S.L. 123.3 · Double Taxation Relief On Taxes On (S.L. 123.3)
S.L. 123.3 Art. 4a person - - is acting State, that first-mentioned for the to conclude of such if exercised fixed place of of that delivers
Notwithstanding the provisions of paragraphs 1 and 2, where other than an agent of an independent status to whom paragraph 6 applies in a Contracting State on behalf of an enterprise of the other Contracting enterprise shall be deemed to have a permanent establishment in the Contracting State in respect of any activities which that person undertakes enterprise, if such a person:
(a) Has and habitually exercises in that State an authority contracts in the name of the enterprise, unless the activities person are limited to those mentioned in paragraph 4 which, through a fixed place of business, would not make this business a permanent establishment under the provisions 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 goods or merchandise on behalf of the enterprise.