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.

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.

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

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.

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)

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.

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.

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.

Other signals were missed, ignored, or deemed unimportant.

Which May Be Deemed to Be Excessively Injurious

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.

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.

Each of the four faced what many deemed overwhelming odds.

Such a move would be deemed premature by numerous critics.

But this middle income transition is sometimes deemed a trap.

He verily deemed that he would never return ( unto Allah ) .

It was deemed particularly important in terms of fundraising capacity.

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.

In other words, he was deemed to be healthy and happy.

Their continued independence is now deemed essential to China s national security.

Where allegations were deemed to be unfounded, the cases were closed.

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.

Dealing with financial institutions deemed too big to fail won t be easy.

Investors withdrew in droves from what was once deemed the Celtic Tiger.

The Committee may wish to make observations and recommendations, as deemed appropriate.

Food, housing and water are deemed more important than democracy and trade unions.

United States In the United States,many types of relationships are deemed friendships.

Consequently, the Human Rights Committee's monitoring cannot in this respect be deemed comprehensive.

When abstaining, a member shall be deemed not to have cast its votes.

When abstaining, a member shall be deemed not to have cast its votes.

Individuals were not deemed qualified to determine the need for such a test.

If such information is deemed to put that person's physical integrity at risk

(b) There will be no unforeseen situations originating from events deemed force majeur

Concerned about the continued establishment of checkpoints in the Occupied Palestinian Territory, including East Jerusalem, and the transformation of several of these checkpoints into structures akin to permanent border crossings inside the Occupied Palestinian Territory,