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)
“All places where women are excluded tend downward to barbarism; but the moment she is introduced, there come in with her courtesy, cleanliness, sobriety, and order.”
—Harriet Beecher Stowe (1811–1896)
“Traveling, you realize that differences are lost: each city takes to resembling all cities, places exchange their form, order, distances, a shapeless dust cloud invades the continents.”
—Italo Calvino (1923–1985)