Page 439 - ΔΟΚΙΜΗ

430 ΕΠΙΣΗΜΗ ΕΦΗΜΕΡΙΔΑ ΤΗΣ 4ης ΑΠΡΙΛΙΟΥ 1984
permanent establishment which the recipient, being
a resident ο! a Contracting State, has ίη the other
Contraoting state, whether or not such income ίθ
derived from industrial or commercial activity.
(b) Το determine whether property or rights are
effectively connected with a permanent establishment,
the factore taken into aooount shall lnolude whether
rights or property are used in οτ held for use ίη
carryiηg οη lndustrial or oommercial aotivity through
such permanent establishment and whether the activities
carried οη through suoh permanent ests.blishDlent were
a material faotor ίη the realization of the income
derived from such property or rights. For this
purpose, due regard shall be given to whether or not.
such property o~ rights or such income were aocounted
for through such permanent establishment.
(7) V/here in(1ustrial or commercial profi ts include ί tems
of income which are dealt with separately ίη other Articles
ο! this Convention, the provisions of thoee Articles shall,
except βθ otherwise provided therein, supersede the
provisions ο! this Article.
Article 9
FERl\:ANENT ESTABLISHMENT
(1) For purposes ο! this Convention, the term "perma.nent
establishment" means a. fixed place ο! business through
which a resident ο! a Contracting state engages ίη industrial
or commeroial activity.
(2) The term "fixed plaoe ο! business" includes but is
not 1imited to:
(a) Α branoh;
(b) An offioe;
(ο) Α factory;
(d) Α workshop;
(e) Α warehouse;
(f) Α store or other salee outlet;
(g) Α mine, quarry, οτ other place of extraotion
of natural resouroes; and