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2. The term “permanent establishment” includes especially:

a) a place of management;

b) a branch;

c) an office;

d) a factory;

e) a workshop;

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

g) an agricultural, pastoral or forestry exploitation.

3. A building site or construction 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 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.

CHAPTER III

TAXATION OF INCOME

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 State.