Nepalese officials said the deal would encourage Bangladeshi investors to come to Nepal, as they would not have to pay taxes in Bangladesh once they pay the tax in Nepal. Her Majesty`s Government of Nepal and the Government of the Republic of India, which wish to conclude an agreement to avoid double taxation and prevent income tax evasion; During the signing ceremony, Minister Ghimire said the agreement will pave the way for expanding trade and investment between the two countries. ESTABLISHMENT 1. For the purposes of this Agreement, “permanent establishment” means a permanent place of business through which the business of the enterprise is carried on in whole or in part. 2. The term “permanent establishment” includes, inter alia: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; (f) a mine, oil or gas drilling, quarry or other natural resource operation; (g) a construction site or project, but only if the project is in projector operation for one or two periods exceeding 183 days in a twelve-month period; (h) the provision of services by an undertaking by workers or other personnel, where activities continue in the country for a period or a period exceeding 183 days in a twelve-month period. 3. without prejudice to the provisions of the preceding Article, the term “permanent establishment” shall not include: (a) the use of facilities for the sole purpose of storing or delivering goods or goods of the enterprise; (b) the keeping of a stock of goods or goods belonging to the undertaking for the sole purpose of their storage or exhibition; (c) the management of a stock of goods or goods belonging to the undertaking exclusively for the purpose of processing by another undertaking; (d) the maintenance of a permanent secretariat for the sole purpose of acquiring goods, parating goods or collecting information for the enterprise; (e) the maintenance of a permanent establishment for the sole purpose of carrying on another activity of a preparatory or auxiliary nature for the enterprise. 4.