S.L. 123.172 · Double Taxation Relief (Taxes On Income) (S.L. 123.172)
S.L. 123.172 Art. 4the term of goods to the to the enterprise; the purpose of 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 or display or merchandise belonging to the enterprise;
(b) the maintenance of a stock of goods or merchandise belonging enterprise solely for the purpose of storage or display;
(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 collecting information for the 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.