(a) A permanent establishment of a nonresident in the Kingdom consists of the

     permanent place of activity of the nonresident through which it carries out

     business, in full or in part, including business carried out through an agent.

(b) The following are considered a permanent establishment:
   - construction sites, assembly facilities, and the exercise of supervisory

     activities connected with them;
   - installations or sites used for surveying for natural resources, drilling

     equipment, or ships used for surveying for natural resources, as well as the

     exercise of supervisory activities connected with them;
   - a fixed base where a nonresident natural person carries out business;
   - a branch of a nonresident company which is licensed to carry out business in

     the Kingdom.

(c) A place is not considered a permanent establishment of a nonresident in the 

     Kingdom if it is used in the Kingdom only to do the following:
   - store, display, or deliver goods or products belonging to the nonresident;
   - keep a stock of goods or products belonging to the nonresident for the

      purpose of processing by another person;
   - purchase goods or products only for the purpose of collection of information

     for the nonresident;
   - perform any other activities that are preparatory or auxiliary in nature in the

     interests of the nonresident;
   - draw-up contracts for signature with regard to credits (loans), delivery of

     goods, or provision of technical services;
   - execute any combination of the activities indicated in the above

     subparagraphs of this paragraph.

(d) A nonresident partner in a resident personal company is considered to have a

     permanent establishment in the Kingdom in the form of a partnership interest.