1 (1) and (2) of this Article, where a person - other than an agent of an independent status to whom paragraph 6 (8) of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name on behalf of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 (5) of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. (7) Notwithstanding the preceding provisions of this Article, 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 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 (8) of this Article applies. (8) 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. (9) The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factoryfactory ; (e) a workshop; and; (f) premises used as sales outlet; (g) a warehouse, in relation to a person providing storage facilities for others; (h) a farm or plantation or other place where agricultural, pastoral, forestry or plantation activities are carried on; (i) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used for exploration or exploitation of natural resources. 3. The term “permanent establishment” also likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only if where such site, project or activities last continue in one of the Contracting States for a period of more than 9 six months; (b) the furnishing of services, including consultancy services, services by an enterprise of a Contracting State through employees an employee or other personnel engaged by the enterprise for such purpose, but only if where activities of that nature continue (for the same or a connected project) within the other Contracting State country for a period or periods aggregating more than 183 days in six months within any 12-twelve month period. 4. Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to include: (a) the use of the facilities solely for the purpose of storage, storage or display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display storage or deliverydisplay; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, advertising or for the enterprise, any activity not listed in subparagraphs (a) to (d), provided that this activity has a preparatory or auxiliary character; orsupply of information; (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs subparagraph (a) to (e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 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 7 applies) acting in a Contracting State on behalf of an enterprise and hasof the other Contracting State shall be deemed to be a permanent establishment in the first- mentioned State, if: (a) he has and habitually exercises, exercises in a Contracting the first-mentioned State an authority to negotiate and conclude contracts in the name for or on behalf of the enterprise, that unless his activities are limited to the purchase of 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 shall from which he 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 and other enterprises which are controlled by it or have a controlling interest in it. 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 State if it collects premiums in the territory of that other State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised or insures risks situated therein 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 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 such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise or on behalf of that enterprise and other enterprises, which are controlled by it or have a controlling interest in it, he will not be considered an agent of independent status within the meaning of this paragraph. 78. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; , and (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used for exploration exploitation of natural resources. 3. The term “permanent establishment” also likewise encompasses: (a) a building site, a construction, assembly or installation project or any supervisory activities activity in connection therewithwith such site or project, but only if where such site, project or activities last activity continues for a period of more than 9 six months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the an enterprise for such purpose, but only if where activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than exceeding in the aggregate 183 days in any 12twelve-month periodperiod commencing or ending in the fiscal year concerned. 4. Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to include: (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 not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; orand (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 term “permanent establishment” shall include a fixed place of business used as a sales outlet notwithstanding the provisions fact that such fixed place of paragraphs 1 and 2business is otherwise maintained for any of the activities mentioned in paragraph 4 of this Article. 6. A person, where a person - other than an agent of an independent status to whom paragraph 6 applies - is acting 7 of this Article applies, who acts in a Contracting State on behalf of an enterprise and of the other Contracting State shall be deemed to be a permanent establishment of that enterprise 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 or carries on any business activities on behalf of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any unless his activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned specified in paragraph 4 which, if exercised through of this Article; or (b) he habitually secures orders for the sales of goods or merchandise in that State exclusively or almost exclusively on behalf of the enterprise or other enterprises controlled by it or which have a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraphcontrolling interest in it. 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 Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especiallyespecially : (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources; and (g) a warehouse, drilling rig or working ship used in relation to a person providing storage facilities for exploration of natural resourcesothers. 3. The term “permanent establishment” also encompassesencompasses : (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only if such site, project or activities last more than 9 six months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only if activities of that nature continue (for the same or a connected project) within the other a Contracting State Party for a period or periods aggregating more than 183 days in six months within any 12-twelve–month period. 4. Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to includeinclude : (a) the use of facilities solely for the purpose of storage, storage or display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display storage or deliverydisplay; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; or; (f) the maintenance of a fixed place of business solely for any combination of the 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 in a Contracting Party, on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterpriseother Contracting Party, that enterprise shall be deemed to have a permanent establishment in that State the first-mentioned Contracting Party in respect of any activities which that person undertakes for the enterprise, if such a person : (a) has and habitually exercises in a Contracting Party an authority to conclude contracts in the name of the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph; (b) has no such authority, but habitually maintains in the first-mentioned Contracting Party a stock of goods or merchandise belonging to the enterprise from which he regularly delivers on behalf of the enterprise; or (c) has no such authority, but habitually secures orders in the first-mentioned Contracting Party wholly or almost wholly for the enterprise or for the enterprise and other enterprises which are controlled by it or have a controlling interest in it. 6. An enterprise of a Contracting Party shall not be deemed to have a permanent establishment in a the other Contracting State Party merely because it carries on business in that State other Contracting Party through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise, 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 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 Contracting Party (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes 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 or exploration of natural resources, drilling rig or working ship used for exploration of natural resources. 3. The term “permanent establishment” also encompasses: (ag) a building site, a constructionconstruction project, an installation project, an assembly or installation project project, or supervisory activities in connection therewith, but only if therewith where such site, project or activities last or any two or more of them continues or continue for more than 9 6 months;: (bh) a warehouse in relation to a person providing storage facilities for others: (i) the furnishing of services, including consultancy services, by an enterprise a resident of a one of the Contracting State States through employees or other personnel engaged by the enterprise for such purposepersonnel, but only if provided activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 days in within any 12-12 month period; (j) an agricultural, pastoral or forestry property. 43. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" An enterprise shall not be deemed not to includehave a permanent establishment merely by reason of: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of for collecting information, for the enterprise;; or (e) the maintenance of a fixed place of business solely for the purpose of carrying on, activities which have a preparatory or auxiliary character for the enterprise, any activity not listed in subparagraphs (a) to (d), provided that this activity has a preparatory such as advertising or auxiliary character; or (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 characterscientific research. 54. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that An enterprise shall be deemed to have a permanent establishment in one of the Contracting States and to carry on business through that permanent establishment if substantial equipment is being used in that State by, for or under contract with the enterprise. 5. A person acting in respect one of the Contracting States on behalf of an enterprise of the other Contracting State other than a broker, general commission agent or any activities which other agent of an independent status to whom paragraph 6 applies-shall be deemed to be a permanent establishment of that person undertakes for enterprise in the first mentioned State if the person: (a) has, and habitually exercises in that State, an authority to conclude contracts on behalf of the enterprise, unless the person' s activities of such person are limited to those the purchase of goods or merchandise for the enterprise: (b) in so acting, manufactures or processes in that State for the enterprise goods or merchandise belonging to the enterprise: (c) habitually maintains in the first mentioned State a stock of goods or merchandise belonging to the enterprise from which the person regularly fills orders on behalf of the enterprise; or (d) habitually secures orders in paragraph 4 whichthe first mentioned State wholly or almost wholly for the enterprise, if exercised through or for the enterprise and other enterprises which are controlled by it or have a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraphcontrolling interest in it. 6. An enterprise of one of the Contracting States shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided where that such persons are person is acting in the ordinary course of their the person’s business. For this purpose, an agent shall not be considered to be an agent of an independent status if the agent carries on in that other State an activity described in paragraph 5 wholly or almost wholly for the enterprise or for the enterprise and any one or more enterprises which are controlled by it or have a controlling interest in it. 7. The fact that a company which is a resident of a one of the Contracting State States controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), ) shall not of itself constitute make either company a permanent establishment of the other. 8. The principles set forth in paragraphs 1 to 7 inclusive shall be applied in determining for the purposes of paragraph 5 of Article 11 and paragraph 6 of Article 12 whether there is a permanent establishment outside both Contracting States, and whether an enterprise, not being and enterprise of one of the Contracting States, has a permanent establishment in one of the Contracting States.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an the enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources; and (g) an installation structure, drilling rig or working ship equipment used for the exploration of natural resources. 3. The term “"permanent establishment” also " likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only if where such site, project or activities last continue for a period of more than 9 six months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only if where activities of that nature continue (continue, for the same or a connected project) , within the other Contracting State country for a period or periods aggregating more than 183 days in 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, 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 not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; or; (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 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, provided that there is another sale-related activity (such as advertising, promotion or after-sales services) taking place also in the first-mentioned State by the enterprise itself or by any other person. 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 purpose of this AgreementConvention, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especiallybut is not limited to: (a) a A place of management; (b) a A branch; (c) an An office; (d) a A factory; (e) a 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 or exploration of natural resources, drilling rig or working ship used for exploration of natural resources. 3. The term “permanent establishment” also encompassesincludes: (a) a A building site, a construction, assembly or installation project project, or supervisory activities activities, in connection therewith, but only if where such site, project or activities last continue for a period of more than 9 six months; (b) the The furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only if where activities of that nature continue (for the same or a connected project) within the other Contracting State country for a period or periods aggregating more than 183 days in six months within any 12-month period.; 4. Notwithstanding the preceding provisions of this Articlearticle, the term "permanent establishment" shall be deemed not to include: (a) the 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 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 The maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the The maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, information for the enterprise; (e) the The maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; or, such as advertising, supplying of information, scientific research or similar activities; (f) the 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; (g) The sale of goods or merchandise belonging to the enterprise displayed at an occasional temporary fair or exhibition after the closing of the said fair or exhibition. 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 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, 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. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branchbranch ; (c) an officeoffice ; (d) a factoryfactory ; (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 quarry, a vessel or any other place of exploration, extraction or exploration exploitation of natural resources, drilling rig or working ship used for exploration of natural resources. 3. The term “permanent establishment” also encompasses:; and (ai) a building site, a construction, assembly or installation project or any supervisory activities activity in connection therewithwith such site or project, but only if where such site, project or activities last activity continues for a period of more than 9 (6) six months;. (bj) the furnishing of services, including consultancy services, services by an enterprise of a Contracting State through its 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 the other a Contracting State for a period or periods aggregating more than 183 days in six (6) months within any 12-month twelve - months period. 43. Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, storage or display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display storage or deliverydisplay; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; orand (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 - is acting in a Contracting State on behalf of an enterprise and has, and habitually exercises, in a of the other Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that the first mentioned Contracting State in respect of any activities which that person undertakes for the enterprise, if such 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 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; 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. 5. Notwithstanding the proceeding provisions of this Article, an insurance enterprise of a Contracting State 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 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. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an the enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used for exploration of natural resources. 3. The term “permanent establishment” also encompasses:; (ag) a warehouse, in relation to a person providing storage facilities for others; (h) a building site, a construction, installation or assembly or installation project or and supervisory activities in connection therewith, but only if such site, project or activities last continue for a period of more than 9 six months;; and (bi) the furnishing of services, including consultancy services, by an enterprise a resident of a one of the Contracting State States through employees or other personnel engaged by the enterprise that resident for such purpose, but only if where activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 days six months within any twelve month period commencing or ending in any 12-month periodtax period concerned. 43. