Question: With specific reference to the exact relevant elements of the OECD model tax convention where relevant in your responses, Explain whether a permanent establishment will

With specific reference to the exact relevant elements of the OECD model tax convention where relevant in your responses, Explain whether a permanent establishment will generally exist in the following scenarios:

i. a construction project lasting eleven months, where there is a relevant double tax agreement in place;

ii. an office, where there is a relevant double tax agreement in place;

iii. the maintenance of a fixed place of business primarily for the purpose of purchasing goods for an enterprise, where there is a relevant double tax agreement in place;

iv. the maintenance of a fixed place of business solely for the purpose of carrying on an activity of a preparatory or auxiliary character;

v. a non-independent agent acting on behalf of an enterprise and habitually exercising an authority to conclude contracts in its name, where there is a relevant double tax agreement in place;

vi. a fixed place of business through which the business of an enterprise is generally carried out, where there is a relevant double tax agreement in place;

vii. an enterprise carrying on business through a general commission agent of independent status acting in the ordinary course of business, where there is a relevant double tax agreement in place;

viii. a satellite in geostationary orbit above a contracting state, where there is a relevant double tax agreement in place; and

ix. a website in a contracting state hosted by an independent third party, where there is a relevant double tax agreement in place.


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