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:
“Never relinquish clothing to a hotel valet without first specifically telling him that you want it back.”
—Fran Lebowitz (b. 1950)
“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)
“The places which I have described may seem strange and remote to my townsmen ... our account may have made no impression on your minds. But what is our account? In it there is no roar, no beach-birds, no tow-cloth.”
—Henry David Thoreau (1817–1862)