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, storage or display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display storage or deliverydisplay; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying onadvertising, for the enterprisesupply of information, any activity not listed in subparagraphs (a) to (d), provided that this activity has for scientific research or for similar activities which have a preparatory or auxiliary character, for the enterprise; orand (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 - -- 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 the enterprise shall be deemed to have a permanent establishment in that the first-mentioned State if such person: (a) has and habitually exercises in respect the first-mentioned State, an authority to conclude contracts on behalf of any activities which that person undertakes for the enterprise, unless the his activities of such person are limited to those the purchase of goods or merchandise for the enterprise; (b) as no such authority, but habitually maintains in the first- mentioned State a stock of goods or merchandise belonging to the enterprise from which he regularly fills orders or makes deliveries on behalf of the enterprise; (c) as no such authority, but habitually secures orders in paragraph 4 whichthe first-mentioned State wholly or mainly for the enterprise or for the enterprise and other enterprises which are controlled by it or have a controlling interest in it. 5. Notwithstanding the preceding provisions of this Article, if exercised through an insurance enterprise of a fixed place of businessContracting State shall, would not make this fixed place of business except in regard to reinsurance, be deemed to have a permanent establishment under in the provisions other State if it collects premiums in the territory of that paragraphother State or insures risks situated therein through an employee or through a representative who is not an agent of an independent status within the meaning of paragraph 6 of this Article. 6. An In 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 mainly on behalf of that enterprise or on behalf of that enterprise and other enterprises, which are controlled by it or have a controlling interest in it, he will not be considered an agent of independent status within the meaning of this paragraph. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used for exploration of natural resources. 3. The term “permanent establishment” also encompasses:; (ag) a farm or plantation; (h) a warehouse, in relation to a person providing storage facilities for others; (i) a building site, a construction, installation or assembly or installation project or supervisory activities in connection therewith, but only if where such site, project or activities last continue for a period or periods aggregating more than 9 6 months; (bj) the furnishing of services, services including consultancy services, services by an enterprise a resident of a one of the Contracting State States through employees or other personnel engaged by the enterprise for such purposepersonnel, but only if where activities of that nature continue (for the same or a connected project) project within the other Contracting State for a period or periods aggregating more than 183 days in 6 months within any 12twelve-month period. 43. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, storage or display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display storage or deliverydisplay; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise 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 activity not listed in subparagraphs (a) to (d), provided that this activity has for scientific research or for similar activities which have a preparatory or auxiliary character; or, for the enterprise; (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 applies - is acting in a Contracting State, on behalf of an the enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterpriseother Contracting State, that the enterprise shall be deemed to have a permanent establishment in that State the first-mentioned Contracting State, if such a person: (a) has and habitually exercises in respect the first-mentioned State, an authority to conclude contracts on behalf of any activities which that person undertakes for the enterprise, unless the his activities of such person are limited to those the purchase of goods or merchandise for the enterprise; (b) has no such authority, but habitually maintains in the first- mentioned State a stock of goods or merchandise belonging to the enterprise from which he regularly fills orders or makes deliveries on behalf of the enterprise; or (c) has no such authority, but habitually secures orders in paragraph 4 which, if exercised through the first-mentioned State wholly or almost wholly for the enterprise or for the enterprise and other enterprises which are controlled by it or have a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraphcontrolling interest in it. 65. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise or on behalf of that enterprise and other enterprises, which are controlled by it or have a controlling interest in it, he will not be considered an agent of independent status within the meaning of this paragraph. 76. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used for exploration of natural resources. 3. The term “"permanent establishment” also " likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only if where such site, project or activities last continue for a period of more than 9 months;six months in any twelve-month period commencing or ending in the fiscal year concerned, and (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only if where activities of that nature continue (for the same or a connected project) within the other Contracting State country for a period or periods aggregating more than 183 days six months in any 12twelve-month periodperiod commencing or ending in the fiscal year concerned. 4. A person carrying on activities offshore in a Contracting State in connection with the exploration or exploitation of the seabed and subsoil and their natural resources situated in that Contracting State shall be deemed to be carrying on business through a permanent establishment in that Contracting State. 5. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; or; (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 Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources; (g) the term "permanent establishment" likewise encompasses: (i) a building site or construction, installation or assembly project, supervisory services connected therewith, or an installation used for the exploration of natural resources, drilling rig or working ship used for exploration of natural resources. 3. The term “permanent establishment” also encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only if such site, project or activities last installation lasts, or such services continue, for a period of more than 9 12 months;; or (bii) the furnishing of services, including consultancy services, by an enterprise of a Contracting State resident through employees or other personnel engaged by the enterprise resident for such purposepurposes, but only if where activities of that nature continue (for the same or a connected project) within the other Contracting State country for a period or periods aggregating of more than 183 days in any 12-month period12 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 of 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 not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; or; (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.to

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" establishment means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig ; (g) a farm or working ship used for exploration of natural resourcesforest. 3. The term “permanent establishment” also likewise encompasses: (a) a building site, a construction, assembly or installation project project, or supervisory activities in connection therewith, but only if such site, where that site or project or those activities last continue for a period of more than 9 six months; (b) the furnishing of services, including consultancy services, in a Contracting State by an enterprise of a the other Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only if where those activities of that nature continue (for the same or a connected project) within the other first-mentioned Contracting State for a period or periods aggregating more than 183 days in six months within any 12twelve-month period; and (c) a structure, installation, drilling rig, ship or other equipment used for the exploration for or exploitation of natural resources, or in activities connected with that exploration or exploitation, but only if so used continuously, or those activities continue, for a period of more than three months. 4. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" An enterprise shall not be deemed not to includehave a permanent establishment merely by reason of: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of for collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity not listed in subparagraphs (a) to (d), provided that this activity has a preparatory or auxiliary character; or (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, such as advertising or scientific research. 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 paragraph 6 applies - is acting on behalf (6) applies—shall be deemed to be a permanent establishment of an that enterprise and in the first-mentioned State if: (a) the person 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 to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the person’s activities of such person are limited to those mentioned the purchase of goods or merchandise for the enterprise; or (b) the person manufactures or processes in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under that State for the provisions of that paragraphenterprise goods or merchandise belonging to the enterprise. 6. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other Contracting State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise, it 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 make either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration exploitation of natural resources, drilling rig or working ship used for exploration of natural resources; and (g) a sales outlet. 3. The term “permanent establishment” also likewise encompasses: (a) a building site, a construction, assembly or installation project or any supervisory activities activity in connection therewithwith such site or project, but only if where such site, project or activities last activity continues for a period of more than 9 twelve months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the an enterprise for such purpose, but only if where activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 exceeding in the aggregate 120 days in any 12twelve-month periodperiod commencing or ending in the fiscal year concerned; (c) the performance of professional services or other activities of an independent character by an individual, but only where those services or activities continue within a Contracting State for a period or periods exceeding in the aggregate 120 days in any twelve-month period commencing or ending in the fiscal year concerned. 4. Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to include: (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 not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; orand (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 AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a local place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used for exploration of natural resources. 3. The term “"permanent establishment” also " likewise encompasses: (a) a building site, or a construction, assembly or installation project or supervisory activities in connection therewith, but only if where such site, project or activities last continue for a period of more than 9 six months; (b) the furnishing of services, including consultancy or managerial services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only if where activities of that nature continue (for in the same or a connected project) within territory of the other Contracting State for a period or periods aggregating more than 183 days exceeding in the aggregate six months within any 12-twelve month period. 4. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, storage or display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display storage or deliverydisplay; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; or; (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 AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used for exploration of natural resources. 3. The Likewise the term “permanent establishment” also encompasses: (a) a building site, a construction, assembly or installation project project, or supervisory activities in connection therewith, but only if where such site, project or activities last continue for a period or periods aggregating more than 9 months;nine months within any twelve-month period. (b) the furnishing of services, including consultancy consulting services, by an enterprise of a Contracting State 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 the other a Contracting State for a period or periods aggregating more than 183 days in six months within any 12-month twelve month- period. 4. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; or; (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, and conditions are made or imposed between that enterprise and the agent in their commercial and financial relations which differ from those which would have been made between independent enterprises, he will not be considered an agent of an independent status within the meaning of this paragraph. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this AgreementConvention, the term "“permanent establishment" “ means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" “ includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration explo- ration of natural resources, a drilling rig or a working ship used for exploration of natural resources. 3. The term “permanent establishment” also encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only if such site, project or activities last more than 9 months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise en- terprise for such purpose, but only if activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 days in any 12-month periodperiod commenc- ing or ending in the fiscal year concerned. 4. Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" es- tablishment“ shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise enter- prise solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise enter- prise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing purchas- ing goods or merchandise or of collecting information, for the enterprise; (e) 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 machin- ery or equipment produced by that enterprise; f) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any activity not listed in subparagraphs (a) to (de), provided that this activity has a preparatory or auxiliary character; or (fg) 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 activ- ity of the fixed place of business resulting from this combination is of a preparatory pre- paratory 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 pro- visions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting Contract- ing State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; , and (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used for exploration of natural resources. 3. The term “"permanent establishment” " also encompassesincludes: (a) a building site, a construction, assembly site or construction or installation or assembly project in a Contracting State, or supervisory activities in connection services connected therewith, but only if such site, site or project lasts or activities last such services continue for more than 9 months;12 months in that Contracting State; and (b) an installation or structure used for the exploration of natural resources in a Contracting State, or supervisory services connected therewith, or a drilling rig or ship used for the exploration of natural resources, only if such use lasts or such services continue for more than 12 months in that Contracting State; and (c) the furnishing of servicesservices within a Contracting State, including consultancy services, by an enterprise of a Contracting State resident through employees or other personnel engaged by the enterprise resident for such purposepurpose and present in that Contracting State, but only if where the activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 days in any 12-month period12 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 not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; or; (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 AgreementConvention, the term "permanent establishment" means a fixed place of business through in which the business of an the enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes shall include especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig ; (g) a building site or working ship used construction or assembly or installation project which exists for exploration of natural resourcesmore than six months. 3. The term “permanent establishment” also encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only if such site, project or activities last more than 9 months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only if activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 days in any 12-month period. 4. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall not be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or deliveryprocessing by another enterprise; (c) the maintenance of a stock fixed place of goods or merchandise belonging to the enterprise business solely for the purpose of processing by another purchasing goods or merchandise, or for collecting information, for the enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or advertising, for the supply of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely scientific research or for the purpose of carrying on, for the enterprise, any activity not listed in subparagraphs (a) to (d), provided that this activity has similar activities which have a preparatory or auxiliary character; or, for the enterprise. (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 Contracting State for any combination of activities mentioned more than six months in subparagraphs (a) to (e)connection with a building site, provided construction, 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 Contracting State. 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 paragraph 6 applies - is acting on behalf of an enterprise and -- shall be deemed to be a permanent establishment in the first-mentioned Contracting State if: (a) he has, and habitually exercisesexercises in that first-mentioned Contracting State, in a Contracting State an any authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed unless his activities are limited to have a permanent establishment in that State in respect the purchase of any activities which that person undertakes goods or merchandise for the enterprise, unless ; or (b) he maintains in the activities first-mentioned Contracting 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. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), ) shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used for exploration of natural resources. 