Of critical importance is paragraph 42.6 of the OECD Commentary, which widens the definition of permanent establishment by specifying that no physical presence is required to establish a permanent establishment.

According to the OECD Commentary, no permanent establishment exists in such a case.

The authors opine that this could give rise to the avoidance of a permanent establishment by managing the contractual terms in cases where the circumstances would justify the permanent establishment conclusion instead.

Post 2003, renovations and installations, planning and supervisions may amount to a permanent establishment.

In general, most of the OECD changes to the Commentary have resulted in the widening of the permanent establishment concept (Pijl, 2002), for example, the conclusion that no human presence is required to constitute a permanent establishment.

Co operation and establishment of a permanent forum of opinion exchange and information by Ministries and NGOs.

Some of the amendments to the OECD Model Tax Convention, however, include a narrowing of the requirements for constituting a permanent establishment.

The international community does not yet have experience in the establishment of permanent international criminal courts.

A permanent establishment (PE) is a fixed place of business which generally gives rise to income or value added tax liability in a particular jurisdiction.

In 2006 formulation of more precise foreign policy priorities awaits the firm establishment of the permanent government.

Establishment of campaigns and or permanent services for collecting solid wastes that pollute marine and coastal areas

That African vision entails the establishment of a 26 member Security Council in which our continent will have two permanent seats having the same prerogatives and privileges as the current permanent members, including the right of veto, as well as five non permanent seats.

Besides the classic source principle namely, that of the permanent establishment other source principles have recently been proposed.

1998, July Member of the Danish Delegation at the Rome Conference for Establishment of the Permanent International Criminal Court (ICC)

Under paragraph 6 of the OECD Commentary, activities existing for a very short period of time could lead to a permanent establishment when the nature of the business so justified.

Requests the OIC Permanent Observer Mission in Geneva, pending the establishment of an OIC Office in Brussels, to continue to maintain a close liaison with the European Union.

The building and use of a maritime port and an airport, as well as the establishment of a permanent geographic link to the West Bank, are absolutely crucial to Gaza's economy.

6. Welcomes the establishment of the Permanent Secretariat of the Assembly of States Parties to the Rome Statute of the International Criminal Court

This narrows the definition of permanent establishment and our proposal is that the wording all or parts of the projects should be used.

Far from being a failure, the ICTY has inspired the establishment of several other such courts, including those for Rwanda, Sierra Leone, Cambodia, and the permanent International Criminal Court.

The question arises whether, if the essential elements (but not all elements) are negotiated by the agent, this would still amount to an agency permanent establishment.

The permanent Working Group on Cooperation in Antarctica of the International Hydrographic Organization (IHO) has reported annually to the Consultative Meetings since its establishment in 1992.

The term parts of such project indicates that if an enterprise had to subcontract all the project, this would not amount to a permanent establishment of that enterprise in the State of subcontraction.

Treaties declaring, creating, or regulating permanent rights or a permanent regime or status

2. Notes the establishment of a voluntary fund for the erection of a permanent memorial, expresses sincere appreciation to those Member States that have already made contributions to the fund, and invites other interested parties to do likewise

(b) Treaties declaring, creating, or regulating permanent rights or a permanent regime or status

Although the Nordic countries support the idea of establishing a permanent court through an international convention, they are at the same time of the view that the establishment of such a court should be based on an evolutionary approach.

Establishment of a registration system

Establishment of a compliance committee

Establishment of a separation fund

The Committee commends the establishment of an Advisory Commission on Human Rights, a Complaints Office within the Permanent Special Commission against Racial Discrimination, advisory commissions for foreigners in the communes, and the appointment of an ombudsman.

A rivet is a permanent mechanical fastener.

Although this can be considered a sympathetic attempt to widen the scope of the permanent establishment concept, it is also to be considered that such rejected positions have a negative bearing on the status of the whole Commentary as a source of interpretation.

Permanent teeth in the maxilla erupt in a different order from permanent teeth on the mandible.

We ask for at least two permanent members with a veto and five non permanent seats.

The establishment of the Permanent Forum on Indigenous Issues as a subsidiary organ of the Economic and Social Council and the two sessions held by the Forum to date represented progress towards compliance with the objectives of the Decade.

The Institute has a bureau and a permanent secretariat.

(c) Establishment of a military staff committee

Support to the establishment of a family

Establishment of a working group 87 88.

(a) Enlarge the Security Council in both the permanent and non permanent categories and improve on its working methods

In order to enable the Court to operate efficiently and to work in a web based environment, the Registry has established a number of information systems. The Registry has also undertaken comparative studies in relation to the establishment of the permanent premises of the Court.

Sami became a permanent ficture in Layla's house.

The Permanent Observer for Palestine made a statement.

(Signed) Simeon A. Adekanye Ambassador Acting Permanent Representative