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.

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.

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 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.

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.

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.

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

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

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.

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

It should be noted, however, that the appeals stage will require a smaller establishment compared to the trial stage.

That would explain the sharp interest being shown in the issues of its composition, number of seats and categories permanent and non permanent of new membership.

In particular, treaties of cession and other treaties effecting permanent territorial dispositions create permanent rights.

Yet I was struck by how much more humane the facility and regime at Alcatraz were compared to Gitmo.

It is the largest sports facility by capacity in the state of Missouri.

A rivet is a permanent mechanical fastener.

Finding durable solutions to the problems of refugees

Austria as permanent neutral

In our view, the addition of six permanent and four non permanent seats strikes a proper balance between the demands for enhanced effectiveness and those for enhanced legitimacy.

Location The restaurant is located on the north bank of the Thames in Hammersmith, in the former Duckhams oil storage facility.

But it does not have to be that way.

The Iranian women's movement has always shown resistance...

There are 15 permanent commissions, or committees.

E. Redoubling the search for durable solutions

The Institute has a bureau and a permanent secretariat.

(d) Finding durable solutions to the problems of refugees

Modern economies rely not on monopolies, but on competition.

Expertise in an area such as the production of single cell protein would be required to ascertain whether a facility like Al Hakam fits its declared status and purpose by its design, construction, equipment, staffing and budget.

More recently, the regime proudly unveiled a modern, high tech uranium enrichment facility.

After her appearance, she entered a facility specializing in helping people with depression, and she decided to stop drinking.

A political union is a type of state which is composed of or created out of smaller states.

Located next to the university campus is a Technology Centre Hermia, including a large Nokia research facility.