3. The term “permanent establishment” also likewise encompasses: (a) a building site, a construction, assembly or installation project or any supervisory activities activity in connection therewithwith such site or project, but only if where such site, project or activities last activity continues for a period of more than 9 six months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the an enterprise for such purpose, but only if where activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 exceeding in the aggregate ninety days in any 12twelve-month periodperiod commencing or ending in the fiscal year concerned; (c) the performance of professional services or other activities of an independent character by an individual, but only where those services or activities continue within a Contracting State for a period or periods exceeding in the aggregate ninety days in any twelve-month period commencing or ending in the fiscal year concerned. 4. Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to include: (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 on, for the enterprise, any other activity not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; or; (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 - person, other than an agent of an independent status to whom paragraph 6 applies - of this Article applies, is acting in a Contracting State on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterpriseother Contracting State, that enterprise shall be deemed to have a permanent establishment in that the first-mentioned Contracting State in respect of any activities which that person undertakes for the enterprise, if such person: (a) has and habitually exercises in that Contracting State an authority to conclude contracts in the name of the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph; or (b) has no such authority, but habitually maintains in the first-mentioned Contracting State a stock of goods or merchandise from which such person delivers goods or merchandise on behalf of the enterprise. 6. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other Contracting State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other Contracting State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is of a Contracting State, wholly or partly carried onpartly, carries on business in the other Contracting State. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; , and (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used for exploration of natural resources. 3. The term “"permanent establishment” also " likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only if where such site, project or activities last continue for a period of more than 9 monthsnine months in any twelve month period; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only if where activities of that nature continue (for the same or a connected project) within the other Contracting State country for a period or periods aggregating more than 183 days nine months in any 12-twelve month period. 4. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; or; (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 -other than an agent of an independent status to whom paragraph 6 applies - applies- is acting in a Contracting State on behalf of an enterprise 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. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise, he shall not be considered to be an agent of an independent status within the meaning of this paragraph. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) premises used as domestic sales outlet; (g) a warehouse, in relation to a person providing storage facilities for others; (h) a farm or plantation or other place where agricultural, pastoral, forestry or plantation activities are carried on; (i) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used for exploration or exploitation of natural resources. 3. The term “"permanent establishment” also " likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only if where such site, project or activities last continue in one of the Contracting States for a period of more than 9 months183 days; (b) the furnishing of services, including consultancy services, services by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only if where activities of that nature continue (for the same or a connected project) within the other Contracting State country for a period or periods aggregating more than 183 120 days in within any 12twelve-month period. 4. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: (a) the use of the facilities solely for the purpose of storage, storage or display of goods or delivery merchandise belonging to the enterprise; the used of facilities solely for the purpose of storage or display of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display storage or deliverydisplay; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying onadvertising, or for the enterprise, any activity not listed in subparagraphs (a) to (d), provided that this activity has a preparatory or auxiliary character; orsupply of information; (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 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; (b) has no such authority, but habitually maintains in the first- mentioned State a stock of goods or merchandise from which he regularly fills domestic orders on behalf of the enterprise; or (c) manufactures or processes in that State for the enterprise goods or merchandise belonging to the enterprise. 6. An insurance enterprise of a Contracting State shall, except with regard to reinsurance, be deemed to have a permanent establishment in the other Contracting State if it collects premiums in that other State or insures risks situated therein through an employee or through a representative who is not an agent of an independent status within the meaning of paragraph 7. 7. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or in no less than 60% of the activities on behalf of that enterprise or its associated enterprises, he will not be considered an agent of an independent status within the meaning of this paragraph. 78. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“ permanent establishment" ’ includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of exploration extraction or exploration exploitation of natural resources, resources or any activities related thereof including an offshore drilling rig or working ship used for exploration of natural resourcessite. 3. The term “permanent establishment” also encompasses: (a) a A building site, a construction, assembly assemble or installation project or supervisory activities in connection therewith, but therewith or drilling rig or ship used for the exploring or exploiting of natural resources constitute a permanent establishment only if such site, project or activities last continue for a period of more than 9 six (6) months;. (b) the 4. The furnishing of services, including consultancy or managerial services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but in the other Contracting State constitutes a permanent establishment only if activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 days in any 12-month periodsix (6) 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, enterprise any other activity not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; or; (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 - person- other than an agent of an independent status to whom paragraph 6 9 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 the first-mentioned Contracting State, an authority to conclude contracts in the name of such enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 6 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph; (b) has no such authority, but habitually maintains in the first-mentioned Contracting State a stock of goods or merchandise belonging to such enterprise from which he or she regularly delivers goods or merchandise on behalf of such enterprise; (c) habitually secures orders in the first-mentioned Contracting State, exclusively or almost exclusively for the enterprise itself or for such enterprise and other enterprises, which are controlled by it or have a controlling interest in it. 6(d) in so acting, he manufactures or processes in that Contracting State for the enterprise goods or merchandise belonging to the enterprise. 7. Notwithstanding the preceding provisions of this Article, an insurance enterprise of a Contracting State shall, except in regard to re-insurance, be deemed to have a 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 8 applies. 8. 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 and other enterprises, which are controlled by it or have a controlling interest in it, he shall not be considered an agent of an independent status within the meaning of this paragraph. 79. Notwithstanding the provision of paragraph 8 of this Article, insurance companies that are owned or controlled by a Contracting State or its Local Governments or local authorities shall be treated differently for tax purposes and may be taxed in the state of residence. 10. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other Contracting State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is of a Contracting State wholly or partly carried oncarries on business in the other Contracting State. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of exploration for, exploitation or extraction or exploration of natural resourcesof, drilling rig or working ship used for exploration of natural resources. 3. The term “"permanent establishment” also " likewise encompasses: (a) a building site, a construction, assembly or installation project or any supervisory activities activity in connection therewithwith such site or project, but only if where such site, project or activities last activity continues for a period of more than 9 twelve months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only if where activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 days in six months within any 12twelve-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 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, for scientific research or for any other activity not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; orand (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 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 where such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or mainly 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 Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an the enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources; and (g) an installation structure, drilling rig or working ship equipment used for the exploration of natural resources. 3. The term “permanent establishment” also likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only if where such site, project or activities last continue for a period of more than 9 six months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only if where activities of that nature continue (continue, for the same or a connected project) , within the other Contracting State country for a period or periods aggregating more than 183 days in 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, 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 not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; or; (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 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, provided that there is another sale-related activity (such as advertising, promotion or after-sales services) taking place also in the first-mentioned State by the enterprise itself or by any other person. 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 Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a warehouse or premises used as safes outlet; (g) a farm or plantation; (h) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used for exploration or exploitation of natural resources. 3. The term “permanent establishment” also encompasses: (a) a A building site, site or a construction, assembly or installation project or a supervisory activities activity in connection therewith, but therewith constitutes a permanent establishment only if such site, project or activities last activity continues for a period of more than 9 three months;. (b) the 4. The furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other engaged personnel engaged by the enterprise for such purpose, but only if activities of that nature continue (for the same or a connected project) within in the other Contracting State constitutes a permanent establishment provided that such activities continue for the same project or a connected project for a period or periods aggregating more than 183 days in three months within any 12twelve-month period. 45. An enterprise of a Contracting State shall be deemed to have a permanent establishment in the other Contracting State if substantial equipment in that other Contracting State is being used or installed by, for or under contract with the enterprise. 6. 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 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 for the purpose of collecting advertising or the collection or supply of 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 not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; or; (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. 57. Notwithstanding the provisions of paragraphs 1 and 22 above, where a person - -- other than an agent of an independent status to whom which paragraph 6 8 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 State the first-mentioned Contracting State, in respect of any activities which that person undertakes for the enterprise, unless if: (a) he has and habitually exercises in the activities first-mentioned Contracting State a general authority to negotiate and conclude contracts in the name of such person enterprise; or (b) he has no such authority, but habitually maintains in the first-mentioned Contracting State a stock of goods or merchandise belonging to such enterprise from which he regularly delivers goods or merchandise on behalf of such enterprise; or (c) he habitually secures orders in the first-mentioned Contracting State, exclusively or almost exclusively for the enterprise itself or for such enterprise and other enterprises which are limited controlled by it or have a controlling interest in it; or (d) in so acting, he manufactures in that Contracting State for the enterprise goods or merchandise belonging to those mentioned in paragraph 4 whichthe enterprise. 8. An insurance enterprise of a Contracting State shall, if exercised through a fixed place of businessexcept with regard to reinsurance, would not make this fixed place of business be deemed to have a permanent establishment under in the provisions other Contracting State if it collects premiums in that other Contracting State or insures risks situated therein through an employee or through a representative who is not an agent of that paragraphan independent status within the meaning of paragraph 9. 69. 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. 710. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other Contracting State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through in which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" includes especially” shall include specifically: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship ships used for exploration and exploitation of natural resources; (g) a farm or plantation. 3. The term “permanent establishment” also likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only if where such site, project or activities last continue for a period of more than 9 six months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by in the enterprise for other Contracting State, provided that such purpose, but only if activities of that nature continue (for the same project or a connected project) within the other Contracting State project for a period or periods aggregating more than 183 days in any 12-month periodsix 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 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 on, for the enterprise, enterprise any other activity not listed in subparagraphs (a) to (d), provided that this activity has a preparatory or auxiliary character; or (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; (f) the sale of goods or merchandise belonging to the enterprise displayed in the frame of an occasional temporary fare or exhibition after the closing of the said or exhibition; provided that involving parties or companies fulfill all requirements in either Contracting States. 5. Notwithstanding the provisions of paragraphs 1 and 2, where 2 a person - acting in a Contracting State on behalf of an enterprise of the other Contracting State other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf of an enterprise and 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 be a permanent establishment in the first-mentioned State if: (a) he has in the first-mentioned State a general authority to negotiate and conclude contracts for or on behalf of such enterprise, or (b) he maintains in the first-mentioned State a stock of goods merchandise from which he regularly sells goods or merchandise for or on behalf of such enterprises. 6. A broker, a commission agent or other agent of genuinely independent status who merely acts as an intermediary between an enterprise of one of the Contracting States and a prospective customer in the other Contracting State, shall not be deemed to be 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 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, and provided that such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise, he will not be considered an agent of an independent status within the meaning of this paragraph. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, State or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of in itself constitute either a company or a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especiallyshall include: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a warehouse, in relation to a person providing storage facilities for others; (g) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig ; and (h) an installation or working ship structure used for the exploration of natural resources. 3. The term “"permanent establishment” also " likewise encompasses: (a) a building site, a site or construction, installation or assembly or installation project project, or supervisory activities in connection therewith, but therewith only if such the site, project or activities last activity lasts more than 9 12 months;. (b) the furnishing of services, services including consultancy services, services by an enterprise of a Contracting State through employees or other personnel engaged by in the enterprise for other Contracting State, provided that such purpose, but only if activities of that nature continue (for the same or a connected project) within the other Contracting State project for a period or periods aggregating to more than 183 days in 9 months within any 12-12 month period. 