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.

Moreover, the addition of new permanent members selected by the Assembly would establish a direct link of accountability between the new permanent members and the general membership.

Thus, we further recommend that United Nations establish a special committee comprising the proposed permanent youth representatives.

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.

With respect to the non permanent membership, we also need to establish proper geographical representation, in accordance with the Charter.

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

(c) To establish a permanent dialogue on investment, the expansion of the entrepreneurial base and access to credit and technical assistance

The universality and integrity of the Rome Statute must be the permanent concern of those who helped to establish the Court.

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.

The President issued a decree on the same day to establish a caretaker Government, pending the establishment of the Government of National Unity.

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.

The Committee also recommends that the State party establish a permanent intersectoral and multidisciplinary mechanism to coordinate all policies, strategies and activities relating to children.

This programme will help to establish a coherent permanent system for the continuous and constant improvement of the training scheme, developed and implemented by FIA.

Some delegations expressed their support for the establishment of regional port waste reception facilities rather than requiring States to establish these on an individual basis.

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.

Settlement activities have been accompanied by disturbing information concerning plans to establish permanent links between several West Bank settlements, particularly in East Jerusalem and its environs.

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.

It was the first government in world history to nationally issue banknotes or true paper money, and the first Chinese government to establish a permanent standing navy.

Operation Tabarin was a World War II military undertaking by the Admiralty and the Colonial Office in 1943 to establish a permanent British presence in the Antarctic.

In 2001 the Government announced plans to establish a permanent social welfare programme within the Social Security Board to assist the elderly and other economically deprived groups.

We therefore welcome the establishment of a Democracy Fund at the United Nations and invite the Secretary General to establish an advisory board to provide policy guidance.

At that point, the constituent assembly and government could decide whether to switch to a presidential form of government or establish a parliamentary system on a permanent basis.

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.

This constitutional convention, after a long period of emergency rule, was striving to establish a more stable and permanent government in the uncertain period after the Reign of Terror.

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.

In 2007 the head of the Russian Space Agency announced plans to send cosmonauts to the Moon by 2025 and establish a permanent robotically operated base there in 2027 2032.

We therefore welcome the establishment of a Democracy Fund at the United Nations and invite the Secretary General to establish an advisory board to provide policy guidance and funding guidelines.

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.

Even in the case of those bilateral treaties intended to establish a permanent condition of things, there is nothing to prevent a victorious belligerent from dissolving them in the peace treaty.

(k) To establish a national human rights commission in accordance with the Principles relating to the establishment of national institutions for the promotion and protection of human rights (the Paris Principles)

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.

We decide to establish the Ibero American Secretariat (SEGIB) as a permanent organ to support the institutionalization of the Ibero American Conference, and we congratulate its first Secretary General, Enrique V. Iglesias.

Reaffirms the inalienable, permanent and unqualified right of the Palestinian people to self determination, including their right to live in freedom, justice and dignity and to establish their sovereign and independent State

Reaffirms the inalienable, permanent and unqualified right of the Palestinian people to self determination, including their right to live in freedom, justice and dignity and to establish their sovereign and independent State