ARTICLE 5

PERMANENT ESTABLISHMENT

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,

exploration or exploitation of natural resources. 3. A building site, or construction or installation project or supervisory activities in connection therewith, constitutes a permanent establishment only if such site, project or activities continue for a period or periods exceeding in the aggregate 12 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;

II SÉRIE-A — NÚMERO 60_______________________________________________________________________________________________________________

54