4. Notwithstanding the preceding provisions of this Article, the term "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 activity not listed in subparagraphs (a) to (d), provided that this activity has for scientific research or for similar activities which have a preparatory or auxiliary charactercharacter of the enterprise; orand (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs (a) to (eto(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 - acting in a Contracting State on behalf of an enterprise of the other Contracting State (other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf of an enterprise and this Article applies) notwithstanding that he has no fixed place of business in the first-mentioned State shall be deemed to be a permanent establishment in that State if he has, and habitually exercises, a general authority in a Contracting the first- mentioned State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed unless his activities are limited to have a permanent establishment in that State in respect the purchase of any activities which that person undertakes goods or merchandise for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "”permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used for exploration of natural resourcesand g) a place where a server is located. 3. The term “”permanent establishment” also likewise encompasses: (a) a building site, site or a construction, assembly or installation project or supervisory activities in connection therewith, but only if where such site, project or activities last continue for a period of more than 9 twelve months; (b) the furnishing of services, including consultancy or managerial services, by an enterprise of a Contracting State or through employees or other personnel engaged by the enterprise for such purpose, but only if where activities of that nature continue (for in the same or a connected project) within territory of the other Contracting State for a period or periods aggregating more than 183 days exceeding in the aggregate six months within any 12-twelve month period. 4. Notwithstanding the preceding provisions of this Article, the term "”permanent establishment" ” shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, storage or display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display storage or deliverydisplay; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any activity not listed in subparagraphs (a) to (d), provided that this activity has a preparatory or auxiliary character; orother activity; (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 such activity or, in the case of sub-paragraph f), the overall activity of the fixed place of business resulting from this combination business, is of a preparatory or auxiliary character. 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is of first a Contracting State wholly or partly carried oncarries on business in the other Contracting State. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; , and (f) a mine, an oil or gas well, a quarry or any other place of exploration, exploitation or extraction or exploration of natural resources, drilling rig or working ship used for exploration of natural resources. 3. The term “"permanent establishment” " also encompassesincludes: (a) a building site, or a construction, installation or assembly or installation project or supervisory activities in connection therewith, but therewith constitutes a permanent establishment only if such site, project or activities last it lasts more than 9 twelve months;. (b) the furnishing of services, services in connection with subparagraph a) of paragraph 3 including consultancy services, by an enterprise of a Contracting State through employees emploees or other personnel engaged by the enterprise for such purpose, but only if where activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 days in six months within any 12twelve-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 not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; or; (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 the 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 in the territory of that other State or insures risks situated therein through a person other than agent of an independent status. 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. 78. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, Agreement the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "" permanent establishmentestablishment " includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; (f) a warehouse; (g) a permanent sales exhibition; and (fh) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources. FBR, drilling rig or working ship used for exploration Government of natural resources.Pakistan 3. The term “"permanent establishment” also encompasses: (a) " likewise encompasses a building site, a construction, assembly or installation project or any supervisory activities activity in connection therewith, but only if where such site, project or activities last more than 9 months; (b) the furnishing activity exists for period of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only if activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 days in any 12-month perioddays. 4. Notwithstanding the preceding proceeding provisions of this Article, the term "permanent establishment" shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, storage or display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display storage or deliverydisplay; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying onadvertising, for the enterprisesupply of information, any activity not listed in subparagraphs (a) to (d), provided that this activity has for scientific research or for similar activities which have a preparatory or auxiliary character; or (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. 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 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.; (b) has no such authority but habitually maintains in the first- mentioned State a stock of goods or merchandise from which he regularly delivers goods or merchandise on behalf of the enterprise; or (c) habitually secures orders in the first-mentioned State exclusively or almost exclusively for the enterprise itself or for such other enterprises which are controlled by it or have a controlling interest in it. FBR, Government of Pakistan 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 than 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 net be considered an agent of an independent status within the meaning of this paragraph. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) a sales outlet; d) an office; (de) a factory; (ef) a workshop; and. (fg) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig h). a building site or working ship used for exploration of natural resourcestemporary installation operation lasting longer than six months. 3. The term “permanent establishment” also encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only if such site, project or activities last more than 9 months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only if activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 days in any 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 merchandise, collecting information, information for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of performing advertising, providing information, scientific research, or of carrying on, for the enterprise, any other activity not listed in subparagraphs (a) to (d), provided that this activity has a preparatory or auxiliary character; or (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 A person who is 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 referred to whom in paragraph 6 applies 5 hereinafter - is acting on behalf of an enterprise and has, shall be deemed a "permanent establishment" in the first-mentioned State if he has and habitually exercises, exercises in a Contracting that State an the authority to conclude contracts in the name 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 the purchase of business, would not make this fixed place of business a permanent establishment under goods or merchandise for the provisions of that paragraphenterprise. 65. An enterprise shall not be deemed to have a "permanent establishment 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 intermediary of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig including an installation or working ship structure used for the exploration or exploitation of natural resources; and (g) a warehouse, in relation to a person providing s torage facilities for others. 3. The term “permanent establishment” also encompasses: (a) a A building site, a construction, installation or assembly or installation project or any supervisory activities activity in connection therewith, but with such site or project constitutes a permanent establishment only if such site, project or activities last it lasts more than 9 six months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only if activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 days in any 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 merchandise, or of for collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose p urpose of carrying on, for the enterprise, any other activity not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; orand (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 Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of exploration, extraction or exploration exploitation of natural resources, resources or any activities related thereof including an offshore drilling rig or working ship used for exploration of natural resourcessite. 3. The term “permanent establishment” also encompasses: (a) a A building site, a construction, assembly or installation project or supervisory activities in connection therewith, but therewith or a drilling rig or ship used for the exploring or exploiting of natural resources constitute a permanent establishment only if such site, project project, activity or activities last usage continues in the territory of a Contracting State for more than 9 twelve months;. (b) the 4. The furnishing of services, including consultancy or managerial services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but constitutes a permanent establishment only if activities of that nature continue (for the same or a connected project) within in the other Contracting State for a period or periods aggregating more than 183 days in any 12-month periodtwelve 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 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 activity not listed in subparagraphs (a) to (d), provided that this activity has a preparatory or auxiliary character; or (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 Agreement, the term "" permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; , and (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used for exploration of natural resources. 3. The term “permanent establishment” also encompasses: (a) a A building site, a construction, assembly site or construction or installation project or supervisory activities in connection therewith, but constitutes a permanent establishment only if such site, project or activities last it lasts more than 9 twelve months;. (b) the furnishing of services, including consultancy services, by an enterprise of 4. A person carrying on activities offshore in a Contracting State in connection with the exploration or exploitation of the sea bed and subsoil and their natural resources situated in that State shall be deemed to be carrying on a business through employees or other personnel engaged by the enterprise for such purpose, but only if activities of a permanent establishment in that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 days in any 12-month periodState. 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 not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; or; (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 Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on.on.‌ 2. The term "“permanent establishment" ” includes especiallyespecially :‌ (a) a place of management;management;‌ (b) a branch;branch;‌ (c) an office;office;‌ (d) a factory;factory;‌ (e) a workshop; andworkshop;‌ (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources; and‌ (g) a warehouse, drilling rig or working ship used in relation to a person providing storage facilities for exploration of natural resources.others.‌ 3. The term “permanent establishment” also encompasses:encompasses:‌ (a) a A building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only if such site, project or activities last more than 9 months;six months;‌ (b) the The furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only if activities of that nature continue (for the same or a connected project) within the other a Contracting State Party for a period or periods aggregating more than 183 days in six months within any 12-twelve–month period.period.‌ 4. Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to includeinclude :‌ (a) the use of facilities solely for the purpose of storage, storage or display or delivery of goods or merchandise belonging to the enterprise;enterprise;‌ (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display storage or delivery;display;‌ (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise;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;enterprise;‌ (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; orcharacter;‌ (f) the maintenance of a fixed place of business solely for any combination of the 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.character.‌ 5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - – other than an agent of an independent status to whom paragraph 6 applies - – is acting in a Contracting Party, on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterpriseother Contracting Party, that enterprise shall be deemed to have a permanent establishment in that State the first-mentioned Contracting Party in respect of any activities which that person undertakes for the enterprise, if such a person :‌ (a) has and habitually exercises in a Contracting Party an authority to conclude contracts in the name of the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph.paragraph;‌ (b) has no such authority, but habitually maintains in the first-mentioned Contracting Party a stock of goods or merchandise belonging to the enterprise from which he regularly delivers on behalf of the enterprise ; or‌ (c) has no such authority, but habitually secures orders in the first-mentioned Contracting Party wholly or almost wholly for the enterprise or for the enterprise and other enterprises which are controlled by it or have a controlling interest in it.‌ 6. An enterprise of a Contracting Party shall not be deemed to have a permanent establishment in a the other Contracting State Party merely because it carries on business in that State other Contracting Party through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business.. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise, 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 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 Contracting Party (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.other.‌

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "‘permanent establishment" ’ means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used for exploration exploitation of natural resources. 3. The term “permanent establishment” also encompassesshall be deemed to include : (a) a building site, a construction, assembly or installation project or any supervisory activities activity in connection therewithwith such site or project, but only if where such site, project or activities last activity continues for a period of more than 9 months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the an enterprise for such purpose, but only if where activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods exceeding in the aggregate days in any twelve-month period commencing or ending in the fiscal year concerned; (c) for an individual, the performing of services in a Contracting State by that individual, but only if the individual’s stay in that State, for the purpose of performing those services, is for a period or periods aggregating more than 183 days within any twelve month period commencing or ending in any 12-month periodthe fiscal year concerned. (d) an installation or structure used in the exploration for natural resources provided that the installation or structure continues for a period of not less than days. 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 enterpriseenterprise ; (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 activity not listed in subparagraphs (a) to (d), provided that this activity has a preparatory or auxiliary character; orother activity; (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), the overall activity of the fixed place of business resulting from this combination business, is of a preparatory or auxiliary character. 4.1 Paragraph 4 shall not apply to a fixed place of business that is used or maintained by an enterprise if the same enterprise or a closely related enterprise carries on business activities at the same place or at another place in the same Contracting State and (a) that place or other place constitutes a permanent establishment for the enterprise or the closely related enterprise under the provisions of this Article, or (b) the overall activity resulting from the combination of the activities carried on by the two enterprises at the same place, or by the same enterprise or closely related enterprises at the two places, is not of a preparatory or auxiliary character, provided that the business activities carried on by the two enterprises at the same place, or by the same enterprise or closely related enterprises at the two places, constitute complementary functions that are part of a cohesive business operation 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 Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used for exploration exploitation of natural resources. 3. The term “"permanent establishment” also " likewise encompasses: (a) a building site, a construction, assembly or installation project or any supervisory activities activity in connection therewithwith such site or project, but only if where such site, project or activities last activity continues for a period of more than 9 six months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the an enterprise for such purpose, but only if where activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than exceeding in the aggregate 183 days in any 12twelve-month periodperiod commencing or ending in the fiscal year concerned; (c) the performance of professional services or other activities of an independent character by an individual, but only where those services or activities continue within a Contracting State for a period or periods exceeding in the aggregate 183 days in ·any twelve-month period commencing or ending in the fiscal year concerned. 4. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: (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 not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; or (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.and

