scholarly journals The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS—Some Thoughts on Complexity and Uncertainty

2018 ◽  
Vol 2018 (1) ◽  
pp. 31-48 ◽  
Author(s):  
David Kleist

Abstract The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI), which was signed in June 2017, raises a multitude of questions relating not only to the text of the treaty provisions but also to the way the MLI will interact with tax treaties, for instance, and what it will mean for the future development of tax treaty law and international cooperation in tax matters. This article focuses on two aspects of the MLI. First, it deals with the substance of the MLI by providing an overview of its background and content, including the many options available to the contracting states under the MLI. Second, some thoughts are presented on the effects of the MLI in terms of complexity and uncertainty.

2018 ◽  
Vol 31 (02) ◽  
pp. 133-137
Author(s):  
Yossi Tagori

SummaryThis article concerns an interview with Roger van Zandvoort, author of ‘Complete Repertory and Dynamic Repertory’. In some parts, it is referring to an article I published in Vol. 2, 2017, of Homeopathic Link ‘Call for a New Concept of Homeopathic Software’. The parts concerned are those dealing with the future development of the homeopathic software, and especially the possibility to have in future software that will enable colleagues worldwide to share their data and the way these data can contribute to future repertories.


Author(s):  
John R. Beard ◽  
Anne Margriet Pot ◽  
Geeske Peeters

Population ageing presents both opportunities and challenges to societies and governments. While even today, the economic contribution of older people is likely to outweigh the expenditure on them by governments, this balance could be even more positive in the future. Yet, outdated stereotypes of ageing are pervasive and limit the way older people are viewed and the way policy is framed. Moving forward will require a broader understanding of the diversity of older populations, the inequities that underpin it, and of the many and varied opportunities for societal responses that can enable the abilities of older people. What population ageing ultimately implies for societies and governments will therefore depend as much on societal attitudes and response as it will on the intrinsic capacities and needs of older populations.


2012 ◽  
Vol 53 (3) ◽  
pp. 20-24 ◽  
Author(s):  
Georg Sorge

Angesichts der zunehmenden Bedeutung von Dienstleistungen als Wirtschaftsfaktor – bei wachsender Industrialisierung und Globalisierung – steigt auch die Bedeutung des Einkaufs von Dienstleistungen. Das vorliegende Werk schlägt dabei einen Bogen von der Entstehung der Dienstleistungen bis hin zur zukünftigen Entwicklung der Dienstleistungsbranche. Worin insbesondere die Potenziale und Risiken im Dienstleistungseinkauf liegen, wird an Beispielen wie der Implementierung eines Risikomanagements, der Bündelung von Gütern und Dienstleistungen sowie der Bildung von Kooperationen und Netzwerken dargestellt. Die Facetten der Dienstleistungen reichen dabei von der Ergänzung zum Kerngeschäft (Services) über das Angebot reiner Dienstleistungen bis hin zum Dienstleistungsmarketing. In view of the increasing significance of services as an economic factor – along with increasing industrialisation and globalisation – the purchasing of services is also increasing in importance. This work starts with the origins of services and goes all the way to the future development of the services sector. The particular potentials and risks involved in purchasing services are shown by examples such as the implementation of risk management, the bundling of products and services, and building co-operation and networks. The different aspects of services range from those which complement the core business, to those where only services are provided, to the marketing of services. Keywords: risikomanagement, netzwerke, maverick buying, marktrecherchen, kostenrecherchen, after sales gewinn


2013 ◽  
Vol 750-752 ◽  
pp. 583-586 ◽  
Author(s):  
Xiao Jie Song ◽  
Quan An Li ◽  
San Ling Fu ◽  
Wen Jian Liu ◽  
Zhi Chen

Magnesium alloys as the emerging commercial metal structure material have excellent specific properties and stability, which is more and more vital for researcher. This paper reviews the creep characteristics and the way to enhance the elevated temperature properties of Mg-Al based alloys. The current Mg-Al based alloys (including AZ, AM, AS, AE, etc.) are summarized. The future development direction is pointed.


2010 ◽  
Vol 2 (3-4) ◽  
pp. 237-244 ◽  
Author(s):  
André Vander Vorst ◽  
Thomas J. Brazil ◽  
Peter J.B. Clarricoats ◽  
Fred E. Gardiol ◽  
Leo P. Ligthart ◽  
...  

This paper describes some key points in the history and development of the European Microwave Conference, the European Microwave Week, and the European Microwave Association, starting from 1969. It captures the way in which the conference since the earliest days has sought to create a successful blend of scientific and industry interests and has adapted itself to and indeed shaped the many existing technical changes that have characterized and continue to be at the core of the field of microwave engineering.


