Libros: "Permanent establishment"

1

How fixed is a permanent establishment? Alphen aan den Rijn, The Netherlands: Kluwer Law International, 2013.

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2

Skaar, Arvid Aage. Permanent establishment: Erosion of a tax treaty principle. Deventer: Kluwer Law and Taxation Publishers, 1991.

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3

Byler, James W. Establishment report: Permanent plots to evaluate the effects of Armillaria root disease in precommercially thinned stands. Missoula, Mont: United States Dept. of Agriculture, Forest Service, Northern Region, State & Private Forestry, 1985.

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4

Kegley, Sandy. Establishment report for dougls-fir [i.e. douglas-fir] tussock moth permanent plots on the Clearwater National Forest. Missoula, MT: USDA Forest Service, Northern Region, 2003.

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5

Williams, Robert L. Fundamentals of permanent establishments. The Hague, The Netherlands: Wolters Kluwer Law & Business, 2014.

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6

Dependent agents as permanent establishments. Wien: Linde, 2014.

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7

John, Huston. Permanent establishments: A planning primer. Deventer: Kluwer Law and Taxation Publishers, 1993.

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8

Hentschel, Sven. The Taxation of Permanent Establishments. Wiesbaden: Springer Fachmedien Wiesbaden, 2021. http://dx.doi.org/10.1007/978-3-658-34000-1.

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9

Watch, Human Rights. Afghanistan's Bonn Agreement one year later: A catalog of missed opportunities. New York: Human Rights Watch, 2002.

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10

Great Britain. Parliament. House of Commons. European Scrutiny Committee. Fourth report together with the proceedings of the Committee on January 2001: Documents considered by the Committee including: Community postal services(10544/00), Establishment of permanent CESDP bodies. London: Stationery Office, 2001.

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11

Larsen, Timothy J. The Chinese market for Colorado and U.S. agricultural exports: Analysis of the potential impacts of the establishment of permanent normal trade relations (PNTR) with China and Colorado's agricultural industry. [Denver, Colo.]: Colorado Department of Agriculture, Division of Markets, 2000.

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12

Plansky, Patrick y Florian Brugger. Permanent establishments in international and EU tax law. Wien: Linde, 2011.

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13

International taxation of permanent establishments: Principles and policy. Cambridge: Cambridge University Press, 2011.

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14

Congress, International Fiscal Association. The OECD model convention-1997 and beyond: Current problems of the permanent establishment definition : proceedings of a seminar held in new Delhi, in 1997 during the 51st Congress of the International Fiscal Association. The Hague: Kluwer Law International, 1999.

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15

Permanent establishments: A domestic taxation, bilateral tax treaty and OECD perspective. Alphen aan den Rijn, The Netherlands: Kluwer Law International, 2014.

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16

Permanent establishments: A domestic taxation, bilateral tax treaty and OECD perspective. 2^a ed. Alphen aan den Rijn, The Netherlands: Kluwer Law International, 2012.

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17

Reimer, Ekkehart, Stefan Schmid y Marianne Orell. Permanent establishments: A domestic taxation, bilateral tax treaty and OECD perspective. Alphen aan den Rijn, The Netherlands: Kluwer Law International, 2015.

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18

Ferreri, Mara. The Permanence of Temporary Urbanism. NL Amsterdam: Amsterdam University Press, 2021. http://dx.doi.org/10.5117/9789462984912.

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Temporary urbanism has become a distinctive feature of urban life after the 2008 global financial crisis. This book offers a critical exploration of its emergence and establishment as a seductive discourse and as an entangled field of practice encompassing architecture, visual and performative arts, urban regeneration policies and planning. Drawing on seven years of semi-ethnographic research, it explores the politics of temporariness from a situated analysis of neighbourhood transformation, media representations and wider political and cultural shifts in austerity London. Through a longitudinal engagement with projects and practitioners, the book tests the power of aesthetic and cultural interventions and highlights tensions between the promise of vacant space re-appropriation and its commodification. Against the normalisation of ephemerality, it presents a critique of the permanence of temporary urbanism as a glamorisation of the anticipatory politics of precarity which are transforming cities, subjectivities and imaginaries of urban action.