PERMANENT ESTABLISHMENT. 1. For the purposes of this AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig ; and g) a building site or working ship used for exploration of natural resourcesconstruction or installation project if it lasts more than twelve months. 3. The term “permanent establishment” also encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only if such site, project or activities last more than 9 months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only if activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 days in any 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, publicity, supplying information, scientific research or any other similar activity not listed in subparagraphs (a) to (d), provided that this activity has a preparatory or auxiliary character; or (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 A person acting in a Contracting State on behalf of an enterprise of the provisions of paragraphs 1 and 2, where a person other Contracting State - other than an agent of an independent status to whom paragraph 6 5 applies - is acting on behalf of an enterprise and shall be deemed to have a "permanent establishment" in the first-mentioned State if he has, and habitually exercises, in a that Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such that person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place the purchasing of business, would not make this fixed place of business a permanent establishment under goods or merchandise for the provisions of that paragraphenterprise. 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 Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship ; and (g) premises used for exploration of natural resourcesas sales outlet. 3. The term “permanent establishment” also encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only if such site, project or activities last lasts more than 9 12 months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only if activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 270 days in 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 not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; or; (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 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 Contracting State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that Contracting State through a broker, a general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other Contracting State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an the enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources; (g) an installation structure, drilling rig or working ship equipment used for the exploration of offshore natural resources. 3. The term “permanent establishment” also likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only if where such site, project or activities last continue for a period of more than 9 six months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only if where activities of that nature continue (for the same or a connected project) within the other Contracting State country for a period or periods aggregating more than 183 days in six months within any 12-12- month period. 4. Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, storage or display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display storage or deliverydisplay; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, 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 not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; or; (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 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. 78. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; f) premises used as sales outlet; and (fg) a mine, an oil or gas well, a quarry or any other place of exploration, extraction or exploration of natural resources, drilling rig or working ship used for exploration and exploitation of natural resources. 3. The term “permanent establishment” also encompasses: (a) a A building site, a construction, assembly or installation project or any supervisory activities activity in connection therewithwith such site or project, but only if where such site, project or activities last activity continues for a period of more than 9 months(9) nine months in any twelve months period; (b) the The furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only if activities of that nature continue (for the same or within a connected project) within the other Contracting State for a period or periods aggregating more than 183 days in (6) six months within any 12twelve-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 not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; or; (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs (a) to (e)) above, 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 except in regard to reinsurance, shall be deemed to have a permanent establishment in the other Contracting State if it collects premiums on the territory of that other Contracting State or insures risks situated therein through a person, other than an agent of an independent status to whom paragraph 7 applies. 7. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise, and conditions are made or imposed between that enterprise and the agent in their commercial and financial relations which differ from those which would have been made between independent enterprises, he will not be considered an agent of an independent status within the meaning of this paragraph. 78. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a 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 officeoffice ; (d) a factoryfactory ; (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 exploration exploitation of natural resources, drilling rig or working ship used for exploration of natural resources. 3. The term “permanent establishment” also encompasses:; and (ai) a building site, a construction, assembly or installation project or any supervisory activities activity in connection therewithwith such site or project, but only if where such site, project or activities last activity continues for a period of more than 9 (6) six months;. (bj) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through its employees or other personnel engaged by the enterprise for such purpose, but only if provided that such activities of that nature continue (for the same project or a connected project) within the other Contracting State project for a period or periods aggregating more than 183 days in (6) six months within any 12twelve-month period. 43. Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, storage or display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display storage or deliverydisplay; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; orand (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 - is acting on behalf of an enterprise and has, and habitually exercises, exercise. in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which3 which , if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 5. Notwithstanding the proceeding provisions of this Article, an insurance company 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 an agent are devoted wholly or almost wholly on behalf of that enterprise, he will be considered as a permanent establishment or a fixed base.‌ 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), . shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used for exploration of natural resources. 3. The term “"permanent establishment” " also encompassesincludes: (a) a building site, a site or construction, assembly or installation project or supervisory activities in connection therewith, and also a drilling rig or ship used for the exploration of natural resources, but only if where such site, project or activities last continue for a period of more than 9 twelve months; (b) the furnishing of services, including consultancy or managerial services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only if where activities of that nature continue (for the same or a connected project) within in the territory of the other Contracting State for a period or periods aggregating of more than 183 days in any 12-month periodtwelve 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 onadvertising, for the enterprisesupply of information, any activity not listed in subparagraphs (a) to (d), provided that this activity has for scientific research or for similar activities which have a preparatory or auxiliary character; or, for the enterprise; (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 AgreementConvention, the term "permanent establishment" means a fixed place of business through in which the business of an the enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes shall include especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources; g) a building site or construction or installation or assembly project, drilling rig or working ship used which exists for exploration of natural resourcesmore than six months. 3. The term “permanent establishment” also encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only if such site, project or activities last more than 9 months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only if activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 days in any 12-month period. 4. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall not be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying onadvertising, for the enterprisesupply of information, any activity not listed in subparagraphs (a) to (d), provided that this activity has for scientific research or for similar activities which have a preparatory or auxiliary character; or, 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 AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; , and (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used for exploration of natural resources. 3. The term “permanent establishment” also encompasses: (a) a A building site, a construction, assembly site or construction or installation or assembly project in a Contracting State, or supervisory activities in connection services connected therewith, but constitute a permanent establishment in that Contracting State only if such site, project or activities they last more than 9 12 months; (b) an installation or structure used for the exploration on natural resources in a Contracting State, or supervisory services connected therewith, or a drilling rig or ship used for the exploration of natural resources in a Contracting State constitute a permanent establishment in that Contracting State only if such use or services last more than 12 months; (c) the furnishing of servicesservices within a Contracting State, including consultancy services, by an enterprise a resident of a the other Contracting State through employees or other personnel present within the first-mentioned State and engaged by the enterprise that resident for such purpose, but purpose constitutes a permanent establishment in that Contracting State only if activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating such services last more than 183 days in any 12-month period12 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 sale, after an exhibition or a fair, of goods or merchandise displayed belonging to the enterprise; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (cd) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (de) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of collecting informationinformation or disseminating information or of marketing of a preparatory or auxiliary character, for the enterprise; (ef) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; or; (fg) the maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs sub-paragraphs (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. 1. Income derived by a resident of a Contracting State from immovable property (including income from agriculture or forestry) situated in the other Contracting State may be taxed in that other State. 2. The term "immovable property" shall have the meaning which it has under the law of the Contracting State in which the property in question is situated. The term shall in any case include property accessory to immovable property, livestock and equipment used in agriculture and forestry, rights to which the provisions of general law respecting landed property apply, usufruct of immovable property and rights to variable or fixed payments as consideration for the working of, or the right to work, mineral deposits, sources and other natural resources; ships, boats and aircraft shall not be regarded as immovable property. 3. The provisions of paragraph 1 shall apply to income derived from the direct use, letting, or use in any other form of immovable property. 4. The provisions of paragraphs 1 and 3 shall also apply to the income from immovable property of an enterprise and to income from immovable property used for the performance of independent personal services.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "«permanent establishment" » means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "«permanent establishment" » includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources; and g) an installation or structure used for the exploration of natural resources, or supervisory services connected therewith, or drilling rig or working ship used for the exploration of natural resources. 3. The term “«permanent establishment” » also encompassesincludes: (a) a building site, a site or construction, assembly or installation project or any supervisory activities activity in connection therewith, but only if with such site, site or project or activities last for a period of more than 9 6 months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purposepurpose or through a related party, but only if where activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 days in 6 months within any 12twelve-month period. For the purpose of this subparagraph, where an enterprise of a Contracting State that is performing services in the other Contracting State is, during period of time, associated with another enterprise that performs substantially similar services in that other Contracting State for the same project or for connected projects through one or more individuals who are present and performing such services in that other Contracting State, the first-mentioned enterprise shall be deemed to be performing services in the other Contracting State for that same project or for connected projects through individuals of another enterprise. For the purpose of the preceding sentence, an enterprise shall be associated with another enterprise if one is controlled directly or indirectly by another enterprise or both such enterprises are controlled directly or indirectly by the same persons, regardless of whether or not these persons are residents of one of the Contracting States. 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, on for the enterprise, any other activity not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; or; (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 Contracting State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that Contracting State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 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. 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 collect 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 6 of this Article applies. 8. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other Contracting State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used for exploration of natural resources. 3. The term “permanent establishment” establishment also encompasses:encompasses any place relating to the exploration of natural resources, provided such activities exists for a period or periods aggregating more than six months within any twelve-month period. (a) a 4. A building site, a construction, assembly assembly, or installation project or supervisory activities in connection therewith, but constitutes a permanent establishment only if such site, site or project or activities last continues for a period of more than 9 nine months;. (b) the furnishing of services, including consultancy services, 5. Consultancy services provided by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purposepurpose in the other Contracting State, but constitutes a permanent establishment only if activities of that nature continue (continue, for the same or a connected project) within the other Contracting State , for a period or periods aggregating more than 183 days in six months within any 12twelve-month period. 46. 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 not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; or; (f) the maintenance of a fixed place of business solely for any combination of activities 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. 57. 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 - 8 applies- is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name 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 6 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 68. An enterprise 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 conditions are made or imposed between that enterprise and the agent in their commercial or financial relations which differ from those which would have been made between independent persons, he will not be considered an agent of an independent status within the meaning of this paragraph. 79. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other Contracting State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branchbranch ; (c) an officeoffice ; (d) a factoryfactory ; (e) a workshop; and; (f) a warehouse or 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 extraction extraction, exploitation or exploration of natural resources, drilling rig or working ship used for exploration of natural resources. 3. The term “permanent establishment” also encompasses:; (ai) a building site, a construction, assembly or installation project or any supervisory activities activity in connection therewithwith such site or project, but only if where such site, project or activities last activity continues for a period of more than 9 months183 days; (bj) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only if where activities of that nature continue (for the same or a connected project) within the other Contracting State country for a period or periods aggregating more than 183 days in within any 12-twelve month period. 43. Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, storage or display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display storage or deliverydisplay; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; orand (f) the 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 - 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. 5. Notwithstanding the preceding provisions of this Article, an insurance enterprise of a Contracting State 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 6 applies. 6. