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.

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.

The Registry has also undertaken comparative studies in relation to the establishment of the permanent premises of the Court.

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.

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 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?

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.

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.

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.

Pijl, H. (2002). The concept of permanent establishment and the proposed Changes to the OECD commentary with special reference to Dutch case law. Bulletin (International Bureau of Fiscal Documentation, Amsterdam, pp. 554 562. November.

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

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,

The Committee commends the establishment of an Advisory Commission on Human Rights, a Complaints Office within the Permanent Special Commission against Racial Discrimination, advisory commissions for foreigners in the communes, and the appointment of an ombudsman.

While paragraph 6 of the OECD Commentary widens the scope of permanent establishment, care must be taken not to include measures so drastic that they could easily result in the amendments being rejected by the domestic courts.

It calls for two permanent seats, with the prerogatives and privileges of permanent membership, and five non permanent seats for Africa.

Strongly welcoming the successful conclusion of the agreement reached among various Afghan groups in Bonn, Germany, on 5 December 2001,Agreement on Provisional Arrangements in Afghanistan Pending the Re establishment of Permanent Government Institutions (see S 2001 1154).

2. Notes the establishment of a voluntary fund for the erection of a permanent memorial, expresses sincere appreciation to those Member States that have already made contributions to the fund, and invites other interested parties to do likewise

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. Even heads of state have not escaped these bodies.

We have consistently suggested an increase in permanent and non permanent seats.

(i) Two permanent seats and two non permanent seats for African States

(ii) Two permanent seats and one non permanent seat for Asian States

Permanent Representative

Permanent Representative

Permanent 644

Permanent 985

Permanent address

Permanent Representative

Permanent Representative

Permanent register

Permanent Representative

The establishment of the Permanent Forum on Indigenous Issues as a subsidiary organ of the Economic and Social Council and the two sessions held by the Forum to date represented progress towards compliance with the objectives of the Decade.

Asia would have two additional permanent seats and one additional non permanent seat.

(Signed) John Dauth Permanent Representative Permanent Mission of Australia to the United Nations

(Signed) Dan Gillerman Permanent Representative Permanent Mission of Israel to the United Nations