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19

Skaar, Arvid Aage. Permanent Establishment: Erosion of a Tax Treaty Principle. Kluwer Law International, 2020.

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20

Skaar, Arvid Aage. Permanent Establishment: Erosion of a Tax Treaty Principle. Kluwer Law International, 2020.

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21

Skaar, Arvid Aage. Permanent Establishment: Erosion of a Tax Treaty Principle. Kluwer Law International, 2020.

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22

BEPS – Transfer pricing and permanent establishment: A Government discussion document. Wellington, New Zealand: Policy and Strategy, Inland Revenue, New Zealand, 2017.

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23

Eileen, Denza. Establishment of Diplomatic Relations. Oxford University Press, 2016. http://dx.doi.org/10.1093/law/9780198703969.003.0004.

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This chapter analyses the Article 2 of the Vienna Convention on Diplomatic Relations which states that diplomatic relations, and of permanent diplomatic missions, takes place by mutual consent. It outlines the changes and development that led to the formation of the article. The International Law Commission traces the roots of the second article from a state’s right to legation, the right of sending a diplomatic mission to a foreign state. However, in order to determine whether an entity has the ‘right of legation’, it is necessary to determine whether or not it is a State. For most of the Parties of the Convention, the right to conduct diplomatic relations is generally regarded as flowing from recognition as a sovereign State. The chapter describes some instances where recognition plays an important factor in diplomacy, such as the status of Palestine and the Holy See.

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24

Preventing the Artificial Avoidance of Permanent Establishment Status, Action 7 - 2015 Final Report. OECD, 2015. http://dx.doi.org/10.1787/9789264241220-en.

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25

Craig, Paul y Gráinne de Búrca. 22. Freedom of Establishment and to Provide Services. Oxford University Press, 2015. http://dx.doi.org/10.1093/he/9780198714927.003.0022.

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All books in this flagship series contain carefully selected substantial extracts from key cases, legislation, and academic debate, providing able students with a stand-alone resource. The Treaty on the Functioning of the European Union (TFEU) has two separate chapters on self-employed persons who move on a permanent or temporary basis between Member States: the chapters on freedom of establishment and freedom to provide services. The central principles governing freedom of establishment and the free movement of services are laid down in the TFEU and have been developed through case law. Important developments have also been brought about through secondary legislation in sectors such as insurance, broadcasting, financial services, electronic commerce, telecommunications, and other ‘services of general economic interest’. This chapter focuses on the broad constitutional principles applicable to every sector.

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26

Manual for permanent research plot in Crocker Range Park: Plot establishment, tree census, monitoring and data analysis. Kota Kinabalu, Sabah: Research and Education Component, Bornean Biodiversity and Ecosystem Conservation Programme in Sabah, 2006.

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27

Long-term monitoring of biological diversity in tropical forest areas: Methods for establishment and inventory of permanent plots. Paris: Educational, Scientific and Cultural Organization, 1992.

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28

Agreement on provisional arrangements in Afghanistan pending the re-establishment of permanent government institutions and the 1964 constitution of Afghanistan. [Kabul: s.n., 2003.

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29

Permanent Establishment in the United States: A View Through Article V of the U.S.-Canada Tax Treaty (Vandeplas Publishing: Tax Law Series). Vandeplas Publishing, 2007.

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30

William A, Schabas. Part 1 Establishment of the Court: Institution de la Cour, Art.1 The Court/La Cour. Oxford University Press, 2016. http://dx.doi.org/10.1093/law/9780198739777.003.0003.

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This chapter comments on Article 1 of the Rome Statute of the International Criminal Court. Article 1 is a sixty-word digest of the salient features of the International Criminal Court. It establishes the Court as a permanent institution with the ‘power’ to exercise jurisdiction over the most serious crimes of international concern. It is to be complementary to national criminal jurisdictions. The provision has not been subject to any significant consideration in the case law of the Court. In a sense, it might well have been omitted from the Rome Statute, as it adds little or nothing in terms of legal consequences.

