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The New Permanent Establishment
This work is the result of an extensive research into the permanent establishment concept, a concept that plays a vital role within the international taxation system through the fair allocation of taxing rights over cross-border business profits in the context of the tenuous balance between the residence and source principles, as a threshold for source taxation. Our research sought to explore and explain the evolution of this concept in the context of recent changes resulting from the joint work of the G20 and the OECD, namely under the aegis of the BEPS Project (Action 7), and later with the enactment of the Multilateral Instrument and the update to the OECD Model Convention. We also address the Portuguese permanent establishment concept and, finally, the future of the permanent establishment concept within the international taxation system.
Letramento
A obra reúne estudos desenvolvidos por pesquisadores nos campos de educação e saúde em diferentes instituições do país. O tema do letramento, que tem sido objeto de discussão tanto nos Parâmetros Nacionais Curriculares como em contextos clínicos, é abordado de maneira atual, constituindo um referencial teórico-prático para fonoaudiólogos, psicólogos, educadores, lingüistas, neurologistas e pediatras.
Jimmy Page in Brazil
immy Page is still recognized as one of the most influential guitarists of all time and one of the most important rock composers worldwide. And Page's relationship with Brazil is old: in addition to having starred in many meetings with national music stars, the Led Zeppelin guitarist spent seasons in Bahia and inaugurated Casa Jimmy to house homeless youth in the capital of Rio de Janeiro – which earns him the title of Honorary Citizen of Rio de Janeiro. This intense story is the theme of Jimmy Page in Brazil, a bilingual book (Portuguese / English) by journalist and musician Leandro Souto Maior. The book has a preface by Ed Motta, one of the greatest collectors and connoisseurs of Led Zeppelin's work in Brazil, and postscript by young guitarist Sebastião Reis, the son of musician Nando Reis, what confirms that the band has crossed generations. The layout and cover bear the signature of Tomás Paoni, the artistic director of the project. The cover photo is by Marcos Hermes, a great photographer in the Brazilian music market. The edition is signed by Chris Fuscaldo, director of Garota FM Books.
Creative Edge: Typography
This showcase represents a thrilling diversity of today's most imaginative and energetic type work, from book designs and logos to posters and CD-ROMs. In these examples, type does more than merely talk...it emotes, it surprises, it moves. Substantive captions and quotes from the designers illuminate the inspiration, concepts and techniques behind their work. Also included are specifics on costs, typefaces, special production techniques and more.
Handbook of Research on Improving Allied Health Professions Education: Advancing Clinical Training and Interdisciplinary Translational Research
Due to the current paradigm shift from traditional teaching to a mixed model with the inclusion of e-learning strategies, reforms in clinical education models are necessary and must carefully consider the socio-professional changes needed to support such efforts. Further study of the implementation of clinical and virtual reality education simulators in education, the irreplaceable role of teaching in the design of advanced roles for health professionals, and the role of education in the continuing professional development are all necessary for the future of successful allied health professional education. The Handbook of Research on Improving Allied Health Professions Education: Advancing Clinical Training and Interdisciplinary Translational Research discusses a range of important topics related to medical and health professions education and clarifies purposes, processes, and future priorities in introducing changes in the educational system. Covering topics such as new technologies and patient safety, this major reference work is ideal for researchers, practitioners, academicians, industry professionals, instructors, and students.
ECIE 2018 13th European Conference on Innovation and Entrepreneurship
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Industrial Engineering and Operations Management
This proceedings volume gathers together selected peer-reviewed papers presented at the second edition of the XXVI International Joint Conference on Industrial Engineering and Operations Management (IJCIEOM), which was virtually held on February 22-24, 2021 with the main organization based at the Pontifical Catholic University of Rio de Janeiro, Brazil. Works cover a range of topics in industrial engineering, including operations and process management, global operations, managerial economics, data science and stochastic optimization, logistics and supply chain management, quality management, product development, strategy and organizational engineering, knowledge and information management, sustainability, and disaster management, to name a few. These topics broadly involve fields like operations, manufacturing, industrial and production engineering, and management. This book can be a valuable resource for researchers and practitioners in optimization research, operations research, and correlated fields.
Active Learning in Graduate Education: listening, curiosity and love
How can we build another society, another country, another education, another university, if the masters and doctors we form attend countless courses that waste their curiosities and interests? Higher (and Graduate) education is still often medieval. Both in methods and in interpersonal relationships. The educational methods used in several Graduate courses are mostly based on the ‘transmission’ of knowledge and the treatment of students as ignorant beings: a banking education, as Freire already warned. This book results from a collective adventure that began in a course called Listening, curiosity, and love, taught from the Federal University of Rio de Janeiro, Brazil, in 2022, in an on...
Infâncias do Campo
Para refletir sobre as crianças e as infâncias do campo, é necessária uma abordagem que as apreenda em sua complexidade. Como as crianças residentes em territórios rurais vivem, brincam, estudam e compartilham experiências? O que elas nos dizem? Partindo dessas perguntas, os pesquisadores-autores deste livro produziram narrativas sobre a experiência de ser criança nos espaços/tempos de luta pela produção e reprodução da vida nos assentamentos, nas comunidades indígenas, nas regiões ribeirinhas. Este livro oferece aos leitores textos que reproduzem a voz e os gestos das crianças, os conteúdos de suas falas, suas reivindicações, seus encantamentos e desencantos com a vida e...
