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May 15, 2026

Part 2 - General Provisions

Section 1 - Permanent Establishments

Article 3

[GTL Notes: Permanent Establishment - Exclusions]

For the purposes of the foregoing Article 2, there shall not be regarded as having a permanent establishment if the foreign person uses a fixed place of business solely for the following purposes:

  1. Storage, display or delivery of goods or merchandise belonging to that person.

  2. The maintenance of a stock of goods belonging to that person for the purpose of storage, display or delivery or processing by another person.

  3. Purchase of goods, merchandise, or collection of information for the business.

  4. Carrying on any other activity of a preparatory or auxiliary character for the purposes of the business.

  5. The combination of any of the activities mentioned in the foregoing four sub-clauses of this Article provided that the overall activity of the fixed place of business resulting from that combination is of a preparatory or auxiliary character.