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31

Craig, Douglas B. y M. Kyle Woodson. Preclassic Hohokam. Editado por Barbara Mills y Severin Fowles. Oxford University Press, 2017. http://dx.doi.org/10.1093/oxfordhb/9780199978427.013.17.

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The establishment of the first permanent farming villages in the southern Southwest coincided with the emergence of the Hohokam cultural tradition. This chapter examines the environmental, demographic, and social processes that shaped the development of Hohokam culture. Special attention is paid to the timing and tempo of cultural change across the region. Three periods of rapid change are discussed—the first associated with the establishment of permanent villages (ca. 500 ce), the second associated with the spread of the ball court system (ca. 800 ce), and the third associated with the collapse of the ball court system (ca. 1050–1100 ce). The conditions that affected the operation and management of the largest irrigation works in pre-Hispanic North America are also discussed.

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32

The taxation of permanent establishments. Amsterdam, The Netherlands: IBFD Publications, 1993.

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33

Ivor, Roberts. Book II Diplomatic and Consular Relations, 5 Functions of Diplomatic Missions and Consulates. Oxford University Press, 2016. http://dx.doi.org/10.1093/law/9780198739104.003.0005.

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This chapter examines the functions of diplomatic missions and the performance of consular functions by diplomatic missions. Under long established principles of international law now codified in Article 2 of the Vienna Convention on Diplomatic Relations, the establishment of diplomatic relations between States and the establishment of permanent diplomatic missions take place by mutual consent. The right to send and receive diplomatic agents flows from recognition as a sovereign State and was formerly known as the right of legation (ius legationis). Furthermore, it is in modern practice highly exceptional for two States to recognize each other without formally establishing diplomatic relations—and such a situation usually indicates extreme tension or coolness between them. By contrast, it is now common for two States to establish or to maintain diplomatic relations without having permanent missions in each other’s territory.

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34

Attribution of Profits to Permanent Establishments. OECD Publishing, 2001. http://dx.doi.org/10.1787/9789264184527-en.

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35

Staff, International Fiscal Association. The OECD Model Convention-1997 and Beyond:Current Problems of the Permanent Establishment Definition : Proceedings Of A Seminar Held In New Delhi, In 1997 ... (Ifa Congress Seminar Series, 22a). Kluwer Law International, 1999.

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36

Rawal, Radhakishan. Taxation of Permanent Establishments: An International Perspective. Spiramus Press, 2010.

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37

Rawal, Radhakishan. The Taxation of Permanent Establishments: An International Perspective. 2^a ed. Spiramus, 2006.

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38

Organisation for Economic Co-operation and Development., ed. Model tax convention: Attribution of income to permanent establishments. Paris: Organisation for Economic Co-operation and Development, 1994.

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39

Dominy, Graham. Establishing an Imperial Presence. University of Illinois Press, 2017. http://dx.doi.org/10.5406/illinois/9780252040047.003.0003.

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This chapter examines the circumstances under which British troops were initially deployed in Natal and the factors that led to the establishment of a permanent presence. To this end, the chapter describes the events preceding the arrival of a British column at Port of Natal in 1842. The first phase of British military involvement took place on the coast at Natal, or Durban, between 1842 and 1843. Thereafter the scene shifts to Pietermaritzburg, where the garrison established a fort in September 1843. The chapter discusses the military clashes at Natal in May and June 1842 between the British Army and the rebellious Trekkers. It also considers the diplomacy involved in trying to settle the issue of British control over Natal, the Trekker women's revolt against British rule, and the garrison's march on Maritzburg in 1843.

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40

Henning, C. Randall. New Facilities and Institutions. Oxford University Press, 2017. http://dx.doi.org/10.1093/oso/9780198801801.003.0009.

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As the crisis evolved, euro-area governments first constructed two transitional financial facilities and then created a permanent fund. This chapter reviews the creation of the financial facilities of the euro area culminating in the establishment of the European Stability Mechanism. The ESM treaty contains a strong presumption, but not a strict legal requirement, that the International Monetary Fund (IMF) will also be involved in assistance to a member state. As a political matter, the Fund’s involvement is strongly favored in creditor countries of the euro area. The emergence of the ESM, a new institutional player in crisis finance, prompted a reconsideration of the institutional arrangements under which crisis programs are designed. The chapter reviews proposals from research institutes and the European Parliament to combine resources of the European Commission and the ESM into a European Monetary Fund.