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent statusStatus, 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 principally on behalf of that enterprise, he shall not be considered an agent of an independent status within the meaning of this paragraph, if it is shown that the transactions between the agent and the enterprise were not made under 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 Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branchbranch ; (c) an officeoffice ; (d) a factoryfactory ; (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 extraction or exploration exploitation of natural resources, drilling rig or working ship used for exploration of natural resources. 3. The term “permanent establishment” also encompasses:; (ai) a building site, a construction, assembly or installation project or any equipment or supervisory activities in connection therewith, but only if where such site, project or activities last continue for a period of more than 9 months;90 days within any twelve month period; and (bj) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only if where activities of that nature continue (for the same or a connected project) within the other Contracting State country for a period or periods aggregating more than 183 90 days in within any 12-twelve month periodperiod . 43. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, storage or display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display storage or deliverydisplay; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purposes of advertising or for the supply of information; (f) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; orand (fg) 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. 54. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 applies - is acting in a Contracting State on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterpriseother Contracting State, that enterprise shall be deemed to have a permanent establishment in that the first-mentioned Contracting State in respect of any activities which that person undertakes for the enterprise, if such a person: (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 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; or (b) has no such authority, but habitually maintains in the first - mentioned State a stock of goods or merchandise from which he regularly delivers goods or merchandise on behalf of the enterprise; or (c) habitually secures orders in the first - mentioned State for the enterprise and other enterprises which are controlled by it or have a controlling interest in it. 5. Notwithstanding the preceeding 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 6 applies. 6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or principally on behalf of that enterprise, he shall not be considered an agent of an independent status within the meaning of this paragraph, if it is shown that the transactions between the agent and the enterprise were not made under arms' length conditions. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) an installation, structure or vessel or any other place used for the exploration of natural resources, but only if the exploration activities last more than 30 days within any period of twelve months; g) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used for exploration of natural resources. 3. The term “permanent establishment” shall also encompassesbe deemed to include: (a) a building site, a construction, assembly site or construction or installation project or supervisory activities in connection therewithproject, but only if such site, site or project or activities last continue for more than 9 twelve months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through its employees or other personnel engaged by the enterprise for such purpose, but only if activities of that nature continue (for the same or a connected project) within the other a Contracting State for a period or periods aggregating more than 183 days in of six months within any 12-month months period. 4. Notwithstanding the preceding provisions of this Articlearticle, the term "permanent establishment" shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to 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 not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; or; (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 I and 2, where a person - other than an agent of an independent status to whom paragraph 6 7 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. Notwithstanding the preceding provisions of this Article, an insurance enterprise of a Contracting State shall, except in regard to re-insurance, be deemed to have a permanent establishment in the other Contracting State if it collects premiums in the territory of that other State or insures risks situated therein through a person other than an agent of an independent status to whom paragraph 7 applies. 7. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 78. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used for exploration of natural resources. 3. The term “permanent establishment” also encompassesincludes: (a) a building site, a construction, assembly or installation project or a supervisory activities in connection or consultancy activity connected therewith, but only if such site, project or activities last activity lasts in a Contracting State for a period of more than 9 twelve months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only if where activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 days in 9 months within any 12twelve-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 not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; or; (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 AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise a resident of a Contracting State is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction relating to the exploration for or exploration of natural resources, drilling rig or working ship used for exploration the exploitation of natural resources. 3. The term “"permanent establishment” " also encompassesincludes: (a) a building site, a construction, assembly site or construction or installation project or assembly project, or supervisory activities in connection services connected therewith, only if such site or project lasts for more than 12 months, or such services continue for more than 12 months; and (b) an installation or structure used for the exploration of natural resources, or supervisory services connected therewith, or a drilling rig or ship used for the exploration of natural resources, but only if such site, project or activities last use lasts for more than 9 3 months;, or such services continue for more than 12 months; and (bc) the furnishing of services, including consultancy services, by an enterprise of a Contracting State resident through employees or other personnel engaged by the enterprise resident for such purpose, but only if where the activities of that nature continue (for the same or a connected project) within the other Contracting State country for a period or periods aggregating more than 183 days in any 12-month period12 months. 4. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" in respect of a resident of a Contracting State 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 enterpriseresident; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise resident solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise resident solely for the purpose of processing by another enterpriseperson; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterpriseresident; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterpriseresident, any other activity not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; or; (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 a resident of a Contracting State and has, and habitually exercises, in a the other Contracting State an authority to conclude contracts in the name of the enterpriseresident, that enterprise resident shall be deemed to have a permanent establishment in that other State in respect of any activities which that person undertakes for the enterpriseresident, 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 A resident of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; , and (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used for exploration of natural resources. 3. The Likewise the term “permanent establishment” also encompasses: (a) a building site, a construction, assembly or installation project project, or supervisory activities in connection therewith, but only if where such site, project or activities last continue for a period or periods aggregating more than 9 monthsnine months within any twelve-month period; (b) the furnishing of services, including consultancy consulting services, by an enterprise of a Contracting State 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 the other whitin a Contracting State for a period or periods aggregating more than 183 days in six months within any 12twelve-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 not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; or; (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, and conditions are made or imposed between that enterprise and the agent in their commercial and financial relations which differ from those which would have been made between independent enterprises, he will not be considered an agent of an independent status within the meaning of this paragraph. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through in which the business of an enterprise is wholly or partly partially carried onout. 2. The term "“permanent establishment" includes especially:” shall include specifically: -- (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig ; (g) a farm or working ship used for exploration of natural resourcesplantation. 3. The term “permanent establishment” also likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only if where such site, project or activities last continue for a period of more than 9 months;nine months within any twelvemonth period. (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by in the enterprise for other Contracting State, provided that such purpose, but only if activities of that nature continue (for the same project or a connected project) within the other Contracting State project for a period or periods aggregating more than 183 days in nine months within any 12-month twelvemonth period. 4. Notwithstanding the preceding provisions of this Articleparagraphs 1 to 3, the term "“permanent establishment" ” shall be deemed not to include:: -- (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance maintainance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c) the maintenance maintainance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance maintainance 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 maintainance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity not listed in subparagraphs (a) to (d), provided that this activity has a preparatory or auxiliary character; or (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. (f) The sale of goods or merchandise belonging to the enterprise displayed in the frame of an occasional temporary fare or exhibition after the closing of the said or exhibition; provided that involving parties or companies fulfill all requirements in either Contracting States. 5. Notwithstanding the provisions provision of paragraphs paragraph 1 and 2, where 2 a person - acting in a Contracting State on behalf of an enterprise of the other Contracting State -- other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf of an enterprise and 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 be a permanent establishment in the first-mentioned State if: a) he has in the first-mentioned State a general authority to negotiate and conclude contracts for or on behalf of such enterprise, or b) he maintains in the first-mentioned State a stock of goods or merchandise from which he regularly sells goods or merchandise for or on behalf of such enterprises, or c) he secures orders in the first-mentioned State, exclusively or almost exclusively for the enterprise itself or for such enterprise and other enterprises which are controlled by it, or have a controlling interest in it. 6. A broker, a commission agent or other agent of genuinely independent status who merely acts as an intermediary between an enterprise of one of the Contracting States and a prospective customer in the other Contracting State shall not be deemed to be a permanent establishment in that other Contracting State in respect the case where such activities do not involve securing of any activities which that person undertakes for orders within the enterprise, unless the activities meaning 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, 5 above and provided that such persons are acting in the ordinary course of their business. 7. 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. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, State or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this AgreementConvention, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used for exploration exploitation of natural resources. 3. The term “permanent establishment” also encompassesshall be deemed to include: (a) a building site, a construction, assembly or installation project or any supervisory activities activity in connection therewith, but only if with such site, project or activities last activity, but only where such site, project or activity continues for a period of more than 9 months183 days; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the an enterprise for such purpose, but only if where activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods exceeding in the aggregate 183 days in any twelve-month period commencing or ending in the fiscal year concerned; (c) for an individual, the performing of services in a Contracting State by that individual, but only if the individual’s stay in that State, for the purpose of performing those services, is for a period or periods aggregating more than 183 days in within any 12twelve-month periodperiod commencing or ending in the fiscal year concerned; (d) an installation or structure used for the exploration for natural resources provided that the installation or structure continues for a period of not less than 183 days. 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 not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; orand (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 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, the agent will not be considered an agent of an independent status within the meaning of this paragraph. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes shall include especially: : (a) a place of management; : (b) a branch; : (c) an office; : (d) a factory; : (e) a workshop; and : (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used for exploration of natural resources. 3. The term “permanent establishment” also encompasses: : (ag) a building site, a constructionconstruction project, an installation project, an assembly or installation project project, or supervisory activities in connection therewith, but only if therewith where such site, project or activities last or any two or more of them continues or continue for more than 9 6 months; : (bh) a warehouse in relation to a person providing storage facilities for others: (i) the furnishing of services, including consultancy services, by an enterprise a resident of a one of the Contracting State States through employees or other personnel engaged by the enterprise for such purposepersonnel, but only if provided activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 days in within any 12-12 month period; (j) an agricultural, pastoral or forestry property. 43. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" An enterprise shall not be deemed not to include: have a permanent establishment merely by reason of: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; ; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; ; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; ; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of for collecting information, for the enterprise; ; or (e) the maintenance of a fixed place of business solely for the purpose of carrying on, activities which have a preparatory or auxiliary character for the enterprise, any activity not listed in subparagraphs (a) to (d), provided that this activity has a preparatory such as advertising or auxiliary character; or (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 characterscientific research. 54. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that An enterprise shall be deemed to have a permanent establishment in one of the Contracting States and to carry on business through that permanent establishment if substantial equipment is being used in that State by, for or under contract with the enterprise. 5. A person acting in respect one of the Contracting States on behalf of an enterprise of the other Contracting State other than a broker, general commission agent or any activities which other agent of an independent status to whom paragraph 6 applies-shall be deemed to be a permanent establishment of that person undertakes for enterprise in the first mentioned State if the person: (a) has, and habitually exercises in that State, an authority to conclude contracts on behalf of the enterprise, unless the person' s activities of such person are limited to those the purchase of goods or merchandise for the enterprise: (b) in so acting, manufactures or processes in that State for the enterprise goods or merchandise belonging to the enterprise: (c) habitually maintains in the first mentioned State a stock of goods or merchandise belonging to the enterprise from which the person regularly fills orders on behalf of the enterprise; or (d) habitually secures orders in paragraph 4 whichthe first mentioned State wholly or almost wholly for the enterprise, if exercised through or for the enterprise and other enterprises which are controlled by it or have a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraphcontrolling interest in it. 6. An enterprise of one of the Contracting States shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided where that such persons are person is acting in the ordinary course of their the person’s business. For this purpose, an agent shall not be considered to be an agent of an independent status if the agent carries on in that other State an activity described in paragraph 5 wholly or almost wholly for the enterprise or for the enterprise and any one or more enterprises which are controlled by it or have a controlling interest in it. 7. The fact that a company which is a resident of a one of the Contracting State States controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), ) shall not of itself constitute make either company a permanent establishment of the other. 8. The principles set forth in paragraphs 1 to 7 inclusive shall be applied in determining for the purposes of paragraph 5 of Article 11 and paragraph 6 of Article 12 whether there is a permanent establishment outside both Contracting States, and whether an enterprise, not being and enterprise of one of the Contracting States, has a permanent establishment in one of the Contracting States.

