Section 4 in Convention between the Government of the Republic of India and the Government of the Republic of Namibia for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income and capital gains
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 or display or the occasional 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 occasional delivery;(c)the maintenance of a stock of goods or merchandise belonging to the enterprises solely for the purpose of processing by another enterprise;(d)the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise;(e)the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character;(f)the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs (a) to (e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character.
