Re: Too Simplistic
Really? I'd have thought that a supermarket would constitute a permanent establishment as it's "a fixed place of business through which the business of an enterprise is wholly or partly carried on". (OECD model convention article 5 para 1)
Amazon's get out is that exempt are "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;" (article 5 para4).
A perfectly decent exemption which made sense before the business of the enterprise took place in a data centre (which isn't a permanent establishment either).
Biting the hand that feeds IT