PERMANENT ESTABLISHMENT. (1. ) For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. (2. ) The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a warehouse; (g) a sales outlet; (h) a mine, an oil or gas well, a quarry or any other place of exploration, extraction or exploration of natural resources, drilling rig or working ship used for exploration exploitation of natural resources. (3. The term “permanent establishment” also encompasses: (a) a A building site, a construction, assembly or installation project or supervisory activities in connection therewith, but therewith constitute a permanent establishment only if such site, project or activities last more than 9 months;six months in any twelve month period commencing or ending in the tax year concerned. (b4) the furnishing of services, including consultancy services, by A permanent establishment shall be deemed to exist where: (a) an enterprise of a Contracting State furnishes services through employees or other personnel engaged by the enterprise for such purpose, but only if the activities of that nature continue (for the same or a connected project) within the other a Contracting State for a period or periods aggregating more than 183 days in any 12-twelve month periodperiod commencing or ending in the tax year concerned; (b) an enterprise through an individual resident in a Contracting State performs services in the other Contracting State and the individual's stay in that other Contracting State is for a period aggregating more than 183 days in any twelve month period commencing or ending in the tax year concerned. 4. (5) Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise merchandise, or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; or; (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. (6) Notwithstanding the provisions of paragraphs 1 (1) and (2) of this Article, where a person - other than an agent of an independent status to whom paragraph 6 (8) of this Article applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name on behalf of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 (5) of this Article which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. (7) Notwithstanding the preceding provisions of this Article, 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 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 (8) of this Article applies. (8) 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. (9) The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a warehouse or 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 extraction extraction, exploitation or exploration of natural resources, drilling rig or working ship used for exploration of natural resources. 3. The term “permanent establishment” also encompasses:; (ai) a building site, a construction, assembly or installation project or any supervisory activities activity in connection therewithwith such site or project, but only if where such site, project or activities last activity continues for a period of more than 9 months183 days; (bj) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only if where activities of that nature continue (for the same or a connected project) within the other Contracting State country for a period or periods aggregating more than 183 days in within any 12-twelve month period. 43. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, storage or display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display storage or deliverydisplay; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; orand (f) the 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.. Agreement Beween the Government of the State of Qatar and the Government of Nepal For the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income 5 54. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that 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, 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 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 statusStatus, 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 principally on behalf of that enterprise, he shall not be considered an agent of an independent status within the meaning of this paragraph, if it is shown that the transactions between the agent and the enterprise were not made under 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 AgreementConvention, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; , and (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used for exploration exploitation of natural resources. 3. The term “permanent establishment” also likewise encompasses: (a) a building site, a construction, assembly or installation project or any supervisory activities activity in connection therewithwith such site or project, but only if where such site, project or activities last activity continues for a period of more than 9 six months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the an enterprise for such purpose, but only if where activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than exceeding in the aggregate 183 days in any 12twelve-month periodperiod commencing or ending in the fiscal year concerned; (c) the performance of professional services or other activities of an independent character by an individual, but only where those services or activities continue within a Contracting State for a period or periods exceeding in the aggregate 183 days in any twelve-month period commencing or ending in the fiscal year concerned. 4. Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to include: (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 not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; orand (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 AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is of a State wholly or partly carried oncarries on business in a 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 [a] quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used for exploration of natural resources. 3. The term “permanent establishment” also encompasses:; (ag) a farm or plantation; (h) a warehouse, in relation to a person providing storage facilities for others; (i) a building site, a construction, installation or assembly or installation project or supervisory activities in connection therewith, but only if where such site, project or activities last continue for a period of more than 9 6 months; (bj) the furnishing of services, services including consultancy services, services by an enterprise a resident of a one of the Contracting State States through employees or other personnel engaged by the enterprise for such purposepersonnel, but only if where activities of that nature continue (for the same or a connected project) project within the other Contracting State for a period or periods aggregating more than 183 days in 3 months within any 12twelve-month period. 43. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, storage or display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display storage or deliverydisplay; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise 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 activity not listed in subparagraphs (a) to (d), provided that this activity has for scientific research or for similar activities which have a preparatory or auxiliary character; or (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 person - -- other than an agent of an independent status to whom paragraph 6 applies - -- is acting in a Contracting State, on behalf of an the enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterpriseother Contracting State, that the enterprise shall be deemed to have a permanent establishment in that State the first-mentioned Contracting State, if such a person: (a) has and habitually exercises in respect the first-mentioned Contracting State, an authority to conclude contracts on behalf of any activities which that person undertakes for the enterprise, unless the his activities of such person are limited to those the purchase of goods or merchandise for the enterprise; (b) has no such authority, but habitually maintains in the first-mentioned State a stock of goods or merchandise belonging to the enterprise from which he regularly fills orders or makes deliveries on behalf of the enterprise; or (c) has no such authority, but habitually secures orders in paragraph 4 whichthe first-mentioned State wholly or almost wholly for the enterprise or for the enterprise and other enterprises which are controlled by it. 5. Notwithstanding the preceding provisions of this Article, if exercised through an insurance enterprise of a fixed place of businessContracting State shall, would not make this fixed place of business except in regard to reinsurance, be deemed to have a permanent establishment under in the provisions other State if it collects premiums in the territory of that paragraphother State or insures risks situated therein through an employee or through a representative who is not an agent of an independent status within the meaning of paragraph 6. 6. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise or on behalf of that enterprise and other enterprises, which are controlled by it, he will not be considered an agent of independent status within the meaning of this paragraph. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an the enterprise is wholly or partly carried on. 2. The term "“permanent establishment" includes especially” shall include: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a warehouse, in relation to a person providing storage facilities for others; (g) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig ; and (h) an installation or working ship structure used for the exploration of natural resources. 3. The term “permanent establishment” also encompasses: (a) a A building site, site or a construction, installation or assembly or installation project project, or supervisory activities in connection therewith, but constitutes a permanent establishment only if such the site, project or activities last activity lasts more than 9 nine months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only if activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 days in any 12-month period. 4. Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to include: (a) the The use of facilities solely for the purpose 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 activity not listed in subparagraphs (a) to (d), provided that this activity has for scientific research or for similar activities which have a preparatory or auxiliary character, for the enterprise; orand (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 - acting in a Contracting State on behalf of an enterprise of the other Contracting State (other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf of an enterprise and this Article applies) notwithstanding that he has no fixed place of business in the first-mentioned State shall be deemed to be a permanent establishment in that State if: (a) he has, and habitually exercises, a general authority in a Contracting the first-mentioned State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed unless his activities are limited to have a permanent establishment in that State in respect the purchase of any activities which that person undertakes goods or merchandise for the enterprise, unless ; or (b) he maintains in the activities first-mentioned State a stock of such person are limited goods or merchandise belonging to those mentioned in paragraph 4 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 shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "" permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig . (g) a farm or working ship a plantation; (h) premises and warehouses used for exploration of natural resourcesas sales outlets. 3. The term “permanent establishment” also likewise encompasses: (a) a A building site, a construction, site or construction or assembly project or installation project or supervisory activities in connection therewith, but only if such site, project or activities last continues for a period of more than 9 8 months; within 12-month period; (b) the The furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purposepersonnel, but only if where activities of that nature continue (for the same or a connected project) within the other Contracting State country for a period or periods aggregating more than 183 days in 8 months within any 12-month period. 4. Notwithstanding the preceding provisions of this Article, Article the term "permanent establishment" shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; or; (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs (a) to (e), b) 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 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 the person has an habitually exercises, in that State an authority to conclude contracts in the name of the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 6. Notwithstanding the preceding provisions of this Article, an insurance enterprise of a Contracting State shall-except in regard to 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 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 AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; , and (f) a mine, an oil or gas well, a quarry or any other place of extraction or relating to the exploration of natural resources, drilling rig or working ship used for exploration and the exploitation of natural resources. 3. The term “"permanent establishment” also " likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only if where such site, project or activities last continue for a period or periods aggregating more than 9 monthssix months within any twelve month period; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only if where such activities of that nature continue (continue, for the same or a and connected project) , within the other Contracting State country for a period or periods aggregating more than 183 days in six months within any 12-twelve month period. 4. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, storage or display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display storage or deliverydisplay; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; or; (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 - 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 activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise, he will not be considered an agent of an independent status within the meaning of this paragraph. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a farm or plantation; (g) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used for exploration of natural resources. 3. The term “"permanent establishment” also " likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only if where such site, site or project or activities last continue in one of the countries of the Contracting Parties for a period of more than 9 6 months; (b) the furnishing of services, including consultancy services, services by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only if where activities of that nature continue (for the same or a connected project) within the other Contracting State country for a period or periods aggregating more than 183 120 days in within any 12-twelve month period. 4. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: (a) the use of the facilities solely for the purpose of storage, storage or display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display storage or deliverydisplay; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of advertising or for the supply of information-, (f) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; or; (fg) the maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs sub-paragraphs (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 the country of a Contracting Party on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprisecountry of the other Contracting Party, that enterprise shall be deemed to have a permanent establishment in that State the first-mentioned country in respect of any activities which that person undertakes for the enterprise, if such a person: (a) has and habitually exercises in that country 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 country a stock of goods or merchandise from which he regularly delivers goods or merchandise on behalf of the enterprise. 6. An enterprise of the country of a Contracting Party shall not be deemed to have a permanent establishment in a the country of the other Contracting State Party merely because it carries on business in that State other country through a broker, 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 the country of a Contracting State Party controls or is controlled by a company which is a resident of the country of the other Contracting StateParty, or which carries on business in that other State country (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration exploitation of natural resources, drilling rig ; and g) an installation or working ship structure used for the exploration of natural resources. 3. The term “permanent establishment” also encompasses: (a) encompasses a building site, a construction, assembly or installation project or any supervisory activities or consultancy activity in connection therewithwith such site or project, but only if where such site, project or activities last activity lasts for a period of more than 9 six months;. (b) 4. Notwithstanding the furnishing provisions of servicesparagraphs 1, including consultancy services2 and 3, by where an enterprise of a Contracting State 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 performs services in the other Contracting State a) through an individual who is present in that other State for during a period or periods aggregating more than exceeding in the aggregate 183 days in any 12-twelve month period, and more than 50 per cent of the gross revenues attributable to active business activities of the enterprise during this period or periods are derived from services in that other State through an individual, or b) during a period or periods exceeding in the aggregate 183 days in any twelve month period, and these services are performed for the same project or connected projects through one or more individuals who are performing services in that State or are present in that State for the purpose of performing such services, these services shall be deemed to be performed through a permanent establishment that the enterprise has in that other State, unless these activities are limited to those mentioned in paragraph 5 which, if performed through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 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, storage or display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (c) the maintenance of stock of goods or merchandise belonging to the enterprise solely for the purpose of storage or display; 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 not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; orand (f) the maintenance of a fixed place of business solely for any combination of activities mentioned men tioned 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 es tablishment under the provisions of that paragraph. 67. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 78. 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 State of insures risks situated therein through an employee or through a person other than an agent of an independent status to whom paragraph 7 applies. 9. The fact that a company accompany which is a resident of a Contracting State 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 of otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an the enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management;: (b) a branch;: (c) an office; (d) a factory;: (e) a workshop; and: (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources: and (g) an installation structure, drilling rig or working ship equipment used for the exploration of natural resources. 3. The term “"permanent establishment” also " likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only if where such site, project or activities last continue for a period of more than 9 six months;: (b) the furnishing of services, including consultancy constancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only if where activities of that nature continue (for the same or a connected project) within the other Contracting State country for a period or periods aggregating more than 183 days in 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, 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 not listed in subparagraphs (a) to (d), provided that this activity has a preparatory or auxiliary character; or (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 per-son: (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 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. 78. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; f) premises used as sales outlet; and (fg) a mine, an oil or gas well, a quarry or any other place of exploration, extraction or exploration of natural resources, drilling rig or working ship used for exploration and exploitation of natural resources. 3. The term “permanent establishment” also encompasses: (a) a A building site, a construction, assembly or installation project or any supervisory activities activity in connection therewithwith such site or project, but only if where such site, project or activities last activity continues for a period of more than 9 months(9) nine months in any twelve months period; (b) the The furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only if activities of that nature continue (for the same or within a connected project) within the other Contracting State for a period or periods aggregating more than 183 days in (6) six months within any 12twelve-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 not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; or; (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs (a) to (e)) above, 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 - 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 except in regard to reinsurance, shall be deemed to have a permanent establishment in the other Contracting State if it collects premiums on the territory of that other Contracting State or insures risks situated therein through a person, other than an agent of an independent status to whom paragraph 7 applies. 7. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise, and conditions are made or imposed between that enterprise and the agent in their commercial and financial relations which differ from those which would have been made between independent enterprises, he will not be considered an agent of an independent status within the meaning of this paragraph. 78. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a 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; (g) a permanent sales exhibition; and (fh) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used for exploration of natural resources. 3. The term “"permanent establishment” also encompasses: (a) " likewise encompasses a building site, a construction, assembly or installation project or any supervisory activities activity in connection therewith, but only if where such site, project or activities last more than 9 months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only if activities of that nature continue (for the same or a connected project) within the other Contracting State activity exists for a period or periods aggregating of more than 183 days in any 12-month perioddays. 4. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, storage or display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display storage or deliverydisplay; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying onadvertising, for the enterprisesupply of information, any activity not listed in subparagraphs (a) to (d), provided that this activity has for scientific research or for similar activities which have a preparatory or auxiliary character; or (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. 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 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; (b) has no such authority but habitually maintains in the first- mentioned State a stock of goods or merchandise from which he regularly delivers goods or merchandise on behalf of the enterprise; or (c) habitually secures orders in the first-mentioned State exclusively or almost exclusively for the enterprise itself or for such other enterprises which are controlled by it or have a controlling interest in it. 6. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise, he will not be considered an agent of an independent status within the meaning of this paragraph. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; (f) a warehouse, in relation to a person providing storage facilities for others; and (fg) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used for exploration of natural resources. 3. The term “permanent establishment” also likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only if where such site, project or activities last continue for a period of more than 9 6 months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other engaged personnel engaged by in the enterprise for other Contracting State, provided that such purpose, but only if activities of that nature continue (for the same project or a connected project) within the other Contracting State project for a period or periods aggregating more than 183 days in 6 months within any 12-month 12 months' period. 4. Notwithstanding the preceding provisions of this Articleparagraphs 1 to 3, the term "“permanent establishment" ” shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; or; (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 the provisions of paragraph 6 applies - is 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 of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that other Contracting State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise, he will not be considered an agent of an independent status within the meaning of this paragraph. 7. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a A place of management; (b) a A branch; (c) an An office; (d) a A factory; (e) a A workshop; and; (f) a A mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used for exploration of natural resources. 3. The term “permanent establishment” also encompassesshall be deemed to include: (a) a A building site, a construction, assembly or installation project or supervisory super- visory activities in connection therewith, but only if such site, project or activities last more than 9 months183 days in any 12-month period commencing or ending in the fiscal year concerned; (b) the furnishing The rendering of services, including consultancy services, by an enterprise of a one Contracting State 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) con- tinue within the other Contracting State for a period or periods aggregating more than 183 days in any 12-month periodperiod commencing or ending in the fiscal year concerned; c) In the case of an enterprise carried on by an individual resident of one Contracting State, the performing of services in the other Contracting State by that individual, but only if that individual is present in that State for a period or periods aggregating more than 183 days in any 12-month period commencing or ending in the fiscal year concerned; d) An installation or structure used in the research or exploration for natural resources located in a Contracting State provided that the installation or structure continues for a period of not less than 90 days. 4. Notwithstanding the preceding provisions of this Article, the term "„permanent establishment" “ shall be deemed not to include: (a) the The use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the The maintenance of a stock of goods or merchandise belonging to the enterprise en- terprise solely for the purpose of storage, display or delivery; (c) the The maintenance of a stock of goods or merchandise belonging to the enterprise en- terprise solely for the purpose of processing by another enterprise; (d) the The maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the en- terprise; e) An installation or assembly project carried on by an enterprise of a Con- tracting State in the other Contracting State in connection with the deliv- ery of machinery or equipment produced by that enterprise; (ef) the The maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any activity not listed in subparagraphs (a) to (de), provided that this activity has a preparatory or auxiliary character; or (fg) the 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 ac- tivities 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 Con- tracting 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 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 AgreementConvention, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; f) sales outlet; g) a warehouse in relation to a person providing storage facilities for others; and (fh) a mine, a pit, an oil or gas well, a quarry quarry, an installation, a structure (including a drilling rig or ship) or any other place of exploration, exploitation or extraction or exploration of natural resources, drilling rig or working ship used for exploration of natural resourcesas well as supervisory services connected therewith. 3. The term “permanent establishment” also encompassesincludes: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only if such site, project or activities last that lasts for a period of more than 9 twelve months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State resident through employees or other personnel engaged by the enterprise resident for such purposepurpose or through associated enterprises, but only if where activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 days in within any 12twelve-month period. For the purposes of this paragraph: a) where an enterprise of a Contracting State carrying on activities in the other Contracting State is associated with another enterprise carrying on substantially similar activities there, the former enterprise shall be deemed to be carrying on all such activities of the latter enterprise, except to the extent that those activities are carried on at the same time as its own activities; b) an enterprise shall be regarded as associated with another enterprise if one participates directly or indirectly in the management, control or capital of the other or if the same persons participate directly or indirectly in the management, control or capital of both enterprises. 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 activity not listed in subparagraphs (a) to (d), provided that this activity has a preparatory or auxiliary character; orother activity; (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 referred to in subparagraphs a)-e) or, in the case of subparagraph f), the overall activity of the fixed place of business resulting from this combination business, is of a preparatory or auxiliary character. 4.1 Paragraph 4 shall not apply to a fixed place of business that is used or maintained by an enterprise if the same enterprise or a closely related enterprise carries on business activities at the same place or at another place in the same Contracting State and a) that place or other place constitutes a permanent establishment for the enterprise or the closely related enterprise under the provisions of this Article, or b) the overall activity resulting from the combination of the activities carried on by the two enterprises at the same place, or by the same enterprise or closely related enterprises at the two places, is not of a preparatory or auxiliary character, provided that the business activities carried on by the two enterprises at the same place, or by the same enterprise or closely related enterprises at the two places, constitute complementary functions that are part of a cohesive business operation. 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 hasand, in doing so, habitually concludes contracts, or habitually plays the principal role leading to the conclusion of contracts that are routinely concluded without material modification by the enterprise, and habitually exercises, in a Contracting State an authority to conclude these contracts are a) in the name of the enterprise, 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 AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; , and (f) a mine, an oil or gas well, a quarry or any other place of extraction relating to the exploration for or exploration of natural resources, drilling rig or working ship used for exploration the exploitation of natural resources. 3. The term “"permanent establishment” " shall also encompassesinclude: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewithwith such site or project, but only if such site, project or activities last more than 9 six months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the an enterprise for such purpose, but only if where activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than exceeding in the aggregate 183 days in any 12twelve-month periodperiod commencing or ending in the fiscal year concerned; (c) the performance of professional services or of other activities of an independent character in a Contracting State by an individual, if that individual is present in that Contracting State for a period or periods exceeding in the aggregate 183 days in-any twelve-month period commencing or ending in the fiscal year concerned. 4. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall xxxXx 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 advertising, supplying information or carrying on, out scientific research for the enterprise, any activity not listed in subparagraphs (a) to (d), provided that this activity has a preparatory or auxiliary character; or (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 on behalf of the enterprise, that enterprise shall xxxXx 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 the case of 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 if it insures risks situated therein through a representative other than an agent of 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 the conditions that are made or imposed in their commercial or financial relations with the enterprise do not differ from those which would be generally made 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 AgreementConvention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig ; (g) a building site or working ship used for exploration of natural resourcesinstallation project lasting more than 12 months. 3. The term “A "permanent establishment” also encompasses" is deemed to exist when: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only if such site, project or activities last more than 9 months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only if activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 days in any 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 are used 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 is maintained solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise is maintained solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business is maintained 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 is maintained solely for the purpose of carrying onadvertising, the supply of information, scientific research or any other similar activity of an auxiliary or preparatory character for the enterprise, any activity not listed in subparagraphs (a) to (d), provided that this activity has a preparatory or auxiliary character; or (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 Where a person - other than an agent of an independent status to whom paragraph 6 5 applies - is acting on behalf of an enterprise of a Contracting State and has, and habitually exercisesexercises in the other Contracting State, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterpriselast-mentioned State, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place the purchasing of business, would not make this fixed place of business a permanent establishment under goods or merchandise for the provisions of that paragraphenterprise. 65. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in a the other Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent intermediary of an independent status, provided that such persons are acting in the ordinary course of their businessactivities. 76. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an 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 store or other sales outlet; e. a factory; (e) f. a workshop; g. a warehouse in relation to a person providing storage facilities for others; h. a permanent sales exhibition; and (f) i. a mine, a quarry, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used for exploration of natural resources.; 3. The term “permanent establishment” also encompasses: (a) j. a building site, a site or construction, installation or assembly or installation project or supervisory activities in connection therewith, but only if where such site, project or activities last supervisory activity continues for a period of more than 9 six months; (b) k. an installation or structure used for the exploration or development of natural resources for more than 90 days; and l. the furnishing of servicesservices other than included services as defined in Article 12, including consultancy services, within a Contracting State by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purposepersonnel, but only if if: i. activities of that nature continue (for the same or a connected project) within the other Contracting that State for a period or periods aggregating more than 183 90 days in within any 12twelve month period; or ii. the services are performed within that State for a related enterprise (within the meaning of paragraph 1 of Article 9) for a period or periods aggregating more than 30 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) a. the use of facilities solely for the purpose of storage, storage or display or delivery of goods or merchandise belonging to the enterprise; (b) b. the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display storage or deliverydisplay; (c) c. the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) d. the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of for collecting information, for the enterprise; (e) e. the maintenance of a fixed place of business solely for the purpose of carrying onadvertising, for the enterprisesupply of information or for scientific research, any activity not listed in subparagraphs (a) to (d), provided that this activity has a preparatory or auxiliary character; or (f) the maintenance of a fixed place of business being activities 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 charactercharacter in the trade or business of the enterprise. 54. Notwithstanding A person acting in a Contracting State for or on behalf of an enterprise of the provisions of paragraphs 1 and 2, where a person - other Contracting State-other than an agent of an independent status to whom paragraph 6 applies - is acting on behalf 5 applies-shall be deemed to be a permanent establishment of an that enterprise and has, in the first-mentioned State if: i. he has and habitually exercisesexercises in that State, in a Contracting State an authority to conclude negotiate and enter into contracts in the name for or on behalf of the enterprise, that enterprise shall be deemed unless his activities are limited to have the purchase of goods or merchandise for the enterprise; or ii. he habitually maintains in the first-mentioned Contracting State a permanent establishment stock of goods or merchandise from which he regularly delivers goods or merchandise for or on behalf of the enterprise; or iii. in so acting, he manufactures or processes in that State in respect of any activities which that person undertakes for the enterprise goods or merchandise belonging to the enterprise, unless provided that this provision shall apply only in relation to 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 paragraphgoods or merchandise so manufactured or processed. 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. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise or for the enterprise and other enterprises which are controlled by it or have a controlling interest in it, he would not be considered an agent of an independent status within the meaning of this paragraph. 76. The fact that a company company, which is a resident of a Contracting State controls or is controlled by a company 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 not, of itself itself, constitute for either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig ; (g) a sales outlet; (h) a farm or working ship used for exploration of natural resourcesplantation. 3. The term “"permanent establishment” " also encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only if such site, project or activities last lasts more than 9 six months; (b) the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose, but only if activities of that nature continue (for for, the same or a connected project) within the other a Contracting State for a period or periods aggregating more than 183 days in 6 months within any 12twelve-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, 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 not listed in subparagraphs (a) to (d), provided that this activity has of a preparatory or auxiliary character; or; (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 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 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. 78. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

PERMANENT ESTABLISHMENT. 1. For the purposes of this Agreement, the term "“permanent establishment" ” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "“permanent establishment" ” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and; (f) a farm or plantation; (g) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used for exploration of natural resources. 3. The term “permanent establishment” also encompasses:; (ah) a building site, a construction, installation or assembly or installation project or supervisory activities in connection therewith, but only if where such site, project or activities last activity continues for a period of more than 9 6 months; (bi) a warehouse, in relation to a person providing storage facilities for others; (j) the furnishing of services, including consultancy services, by an enterprise a resident of a one of the Contracting State States through employees or other personnel engaged by the enterprise for such purposepersonnel, but only if provided activities of that nature continue (for the same or a connected project) within the other Contracting State for a period or periods aggregating more than 183 days in within any 12twelve-month period. 43. Notwithstanding the preceding provisions of this Article, the term "“permanent establishment" ” shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, storage or display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of off a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or deliverystorageor display; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying onadvertising, for the enterprisesupply of information, any activity not listed in subparagraphs (a) to (d)for scientific research, provided that this activity has or for similar activities which have a preparatory or auxiliary character; or (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 a broker, general commission agent or any other 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 Contracting State, if: (a) he has, and habitually exercisesexercises in the first-mentioned Contracting State, in a Contracting State an authority to conclude contracts in the name on behalf of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any unless his activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 3 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions ofthat paragraph; or (b) he maintains in the first-mentioned Contracting State a stockof goods or merchandise belonging to the enterprise from which he regularly fills orders or make deliveries on behalf of that paragraphthe enterprise; or (c) he habitually secures orders in the first- mentionedContracting State wholly or almost wholly for the enterprise or for the enterprise and other enterprises which are controlled by it or have a controlling interest in it. 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 where such persons are acting in the ordinary course of their business. For this purpose, an agent shall not be considered an agent of an independent status if it carries on in the other Contracting State an activity described in paragraph 4 wholly or almost wholly for the enterprise or for the enterprise and other enterprises which are controlled by it or have a controlling interest in it. 6. 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 an employee or through a representative who is not an agent of an independent status within the meaning of paragraph 5. 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.