2012 ◽  
Vol 178-181 ◽  
pp. 2829-2833 ◽  
Author(s):  
Ze Fei Tan ◽  
Gang Ping Tan

The study of sound quality which is a newly developed research area has become a hot topic and become to attract increasing attention from academia and industries. The description of sound quality, the technique of subjective and objective evaluation, and the way of improving sound quality inside vehicle are outlined. Based on an extensive discussion over the sound quality issues, the progress in sound quality methodologies and evaluation method are reviewed, and the prospects of the future development are introduced and discussed.


Author(s):  
Charles S. Bullock ◽  
Susan A. MacManus ◽  
Jeremy D. Mayer ◽  
Mark J. Rozell

The concluding chapter summarizes key findings of the volume and points the way toward areas of future research and analysis of southern politics. It offers some projections about the future of the region, including its potentially key role in the 2020 elections. The discussion covers the many areas in which change is occurring, including changing demographics, changing partisanship, changing politics of race, and changing politics of religion, all leading up to a discussion of the changing politics of the Trump Era. In its final words, the chapter concludes that the direction of U.S. national politics and governing will continue to be driven substantially by what happens in the South.


2021 ◽  
pp. 251512742110068
Author(s):  
Karen Ford-Eickhoff ◽  
Aaron Cress

Aaron, a young entrepreneur, was striving to establish a self-funded business that combined his love of photography with the ability to earn a living while doing what he enjoyed. Aaron’s journey was filled with many high points, low points, and major detours as he simultaneously navigated starting a business, earning an undergraduate degree, and marrying a Chinese woman whose visa was about to expire. Aaron’s experience illustrated the many challenges young entrepreneurs may encounter and must then conquer. Covering a decade of Aaron’s life, from age 19 to 29, his story particularly focused on the opportunities as well as the challenges that arose along the way. Aaron’s experiences exemplified the need for entrepreneurial risk-taking, creativity, and ability to bounce back when adversity struck. Concluding with several possible paths along which his journey may take him in the future, the case sets the stage for readers to evaluate the options and decide what they think Aaron should do.


2022 ◽  
Vol 16 (3) ◽  
pp. 1-32
Author(s):  
Junchen Jin ◽  
Mark Heimann ◽  
Di Jin ◽  
Danai Koutra

While most network embedding techniques model the proximity between nodes in a network, recently there has been significant interest in structural embeddings that are based on node equivalences , a notion rooted in sociology: equivalences or positions are collections of nodes that have similar roles—i.e., similar functions, ties or interactions with nodes in other positions—irrespective of their distance or reachability in the network. Unlike the proximity-based methods that are rigorously evaluated in the literature, the evaluation of structural embeddings is less mature. It relies on small synthetic or real networks with labels that are not perfectly defined, and its connection to sociological equivalences has hitherto been vague and tenuous. With new node embedding methods being developed at a breakneck pace, proper evaluation, and systematic characterization of existing approaches will be essential to progress. To fill in this gap, we set out to understand what types of equivalences structural embeddings capture. We are the first to contribute rigorous intrinsic and extrinsic evaluation methodology for structural embeddings, along with carefully-designed, diverse datasets of varying sizes. We observe a number of different evaluation variables that can lead to different results (e.g., choice of similarity measure, classifier, and label definitions). We find that degree distributions within nodes’ local neighborhoods can lead to simple yet effective baselines in their own right and guide the future development of structural embedding. We hope that our findings can influence the design of further node embedding methods and also pave the way for more comprehensive and fair evaluation of structural embedding methods.


2019 ◽  
Vol 197 (1) ◽  
pp. 8-24
Author(s):  
Rhys Jones

Recent contributions in Geography and beyond have examined historical and more contemporary efforts to govern the future. Work in this area has highlighted some important conceptual considerations by drawing attention to the way in which states, regions and other organisations view the future as an object of governance for a variety of reasons: as something that constitutes a threat that needs to be managed; as something that can be predicted, thus leading to an improvement in governance; as something that allows a more hopeful and just society, economy and environment to be expressed (and achieved). In this paper, I use this context as a way of making an argument for the need to: 1) consider more explicitly the many geographies associated with governing the future; and 2) explore how these geographies might impact on the definition and promotion of spatial justice. I illustrate these arguments through an empirical discussion of the development and implementation of Wales’ Well-being of Future Generations Act, an Act that seeks to create a better and more just Wales by the year 2050. I conclude by exhorting geographers to take the lead in exploring the impact that geographical themes might have on states’ and regions’ attempts to achieve spatial justice in the present and the future.


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