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. A building site or construction or installation project constitutes a  permanent establishment only if it lasts more then 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  advertising, for the supply of information, for scientific research or similar activities  which have a preparatory or auxiliary character for the enterprise; f) 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  machinery or equipment produced by that enterprise; 

g) the maintenance of a fixed place of business solely for any combination  of activities mentioned in subparagraphs a) to f), 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 then 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.