Permanent Establishments Sample Clauses

Permanent Establishments. Neither the Company nor any Company Subsidiary has or has had a permanent establishment in any foreign country, as defined in any applicable Tax treaty or convention between the United States of America and such foreign country.

Permanent Establishments. 1. For the purposes of this Agreement, the term " permanent establishment " means a fixed place of business through which the business of 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; f. a mine, a quarry, an oilfield or other place of extraction of natural resources; g. a farm, plantation or other place where agricultural, forestry, plantation or related activities are carried on; h. a building site or construction or assembly project or supervisory activities in connection therewith, where such site project or supervisory activity continues for a period of more than twelve months. 3. Notwithstanding the proceeding provisions of this Article, the term " pemanent establishment " shall be deemed not to include:--- a. the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b. the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c. the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the 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; for the supply of information or for scientific research, being activities solely of a preparatory or auxiliary character in the trade or business of the enterprise. 4. Notwithstanding the provisions of paragraphs 1 and 2, where a person other than an agent of independent status to whom paragraph 5 applies is acting on behalf of an enterprise and has, and habitually exercise, in a Contracting State, an authority to conclude contracts 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 of such person are limited to the purchase of goods or merchandise for the enterprise. 5. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any ot...

Permanent Establishments. Prior to Closing, Seller shall deliver to Purchaser a list of each jurisdic- tion in which the Packaging Companies currently take the position that they have permanent establishments (as such term is used in any relevant double taxation agreement) outside the country in which it is incorporated.

Permanent Establishments. Except as set out in Schedule 17.4, for Tax purposes, both the Company and debis AirFinance Ireland plc are and have been resident only in the jurisdiction in which they are incorporated and do not have nor had a permanent establishment or permanent representative or other taxable presence in any jurisdiction other than that in which they are resident for Tax purposes. Neither the Company nor a dAF-Consolidated Company constitutes or has constituted a permanent establishment or is or has been a permanent representative of another Person.

Permanent Establishments. The Company does not have and has not had a permanent establishment in any foreign country, as defined in any applicable Tax treaty or convention between the United States of America and such foreign country.