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41

Raffaele, Russo, ed. The attribution of profits to permanent establishments: The taxation of intra-company dealings. Amsterdam, The Netherlands: IBFD, 2005.

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42

Epstein, Ben. Introduction. Oxford University Press, 2018. http://dx.doi.org/10.1093/oso/9780190698980.003.0001.

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This introduction serves several important goals. It lays out both the research objective and theoretical framework placing this study on an interdisciplinary foundation that combines work from political science, American political development, mass communication, history, and diffusion studies. It introduces the core concepts of the book, concentrated around a recurring multistage process called the political communication cycle (PCC). The three stages of the PCC, detailed in the following chapters, include the information and communications technology (ICT)–focused technological imperative phase; the political choice phase, which emphasizes the behavioral process central to innovation; and stabilization through the establishment of new norms, regulations, and institutions. This process has repeated throughout history, where long periods of relative stability, known as political communication orders (PCOs), are disrupted by shorter periods of permanent change, identified as political communication revolutions (PCRs). The introduction concludes by introducing the three claims that are used throughout the book and outlining the chapters that follow.

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43

Organization for Economic Co-operation and Development. Model Tax Convention: Attribution of Income to Permanent Establishments (Issues in International Taxation, No 5). Organization for Economic, 1994.

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44

Howard M, Holtzmann y Kristjánsdóttir Edda, eds. International Mass Claims Processes. Oxford University Press, 2007. http://dx.doi.org/10.1093/acprof:oso/9780199207442.001.0001.

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This book analyzes a significant procedural innovation in international law — the development of mass claims processes. Mass claims processes have become increasingly important phenomena in international dispute resolution. This is the first book to provide comprehensive information for a systematic comparison and analysis of the legal issues and practical matters involved in their establishment and operation. This book considers eleven of the highest profile modern mass claims tribunals and commissions created to redress large-scale losses. These include processes resolving claims arising from the Iranian Revolution, Iraq’s invasion of Kuwait, the Holocaust, and conflicts in the Former Yugoslavia and between Eritrea and Ethiopia. The book identifies and focuses on forty-seven basic issues that experience shows typically arise with respect to international mass claims processes, offering descriptions and commentary on the ways in which the various processes have approached each issue. Much of the information gathered in this book is not publicly available elsewhere and is based on the knowledge and experience of the 25 members of the Permanent Court of Arbitration’s Steering Committee on mass claims processes, experts who have either served on the processes or otherwise been directly engaged in their activities.

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45

Memorandum on behalf of the shareholders of the Grand Trunk Railway Company of Canada: Setting forth the basis of the scheme of financial assistance, which it is proposed should be granted by the government and legislature for the relief of the enterprise, for the re-establishment of its commercial credit, and to secure the permanent prosperity of the provinces. [Toronto?: s.n., 1985.

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46

Caserta, Salvatore. International Courts in Latin America and the Caribbean. Oxford University Press, 2020. http://dx.doi.org/10.1093/oso/9780198867999.001.0001.

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The book provides the first in-depth and empirically grounded analysis on the foundations and trajectories of gaining authority of the four Latin American and Caribbean regional economic courts: the Central American Court of Justice (CACJ), the Caribbean Court of Justice (CCJ), the Andean Tribunal of Justice (ATJ), and the Mercosur Permanent Review Court (PRC). While these courts were, on their terms, established to build common markets and to enforce trade liberalization, they have often developed bodies of jurisprudence in domains often not directly associated with regional economic integration. The CCJ has been most successful in the area of human and fundamental rights; the CACJ has addressed issues related to the enforcement of the rule of law in national legal arenas and long-standing border disputes between the countries of the region; the ATJ is an island of effective adjudication on intellectual property issues; and the PRC has significantly struggled to receive a significant number of cases to rule upon all together. The particular trajectories of the four Latin American and Caribbean Regional Economic Courts (RECs) suggest that there is no universal formula for success for these institutions and that their operational path is not necessarily a function of their formally delegated competences and/or of the will of the Member States, as it is often argued in mainstream legal and political science literature. Rather, local socio-political contextual factors—such as the historical legacies of a region, the interests and dynamics of socialization of legally and politically situated actors, the nature of national and regional politics, and legal culture—often play a far more decisive role in influencing the direction of RECs during and after their establishment.

