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Adolfo Martín Jimenézexception to this paragraph, which makes its effect very limited,especially if it is considered that associated companies are, inprinciple, regarded as independent. This may explain why theUnited Nations Committee of Experts pointed out, with regardto Article 5 (4), that having a warehouse for delivery would leadto little income being attributed to it;‣ ¾ An insurance provision (excluding reinsurance) is provided inArticle 5 (6) of the United Nations Model Convention whereby aPE is deemed to exist if the foreign enterprise collects premiumsin the territory of the other State or insures risk there througha dependent agent;‣ ¾ Article 5 (7) of the United Nations Model Convention (the independentagent provision equivalent to Article 5 (6) of the OECDModel Convention) adds a sentence considering that the agentloses independence “when the activities of such an agent aredevoted wholly or almost wholly on behalf of that enterprise,and conditions are made or imposed between that enterpriseand the agent in their financial relations which differ from thosewhich would have been made between independent enterprises;‣ ¾ Article 7 (1) of the United Nations Model Convention followsa limited force of attraction principle whereby the profits of aPE also encompass, apart from those connected with its activities,those attributable to: (a) sales of goods or merchandise ofthe same or similar kind as those sold through the PE; and (b)other business activities carried out in the PE State of the sameor similar kind as those effected through the PE. This is viewedas an objective rule, as it is shown by the observation of someStates that the limited force of attraction rule should not applywhere an enterprise “is able to demonstrate that the sales or businessactivities were carried out for reasons other than obtainingtreaty benefits,” which “recognizes that an enterprise may havelegitimate business reasons for choosing not to carry out salesor business activities through its permanent establishment.” 92Finally, the current work of the United Nations Committeeof Experts on the possibility of adding a technical service article in92See paragraph 7 of the Commentary on Article 7 of the United NationsModel Convention.374