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Courts and Tax Treaty Law
A detailed and comprehensive study of the issues faced by judiciaries when dealing with tax treaty law cases. It begins with an overview of some of the questions that domestic courts have to deal with when facing treaty cases. It then provides a comparative look into the structure of tax judiciaries and the issues raised by the burden of proof in cases dealing with the application of tax treaties. The different approaches of judiciaries of common law and civil law countries are also taken into consideration. A particular focus is devoted to the interaction between European law principles and bilateral tax treaties, both from the point of view of national judges and the Court of Justice of th...
Methods in Consumer Research, Volume 1
Methods for Consumer Research, Volume One: New Approaches to Classic Methods brings together world leading experts in global consumer research who provide a fully comprehensive state-of-the-art coverage of advances in the classical methods of consumer science. The book touches on the latest developments in qualitative techniques, including coverage of both focus groups and social media, while also focusing on liking, a fundamental principle of consumer science, consumer segmentation, and the influence of extrinsic product characteristics, such as packaging and presentation on consumer liking. In conjunction with the second volume, which covers alternative approaches and special applications,...
International Tax Planning and Prevention of Abuse
This study considers how tax authorities attempt to strike down international tax avoidance structures, in particular those involving the use of conduit and base companies set up by third-country residents for purposes of "treaty shopping" and "EC-Directive shopping". The book focuses on the interaction between provisions and judicially developed doctrines of domestic tax law preventing international tax avoidance on the one hand, and norms of international law, in particular tax treaties and rules of Community law, on the other. It also considers treaty-based anti-avoidance measures such as the "beneficial ownership" requirement and "limitation on benefits" provisions. This part of the study compares and analyses the case law of Australia, Austria, Belgium, Canada, the Czech Republic, Finland, France, Germany, India, the Netherlands, Switzerland, the United Kingdom, and the United States.
Optimization of Tax Sovereignty and Free Movement
The book argues that the notions of tax sovereignty and EU free movement should be regarded as two fundamentally equal principles. The conflict between these two principles is resolved by establishing, in individual cases, the optimum position between two extremes: a general unrestricted freedom of action by states versus a prohibition of any obstacle to the free movement of goods, persons, services and capital. The process of reconciliation of these competing principles is structured by the theoretical optimization model developed in the present study. This model is external to the present case law. The application of the theoretical optimization model to the ECJ’s case law in the area of...
Text Encoding Initiative
Charles F. Goldfarb Saratoga. California If asked for a sure recipe for chaos I would propose a I am delighted that my invention, the Standard project in which several thousand impassioned special Generalized Markup Language, was able to play a ists in scores of disciplines from a dozen or more role in the TEl's magnificent accomplishment, particu countries would be given five years to produce some larly because almost all of the original applications 1300 pages of guidelines for representing the informa of SGML were in the commercial and technological tion models of their specialties in a rigorous, machine realms. It is reasonable, of course, that organiza verifiable notation. Clearly, it w...
Wetlands of the World I: Inventory, Ecology and Management
The impetus for this volume was the 2nd International Wetlands Conference which was held in June, 1984 at Trebon, Czechoslovakia. An overview of the worlds wetlands was one of the themes of the conference and it was decided that a useful follow-up would be a publication on the same topic. The initial goal was to cover as many of the worlds wetlands as possible in one volume and to have an emphasis on wetland ecology, biota, classification, and management. Individuals who made presentations at the Trebon confer ence were asked to prepare chapters and the editors also solicited other contributions. For a variety of reasons, the initial goal has been difficult to reach, especially coverage of t...
Environment and Innovation
This book seeks to show the role of sustainability and innovation in the business and productive sector as good strategy to improve performance and contribute to growth and sustainable development through innovative strategies applied to the management process. Different public and private organizations seek to maintain their business and market share, while developing strategies to improve environmental performance through innovation and address new challenges that seek a productive sector responsible on environmental issues. This book offers an analysis of the relationship between sustainability and innovation in production with the aim to offer strategies to improve sustainability performance.
Delayed Project Terminations in the Venture Capital Context
Venture capital plays an important role in the entrepreneurial process of providing financing and management support to young, rapidly growing companies. While venture capital investment success stories such as those of Microsoft, Apple and Google are well known, such "home runs" are rather rare. Many investments provide little or no return so that accurately evaluating the prospects of portfolio companies and terminating further engagement in unsuccessful ventures in time is key to the overall portfolio performance of venture capital firms. When venture capitalists act rationally it should be expected that investment terminations are neither systematically premature nor systematically delay...
