AGREEMENT BETWEEN

PERMANENT ESTABLISHMENT 1.  For the purposes of this Agreement, the term “permanent establishment” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2.  The term “permanent establishment” includes especially: a)  a place of management; b)  a branch; c)  an office; d)  a factory; e)  a workshop; and f)  a mine, an oil or gas well, a quarry, or any other place of extraction of natural resources. 3.  The term “permanent establishment” 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 183 days; b)  the furnishing of services, including consultancy services, by an enterprise through employees or other personnel engaged by the enterprise for such purpose, but only if activities of that nature continue within a Contracting State for a period or periods aggregating more than 183 days in any twelve-month period commencing or ending in the fiscal year concerned; c)  the carrying on of activities by an enterprise in a Contracting State which are connected with the exploration or exploitation of natural resources situated in that Contracting State for a period or periods aggregating more than 30 days in any twelve-month period commencing or ending in the fiscal year concerned. The duration of activities under subparagraphs a), b) and c) shall be determined by aggre- gating the periods during which activities are carried on in a Contracting State by closely related enterprises, provided that the activities of such a closely related enterprise in that Contracting State are connected with the activities carried on in that Contracting State by its closely related enterprises. The period during which two or more closely related enterprise are carrying on concurrent activities shall be counted only once for the purpose of deter- mining the duration of activities. 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; 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, is of a preparatory or auxiliary character.