Permanent Establishment - Specifically Excluded Places

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:

    Can we not teach children, even as we protect them from victimization, that for them to become victimizers constitutes the greatest peril of all, specifically the sacrifice—physical or psychological—of the well-being of other people? And that destroying the life or safety of other people, through teasing, bullying, hitting or otherwise, “putting them down,” is as destructive to themselves as to their victims.
    Lewis P. Lipsitt (20th century)

    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)

    There are few places outside his own play where a child can contribute to the world in which he finds himself. His world: dominated by adults who tell him what to do and when to do it—benevolent tyrants who dispense gifts to their “good” subjects and punishment to their “bad” ones, who are amused at the “cleverness” of children and annoyed by their “stupidities.”
    Viola Spolin (b. 1911)