1. For the purposes of this Convention, the term "permanent establishment" means a  fixed place of business through which the business of an enterprise is wholly or partly  carried on.  

2. The term "permanent establishment" includes especially:  

a) a place of management;  

b) a branch;  

c) an office;  

d) a factory; 

e) a workshop, and  

f) a mine, an oil or gas well, a quarry or any other place of extraction of natural  resources.

3. A building site or construction, assembly or installation project constitutes a  permanent establishment only if it lasts more than twelve months.

4. Notwithstanding the preceding provisions of this Article, the term "permanent  establishment" shall be deemed not to include:  

a) the use of facilities solely for the purpose of storage, display or delivery of goods or  merchandise belonging to the enterprise;  

b) the maintenance of a stock of goods or merchandise belonging to the enterprise  solely for the purpose of storage, display or delivery;  

c) the maintenance of a stock of goods or merchandise belonging to the enterprise  solely for the purpose of processing by another enterprise;  

d) the maintenance of a fixed place of business solely for the purpose of purchasing  goods or merchandise or of collecting information, for the enterprise;  

e) the maintenance of a fixed place of business solely for the purpose of carrying on,  for the enterprise, any other activity of a preparatory or auxiliary character;  

f) the maintenance of a fixed place of business solely for any combination of activities  mentioned in 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 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 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. Notwithstanding the preceding provisions of this Article, an insurance enterprise of a  Contracting State shall, except the cases of reinsurance, be considered as having a  permanent establishment in the other Contracting State if it collects insurance premiums on  the territory of that other State or insures risks situated therein through a person which is  not an agent of an independent status.

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 State (whether through a permanent establishment or otherwise),  shall not of itself constitute either company a permanent establishment of the other.