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@freshy70 wrote:

For these reasons there is no PE:

4. Notwithstanding the preceding provisions of this Article, the term “permanent establishment” shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise;

The 3rd party he uses in the U.S. is simply to store and deliver goods. He has no control over that enterprise nor is it part of his company.

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Btw, I should have asked a couple other questions about these goods that are stored and delivered in the US.  Where are these manufactured?  How are the sales negotiated, contracted, and settled?