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Value Creation and its effects on Transfer Pricing and tax law Emerging from the OECD/G20 BEPS Project, a new, somewhat fuzzy notion of Value Creation came to permeate not only Transfer Pricing language but also wider allocation rules and anti-abuse provisions in international tax law. The notion of ‘Value Creation’ reframes the interpretation and application of the Arm’s Length Principle (ALP) that is embedded in Articles 7 and 9 of the OECD Model Convention. This new Value Creation notion and approach assist in understanding key enterprise functions while different industry sectors manifest these concepts in various ways. Situating such notions and this approach within the law of tax...
Value Creation and its effects on Transfer Pricing and tax law Emerging from the OECD/G20 BEPS Project, a new, somewhat fuzzy notion of Value Creation came to permeate not only Transfer Pricing language but also wider allocation rules and anti-abuse provisions in international tax law. The notion of ‘Value Creation’ reframes the interpretation and application of the Arm’s Length Principle (ALP) that is embedded in Articles 7 and 9 of the OECD Model Convention. This new Value Creation notion and approach assist in understanding key enterprise functions while different industry sectors manifest these concepts in various ways. Situating such notions and this approach within the law of tax...
This book examines the role of experts and expertise in the dynamics of globalisation since the mid-nineteenth century. It shows how engineers, scientists and other experts have acted as globalising agents, providing many of the materials and institutional means for world economic and technical integration. Focusing on the study of international connections, Technology and Globalisation illustrates how expert practices have shaped the political economies of interacting countries, entire regions and the world economy. This title brings together a range of approaches and topics across different regions, transcending nationally-bounded historical narratives. Each chapter deals with a particular topic that places expert networks at the centre of the history of globalisation. The contributors concentrate on central themes including intellectual property rights, technology transfer, tropical science, energy production, large technological projects, technical standards and colonial infrastructures. Many also consider methodological, theoretical and conceptual issues.
Twelve years have passed since its last edition - making Antimicrobials in Foods, Third Edition the must-have resource for those interested in the latest information on food antimicrobials. During that time, complex issues regarding food preservation and safety have emerged. A dozen years ago, major outbreaks of Escherichia coli O157:H7 and Listeri
The power of a country to freely design its tax system is generally understood to be an integral feature of sovereignty. However, as an inevitable result of globalization and income mobility, one country’s exercise of tax sovereignty often overlaps, interferes with, or even impedes that of another. In this collection of essays, internationally respected practitioners and academics reveal how the OECD’s Base Erosion and Pro t Shifting (BEPS) initiative, although a major step in the right direction, is insuf cient to resolve the tax sovereignty paradox. Each contribution deals with different facets of a single topic: How tax sovereignty is shaped in a post ,BEPS world. The contributors pro...
The World Justice Project (WJP) joins efforts to produce reliable data on rule of law through the WJP Rule of Law Index 2016, the sixth report in an annual series, which measures rule of law based on the experiences and perceptions of the general public and in-country experts worldwide. We hope this annual publication, anchored in actual experiences, will help identify strengths and weaknesses in each country under review and encourage policy choices that strengthen the rule of law. The WJP Rule of Law Index 2016 presents a portrait of the rule of law in each country by providing scores and rankings organized around eights factors: constraints on government powers, absence of corruption, ope...
"The attribution of profits to permanent establishments (PEs) is probably one of the most complex subjects of the international tax arena. The interaction of treaty rules and domestic legislations sometimes leads to unacceptable results such as double taxation or double non-taxation. This book compares the tax treatment of cross-border dealings between different parts of the same enterprise in several countries."--Extracted from publisher website on June 29, 2016
Ethnobotany includes the traditional use of plants in different fields like medicine and agriculture. This book incorporates important studies based on ethnobotany of different geographic zones. The book covers medicinaland aromatic plants, ethnopharmacology, bioactive molecules, plants used in cancer, hypertension, disorders of the central nervous system, and also as antipsoriatic, antibacterial, antioxidant, antiurolithiatic. The book will be useful for a diverse group of readers including plant scientists, pharmacologists, clinicians, herbalists, natural therapy experts, chemists, microbiologists, NGOs and those who are interested in traditional therapies.