S.L. 123.100 · Double Taxation Relief On Taxes On (S.L. 123.100)
S.L. 123.100 Art. 4the term or delivery to the to the enterprise; the purpose of for the the purpose of preparatory or combination that the from this
Notwithstanding the preceding provisions of this Article, "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging enterprise solely for the purpose of processing by another d) the maintenance of a fixed place of business solely for purchasing goods or merchandise or of collecting information enterprise; e) the maintenance of a fixed place of business solely for carrying on, for the enterprise, any other activity of a auxiliary character; f) the maintenance of a fixed place of business solely for any of activities mentioned in sub-paragraphs (a) to (e), provided overall activity of the fixed place of business resulting combination is of a preparatory or auxiliary character.