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(d) the maintenance of a fixed place of business solely for the purpose of collecting information of the

enterprise or of purchasing goods or merchandise in order to continue producing or processing by 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; and

(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 paragraph 7 applies - is acting in a Contracting State on behalf of an enterprise

of the other Contracting State, that enterprise shall be deemed to have a permanent establishment in the first-

mentioned Contracting State in respect of any activities which that person undertakes for the enterprise, if

such a person:

(a) has and habitually exercises in that State an authority to conclude contracts in the name of 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; or

(b) has no such authority, but habitually maintains in the first-mentioned State a stock of goods or

merchandise from which he regularly delivers goods or merchandise on behalf of the enterprise.

6. Notwithstanding the preceding provisions of this Article, an insurance enterprise of a Contracting

State shall, except in regard to re-insurance, be deemed to have a permanent establishment in the other

Contracting State if it collects premiums in the territory of that other State or insures risks situated therein

through a person other than an agent of an independent status to whom paragraph 7 applies.

7. 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 Contracting 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. However, when the activities of such an agent are devoted wholly or

almost wholly on behalf of that enterprise, and conditions are made or imposed between that enterprise and

the agent in their commercial and financial relations which differ from those which would have been made

between independent enterprises, he will not be considered an agent of an independent status within the

meaning of this paragraph.

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

Contracting State (whether through a permanent establishment or otherwise), shall not of itself constitute

either company a permanent establishment of the other.

ARTICLE 6

Income from Immovable Property

1. Income derived by a resident of a Contracting State from immovable property (including income from

agriculture or forestry) situated in the other Contracting State may be taxed in that other Contracting State.

2. The term “immovable property” shall have the meaning which it has under the law of the Contracting

State in which the property in question is situated. The term shall in any case include property accessory to

immovable property, livestock and equipment used in agriculture and forestry, rights to which the provisions of

general law respecting landed property apply, usufruct of immovable property and rights to variable or fixed

payments as consideration for the working of, or the right to work, mineral deposits, sources and other natural

resources; ships and aircraft shall not be regarded as immovable property.

3. The provisions of paragraph 1 shall apply to income derived from the direct use, letting, or use in any

other form of immovable property.