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(1) For the purposes of this Agreement the term “per- manent establishment” means a fixed place of business in which the business of the enterprise is wholly or partly carried on.
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(2) The term “permanent establishment” shall include especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop; f} a mine, quarry or other place of extraction of natural resources; g) a building site or construction or assembly project which exists for more than six months.
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(3) The term “permanent establishment” shall not be deemed 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; the maintenance of a stock of goods or merchandise Cc 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 merc andise, or for collecting information, for the enterprise; the maintenance of a fixed place of business solely e for the purpose of advertising, for the supply of in- formation, for scientific research or for similar ac- tivities which have a preparatory or auxiliary charac- ter, for the enterprise.
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(4} 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 para- graph (5) applies—shall be deemed to be a permanent establishment in the first-mentioned State if: a) he has, and habitually exercises in that State, an authority to conclude contracts in the name of the enterprise, unless his activities are limited to the purchase of goods or merchandise for the enterprise; or he has, and habitually exercises in that State, an b authority to fill orders on behalf of the enterprise from a stock of goods or merchandise which he maintains in that State and which belong to the enterprise.
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(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 other agent of an independent status, where such persons are acting in the ordinary course of their business.
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(6) The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself make either company a permanent establish- ment of the other.
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(7) Notwithstanding any other provision of this Ar- ticle, an enterprise of a Contracting State which is regularly engaged in the business of furnishing personal services, shall be deemed to have a permanent establish- ment in the other Contracting State, if a person or persons, being employees of such enterprise and sent by such enterprise for the purposes of performing such services, are present in that other State for performing such services in respect of the same project for a period or periods exceeding in the aggregate six months during any twelve-month period.