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47

Principles for the Determination of the Income and Capital of Permanent Establishments and Their Applications to Banks, Insurance Companies and Other Financial ... (Cahiers De Droit Fiscal International). Springer, 1996.

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48

Eileen, Denza. Offices away from the Seat of the Mission. Oxford University Press, 2016. http://dx.doi.org/10.1093/law/9780198703969.003.0013.

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This chapter examines Article 12 of the Vienna Convention on Diplomatic Relations which refers to the establishment of offices away from the seat of the diplomatic mission. Article 12 states that the members of the sending State may not establish offices forming part of the mission in the localities other than those where the mission itself is established without prior express consent. The Article traces its roots from the general practice of missions being established in the seat of government of the receiving State and to follow that government if it moved either permanently or to a summer residence. However, there are exceptions to this. One example would be in China when between 1927 and 1937; many of the missions remained in Peking although the Government had moved to Nanking. In making the Article, the members of the International Law Commission stressed the difficulty for the receiving State in ensuring privileges and immunities away from the seat of government and to prevent abuses.

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49

Grint, Keith. Mutiny and Leadership. Oxford University Press, 2021. http://dx.doi.org/10.1093/oso/9780192893345.001.0001.

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Mutiny is often associated with the occasional mis-leadership of the masses by politically inspired hotheads or a spontaneous and unusually romantic gesture of defiance against a uniquely overbearing military superior. In reality it is seldom either, and usually it has far more mundane roots, not in the absolute poverty of the subordinates but in the relative poverty of the relationships between leaders and led in a military situation. Using contemporary leadership theory to cast a critical light on an array of mutinies across time and space, this book suggests we consider mutiny as a permanent possibility that is further encouraged or discouraged by particular contexts. What turns discontent into mutiny, however, lies in the leadership skills of a small number of leaders, and what transforms that into a constructive dialogue or a catastrophic disaster depends on how the leaders of both sides mobilize their supporters and their networks. From mutinies in ancient Roman and Greek armies through those that were generated by uncaring European monarchs and those that toppled the German and Russian states—and those that forced governments to face their own disastrous policies and changed them forever—this book covers an array of cases across land, sea, and air that still pose a threat to military establishments today.

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50

Szewczyk, Janusz. Rola zaburzeń w kształtowaniu struktury i dynamiki naturalnych lasów bukowo-jodłowo-świerkowych w Karpatach Zachodnich. Publishing House of the University of Agriculture in Krakow, 2018. http://dx.doi.org/10.15576/978-83-66602-35-9.

