Places of business are not «separated organizationally» where they each perform in a Contracting State complementary functions such as receiving and storing goods in one place, distributing those goods through another etc. An enterprise cannot fragment a cohesive operating business into several small operations in order to argue that each is merely engaged in a preparatory or auxiliary activity. OECD Model Tax Convention. Condensed Version (2010). Commentary to art. 5. § 27.1. P. 104.
