Future of Profit Splits

In a highly integrated world where new technologies are disrupting the market, taxation and transfer pricing have gained a lot of attention because governments are seeking new ways to increase revenue collection. Although the application of the arm’s length standard is sometimes unpredictable, and its geographical approach may lead to stateless income, transfer pricing has proven to be an effective tool to protect a country’s tax base. Tax authorities and international organizations have tried to revise the transfer pricing framework through the BEPS project. However, until the new framework is settled, there is a need for an updated rational interpretation of the current methodologies to provide realistic options to allocate profits in a modern setting where multinational groups are centrally managed and intangibles are highly integrated. This Article provides such an interpretation and demonstratesits implementation with a realistic example.

Incremental Visual Occlusion During Split-Belt Treadmill Walking Has No Gradient Effect on Adaptation or Retention

Split-belt treadmills have become an increasingly popular means of quantifying ambulation adaptability. Multiple sensory feedback mechanisms, including vision, contribute to task execution and adaptation success. No studies have yet explored visual feedback effects on locomotor adaptability across a spectrum of available visual information. In this study, we sought to better understand the effects of visual information on locomotor adaptation and retention by directly comparing incremental levels of visual occlusion. Sixty healthy young adults completed a split-belt adaptation protocol, including a baseline, asymmetric walking condition (adapt), a symmetric walking condition (de-adapt), and another asymmetric walking condition (re-adapt). We randomly assigned participants into conditions with varied visual occlusion (i.e., complete and lower visual field occlusion, or normal vision). We captured kinematic data, and outcome measures included magnitude of asymmetry, spatial and temporal contributions to step length asymmetry, variability of the final adapted pattern, and magnitude of adaptation. We used repeated measures and four-way MANOVAs to examine the influence of visual occlusion and walking condition. Participants with complete, compared to lower visual field visual occlusion displayed less consistency in their walking pattern, evident via increased step length standard deviation ( p = .007, d = 0.89), and compared to normal vision groups ( p = .003 d = 0.81). We found no other group differences, indicating that varying levels of visual occlusion did not significantly affect locomotor adaptation or retention. This study offers insight into the role vision plays in locomotor adaptation and retention with clinical utility for improving variability in step control.

Morphometric and Meristic Analysis of Tor putitora (Hamilton Buchanan) from Ujh River, Kathua (J&K)

The morphology of fishes has been the major source of information for taxonomic and evolutionary studies. The present communication deals with the taxonomic analysis of Golden Mahseer- Tor putitora, collected from river Ujh, a tributary of Ravi in District Kathua, (Jammu & Kashmir). The morphological characters are generally divided into two major categories, the morphometric and the meristic. For morphometric studies the parameters considered were: the total length, standard length, head length, pre-dorsal length, pre-ventral length, pre-anal length, caudal length, snout length, eye diameter and maximum body depth. The growth of parameters were studied in relation to three independent variables, i.e., total length, standard length and the head length. Meristic counts of fin rays and fin spines etc. were also studied.

The Promise of Non-arm’s Length Practices: Is the Destination-Based Cash Flow Tax or Unitary Taxation the Panacea of Which Developing Countries Are in Search?

The issues developing countries face when implementing the arm’s length standard are well known. As a result, the time seems opportune for an alternative paradigm. The unitary taxation system has received considerable attention and comment over the last few years as such an alternative. Some have heralded it as the answer to the many problems brought about by the arm’s length standard. Moreover, some suggest that the destination-based cash flow taxation system is the panacea to the present problems in international tax arising from the prevailing approach to the taxation of global affiliated companies. This article tests whether the destination-based cash flow tax and unitary taxation system continue to hold promise when applied in an African context.

