S.L. 123.123 чл. 5this Article a Contracting by mutual to that 1. For means a fixed wholly or 2. The a) a b) a c) an d) a e) a f) a 3. A drilling rig permanent more than 4. "permanent a) of b) c) d) e) (f) of 5. other than an on behalf of authority to shall be activities that person are fixed plan of establishment 6.

Where by reason of the provisions of paragraphs 1 and 2 of person other than an individual or a company is a resident of both States, the competent Authorities of the Contracting States shall agreement endeavour to determine the mode of application of this Convention person. Article 5 PERMANENT ESTABLISHMENT

the purposes of this Convention, the term "permanent establishment"' place of business through which the business of an enterprise is partly carried on. term "permanent establishment"' includes especially:

place of management; branch; office; factory; workshop; and mine, an oil or gas well, a quarry, or any other place of extraction of natural resources.

building site or construction or installation project, or an installation or or ship used for the exploration of natural resources, constitutes a establishment only if it lasts, or the exploration activity continues for twelve months. Notwithstanding the preceding provisions of this Article, the term establishment" shall be deemed not to include: the use of facilities solely for the purpose of storage, display or delivery goods or merchandise belonging to the enterprise; the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise, or of collecting information, for the enterprise; 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; the maintenance of a fixed place of business solely for any combination the activities mentioned in subparagraphs a) through e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. Notwithstanding the provisions of paragraphs 1 and 2, where a person -agent of an independent status to whom paragraph 6 applies - is acting an enterprise and has and habitually exercises in a Contracting State an conclude contracts that are binding on the enterprise, that enterprise deemed to have a permanent establishment in that State in respect of any the person undertakes for the enterprise, unless the activities of such limited to those mentioned in paragraph 4 that, if exercised through a business, would not make this fixed place of business a permanent under the provisions of that paragraph.

enterprise shall not be deemed to have a permanent establishment in a State merely because it carries on business in that State through a broker, general commission agent, or any other agent of an independent provided that such persons are acting in the ordinary course of their independent agents.