Specifically Excluded Places
Many treaties explicitly exclude from the definition of PE places where certain activities are conducted. Generally, these exclusions do not apply if non-excluded activities are conducted at the fixed place of business. Among the excluded activities are:
- Ancillary or preparatory activities
- The use of a storage facility solely for delivery of goods to customers
- The maintenance of a stock of goods owned by the enterprise solely for purposes of processing by another enterprise (sometimes referred to as toll processing)
- Purchasing or information gathering activities
Read more about this topic: Permanent Establishment
Famous quotes containing the words specifically, excluded and/or places:
“What people don’t realize is that intimacy has its conventions as well as ordinary social intercourse. There are three cardinal rules—don’t take somebody else’s boyfriend unless you’ve been specifically invited to do so, don’t take a drink without being asked, and keep a scrupulous accounting in financial matters.”
—W.H. (Wystan Hugh)
“Reasoning from the common course of nature, and without supposing any new interposition of the Supreme Cause, which ought always to be excluded from philosophy; what is incorruptible must also be ingenerable. The soul, therefore, if immortal, existed before our birth: And if the former existence noways concerned us, neither will the latter.”
—David Hume (1711–1776)
“All men are lonely. But sometimes it seems to me that we Americans are the loneliest of all. Our hunger for foreign places and new ways has been with us almost like a national disease. Our literature is stamped with a quality of longing and unrest, and our writers have been great wanderers.”
—Carson McCullers (1917–1967)