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The aim of the study was to determine the influence of different disturbances (both natural and anthropogenic) on species composition and stand structure of old-growth mixed mountain forests in the Western Carpathians. These stands are usually dominated by beech, fir and spruce, mixed in different proportions. The tree main species represent different growth strategies, and they compete against each other. The longevity of trees makes the factors influencing the stand structure difficult to identify, even during longitudinal studies conducted on permanent research plots. That is why dendroecological techniques, based upon the annual variability of tree rings, are commonly used to analyze the disturbance histories of old-growth stands. Dendroecological methods make it possible to reconstruct the stand history over several centuries in the past by analyzing the frequency, intensity, duration and spatial scale of disturbances causing the death of trees. Combining the dendroecological techniques with the detailed measurements of stand structure, snag volume, CWD volume, and the analyses of regeneration species composition and structure allows us to identify the factors responsible for the changes in dynamics of mixed mountain forests. Various disturbance agents affect some species selectively, while some disturbances promote the establishment of tree seedlings of specific species by modifying environmental conditions. Describing the disturbance regime requires a broad scope of data on stand structure, on dead wood and tree regeneration, while various factors affecting all the stages of tree growth should be taken into consideration. On the basis of the already published data from permanent sample plots, combined with the available disturbance history analyses from the Western Carpathians, three research hypotheses were formulated. 1. The species composition of mixed mountain forests has been changing for at least several decades. These directional changes are the consequence of simultaneous conifer species decline and expansion of beech. 2. The observed changes in species composition of mixed mountain forests are the effect of indirect anthropogenic influences, significantly changing tree growth conditions also in the forests that are usually considered natural or near-natural. Cumulative impact of these indirect influences leads to the decrease of fir share in the tree layer (spruce decline has also been observed recently),and it limits the representation of this species among seedlings and saplings. The final effect is the decrease of fir and spruce share in the forest stands. 3. Small disturbances, killing single trees or small groups of trees, and infrequent disturbances of medium size and intensity dominate the disturbance regime in mixed mountain forests. The present structure of beech-fir-spruce forests is shaped both by complex disturbance regime and indirect anthropogenic influences. The data were gathered in permanent sample plots in strictly protected areas of Babia Góra, Gorce, and Tatra National Parks, situated in the Western Carpathians. All plots were located in the old-growth forest stands representing Carpathian beech forest community. The results of the measurements of trees, snags, coarse woody debris (CWD) and tree regeneration were used for detailed description of changes in the species composition and structure of tree stands. Tree ring widths derived from increment cores were used to reconstruct the historical changes in tree growth trends of all main tree species, as well as the stand disturbance history within the past two to three hundred years. The analyses revealed complex disturbance history in all of the three forest stands. Intermediate disturbances of variable intensity occurred, frequently separated by the periods of low tree mortality lasting from several decades up to over one hundred years. The intervals between the disturbances were significantly shorter than the expected length of forest developmental cycle, in commonly used theories describing the dynamics of old-growth stands. During intermediate disturbances up to several dozen percent of canopy trees were killed. There were no signs of stand-replacing disturbances, killing all or nearly all of canopy trees. The periods of intense tree mortality were followed by subsequent periods of increased sapling recruitment. Variability in disturbance intensity is one of the mechanisms promoting the coexistence of beech and conifer species in mixed forests. The recruitment of conifer saplings depended on the presence of larger gaps, resulting from intermediate disturbances, while beech was more successful in the periods of low mortality. However, in the last few decades, beech seems to benefit from the period of intense fir mortality. This change results from the influence of long-term anthropogenic disturbances, affecting natural mechanisms that maintain the coexistence of different tree species and change natural disturbance regimes. Indirect anthropogenic influence on tree growth was clearly visible in the gradual decrease of fir increments in the twentieth century, resulting from the high level of air pollution in Europe. Synchronous decreases of fir tree rings’ widths were observed in all three of the sample plots, but the final outcomes depended on the fir age. In most cases, the damage to the foliage limited the competitive abilities of fir, but it did not cause a widespread increase in tree mortality, except for the oldest firs in the BGNP (Babia Góra National Park) plot. BGNP is located in the proximity of industrial agglomeration of Upper Silesia, and it could be exposed to higher level of air pollution than the other two plots. High level of fir regeneration browsing due to the deer overabundance and insufficient number of predators is the second clear indication of the indirect anthropogenic influence on mixed mountain forests. Game impact on fir regeneration is the most pronounced in Babia Góra forests, where fir was almost completely eliminated from the saplings. Deer browsing seems to be the main factor responsible for limiting the number of fir saplings and young fir trees, while the representation of fir among seedlings is high. The experiments conducted in fenced plots located in the mixed forests in BGNP proved that fir and sycamore were the most preferred by deer species among seedlings and saplings. In GNP (Gorce National Park) and TNP (Tatra National Park), the changes in species composition of tree regeneration are similar, but single firs or even small groups of firs are present among saplings. It seems that all of the analysed mixed beech-fir-spruce forests undergo directional changes, causing a systematic decrease in fir representation, and the expansion of beech. This tendency results from the indirect anthropogenic impact, past and present. Fir regeneration decline, alongside with the high level of spruce trees’ mortality in recent years, may lead to a significant decrease in conifers representation in the near future, and to the expansion of beech forests at the cost of mixed ones.

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Libros sobre el tema "Permanent establishment"

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