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.

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.

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.

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.

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

c) The establishment of Joint learning groups on small scale business, on credit management, on marketing, on business start up etc

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

In that sense, the phenomenon of the business cycle looked relatively permanent and unchanging.

UNCTAD's component included intensive training and business development services for more than 1,000 local companies, the establishment of TNC SME business linkages and the implementation of a business incubator.

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.

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

History It was established in 1964, after the Franks Report recommended the establishment of two business schools, as part of existing universities (London Business School and Manchester Business School), but with considerable autonomy.

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

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

In both cases, the biggest winners were vested interests (Korea s business establishment and the Chinese Communist Party).

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

Other terms such as place of business or non transitory establishment also could create problems under EU law.

(a) The principal place of business or , in the absence thereof, the habitual permanent residence of the defendant or

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

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.

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

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.

Moreover, Doing Business helps to break down barriers particularly in developing countries that can discourage the establishment of small and medium size enterprises, provide opportunities for corruption, and drive small business owners to the informal sector.

If banks are regulated at the national level, but do business internationally, national regulatory authorities have a permanent incentive to set lax standards to avoid driving business to other countries and to lure it from them instead.

CAMBRIDGE Last year, the leaders of all five permanent members of the United Nations Security Council visited India, accompanied by delegations of business leaders.

7. Welcomes, in this regard, the establishment by the Community of the Women in Business Network, aimed at empowering women by, inter alia, facilitating and enhancing their access to credit and training in business and technical skills

The establishment of a business must conform to planning regulations (zoning plan and urban renewal plan) and to bye laws concerning the residential environment.

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.

In a globalizing world, competition for foreign direct investment focuses on the establishment of a good business environment and investment incentives, consistent with national development objectives.

Burkina Faso welcomes the establishment of the International Independent Investigation Commission authorized by the Security Council, and hopes that this murky business will be thoroughly clarified.

These programs include assistance in funding for small businesses, feminine empowerment courses, establishment of women only business clubs and other activities and special assistance for single mothers.

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.

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.

Nobel travelled for much of his business life, maintaining companies in various countries in Europe and North America and keeping a permanent home in Paris from 1873 to 1891.

An institutional framework implies that CFMs should be part of a country s permanent policy toolkit, and that regulations are strengthened or weakened depending on the phase of the business cycle.

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.

The provision of grants to young people, which was also announced in the programme, will allow us to promote self employment through the establishment of small and medium sized business.

Following the establishment of a new rolling stock manufacturing business (PT.INKA), a number of technology transfer processes based on technology sources from abroad were undertaken to prepare for the work.

Graham at the Permanent Mission of the United States of America to the United Nations during regular business hours at 212 415 4330 and after hours please call 212 415 4444.

I would also like to express our appreciation for the efforts made by your predecessor, Ambassador Baja, the Permanent Representative of the Philippines, in conducting the business of the Council last month.

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.

Many of the measures described, such as the establishment of the Management Performance Board and the proposed establishment of the Office of Ethics, will themselves lead to a further examination of the way that the United Nations conducts its business and to additional measures to improve the system of accountability.