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:
“All of the valuable qualities ... like helping in the development of others—will not get you to the top at General Motors, were that path open to women.... The characteristics most highly developed in women and perhaps most essential to human beings are the very characteristics that are specifically dysfunctional for success in the world as it is.... They may, however, be the important ones for making the world different.”
—Jean Baker Miller (20th century)
“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)
“As Jerome expanded, its chances for the title, “the toughest little town in the West,” increased and when it was incorporated in 1899 the citizens were able to support the claim by pointing to the number of thick stone shutters on the fronts of all saloons, gambling halls, and other places of business for protection against gunfire.”
—Administration in the State of Ariz, U.S. public relief program (1935-1943)