S.L. 123.42 Art. 5to have a it carries on or any other course wholly an agent of shown that the arm’s length

An enterprise of a Contracting State shall not be deemed permanent establishment in the other Contracting State merely because business in that other State through a broker, general commission agent agent of an independent status, where such persons are acting in the ordinary of their business. However, when the activities of such an agent are devoted or almost wholly on behalf of the enterprise, he shall not be considered an independent status within the meaning of this paragraph, if it is transactions between the agent and the enterprise were not made under conditions.