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.

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

We strongly support the creation of new permanent seats.

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.

From 840, the Vikings began establishing permanent bases at the coasts.

Under those treaties, a building site or construction or installation project constitutes a PE only if it lasts more than a specified length of time.

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

The dream of a permanent international court was deferred for far too long.

Here, one may wonder why a country such as Belgium would support the creation of new permanent seats.

To date, 253,000 new jobs have been created, 133,000 of which are permanent.

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

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.

In 1945, the price of peace included the creation of the five permanent seats with which we are so familiar.

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.

This gave rise to serious discussion about instituting permanent direct air links to aid bilateral trade flow.

Her delegation agreed with the High Commissioner's proposal to establish standing capacities for rapid response, fact finding and investigations.

A solar energy installation in Germany.

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.

Sixteen of 59 installations and sites have been released.

The foundation De Stromen' therefore decided to set up a care centre in the Rotterdam and Ridderkerk region, a small scale business providing care, comfort services and support for the elderly.

Fourthly, the creation of six new permanent seats would also seriously undercut the effectiveness of the Security Council.

To serve Reception Classes, 257 permanent positions of elementary school teachers have been established, while the rest of the positions are staffed by substitute teachers.

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 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.

In other words, if some minor detail is decided by the general enterprise, and not by the agent, would this not give rise to an agency permanent establishment? If this is the interpretation given, it could easily lead to abuse.

55 171. Closure of the Chernobyl nuclear power plant

At the same meeting, it was also decided to establish a new standing committee to give better policy direction and to follow up on joint activities of the United Nations and regional organizations.

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.

It was discovered in the 10th century by the Arabs and was first named Dina Harobi, but the first permanent settlement was by the Dutch in 1638.

We must make progress in setting up the Human Rights Council as a standing body to address all situations of human rights violations and guarantee a system of evaluation of the performance of its members.

By then, the torture facility had been turned into a museum.

(1) A facility for the production, stockpiling, preservation or destruction of chemical weapons or a facility for the production of unfilled chemical munitions or materials intended for chemical weapons use

Another essential element to which we attach great importance, and which we hope to see realized promptly, relates to the decision taken by our heads of State or Government on the establishment of a standing police force.

Over 50 years ago, in the wake of the Holocaust, the newly created United Nations first took up the issue of a permanent international criminal court.

We took off from the shuttle landing facility, where the shuttle takes off and lands.

(b) Holding office in an enterprise owned in whole or in part by the State.

The existing machinery includes treaty bodies, some of which are working fine.

History The idea of a permanent international political science students' network was first discussed in 1996, when students from Leiden University visited colleagues in Rome.

We particularly endorse the proposal for a peacebuilding commission to address the need for sustained action to prevent countries emerging from war from lapsing back into violence.

Therefore if a particular contracting state places a different meaning on the term 'permanent establishment' than what the taxpayer seeks to place, the taxpayer would be left with virtually no remedy within that state, other than to seek a mutual agreement to that dispute with the other contracting state to that treaty.

At one time, there were regular residents working at a bonito drying facility.

Computer graphics software is used to make computer generated imagery for films, etc.

identification of 11 port facilities subject to the ISPS Code