A Technology for Genetic Identification of Varieties and Wild Forms of Grapes Based on Multilocus Microsatellite Analysis

The genotyping technology has been developed based on 9 microsatellite loci (VVS2, VVMD5, VVMD7, VVMD27, VVMD28, VVMD25, VVMD32, VrZAG62, VrZAG79). It can be used for efficient, accurate and fast identification of grape varieties and forms (genus Vitis). The proposed approach includes a multiplex PCR of all loci followed by electrophoretic analysis of DNA fragments in one capillary of a genetic analyzer. The application of an additional length standard, an allelic ladder, consisting of all possible DNA fragments of the analyzed microsatellite loci, is one of the key features of the technology, which ensures the accuracy and reproducibility of the results. The advantage of the proposed technology is the ability to standardize and automate the procedure using 96-well plates, which opens up the possibility of conducting mass analyses. As a result of the study of varieties and forms of Vitis genus species, genetic passports were obtained, according to which a dendrogram was constructed, reflecting the genetic relationship of the studied samples. The developed technology makes it possible to distinguish varieties and wild forms of grapes; it can be used for their identification and determination of genetic distance between them, as well as for assessment of planting material and protection of breeders' rights. Vitis, grapes, microsatellites, SSR, genotyping, multiplex PCR, DNA fragment analysis The work was carried out within the framework of the state assignment on the topic "Development of New Technologies for Genetic Analysis of Forms of Agricultural Plants to Accelerate and Control the Selection Process" (project no. 0574-2019-0003).

Geodetic Activity for Compatibility of the Unit of Length of Geodetic Bases Koštice (Czech Republic) and Javoriv (Ukraine)

The paper deals with geodetic and metrological activities in the field of length parameter, on the basis of which the uniformity and accuracy of measurements and gauges are ensured also in international extent. The historical role of surveyors in determining the basic unit of length is briefly described. Furthermore, the impact of the application of the laser tracker on the accuracy of determination of the characteristics of the geodetic length standard Koštice (Czech Republic) is evaluated. Based on laboratory tests performed in VUGTK and interlaboratory comparative tests with a leading laboratory in the length parameter in Veisala (Finland), the declared uncertainties of measurement of the VUGTK laboratory were confirmed. These are applied in the metrological traceability of the geodetic length base in Javoriv (Ukraine).

Organosomatic indices and leukocyte formula of chub (Squalius cephalus L) from the Suturlija River

Coefficients of organs, along with haematological characteristics, represent an important means of monitoring the health and condition of fish. Organosomatic indices show the state of organ systems and individual organs. They manifest as changes in size, which are reflected through a decrease or increase, under the influence of environmental factors. Chub individuals from the Suturlija River were used for analysis. The paper analyses the Fulton's condition factor, heart, liver, and spleen coefficients as a condition factor. Furthermore, the values ​​of total length, standard length, and body weight were determined for all individuals. Also, certain haematological parameters were analysed in the paper: total leukocyte count and differential blood count. A total of 19 chubs caught from the Suturlija River were analysed. The obtained result of Fulton's condition factor (1.53) indicates favourable habitats for chub individuals in the Suturlija River. The results of organosomatic indices are without major variations between individuals (CSI = 0.184, SSI = 0.992, HSI = 0.133). The mean leukocyte count was 45.857x109/l, with the highest proportion of lymphocytes in the differential blood count.

On the Efficient Monitoring of Multivariate Processes with Unknown Parameters

Control charts are commonly used tools that deal with monitoring of process parameters in an efficient manner. Multivariate control charts are more practical and are of greater importance for timely detection of assignable causes in multiple quality characteristics. This study deals with multivariate memory control charts to address smaller shifts in process mean vector. By adopting a new homogeneous weighting scheme, we have designed an efficient structure for multivariate process monitoring. We have also investigated the effect of an estimated variance covariance matrix on the proposed chart by considering different numbers and sizes of subgroups. We have evaluated the performance of the newly proposed multivariate chart under different numbers of quality characteristics and varying sample sizes. The performance measures used in this study include average run length, standard deviation run length, extra quadratic loss, and relative average run length. The performance analysis revealed that the proposed control chart outperforms the usual scheme under both known and estimated parameters. An application of the study proposal is also presented using a data set related to Olympic archery, for the monitoring of the location of arrows over the concentric rings on the archery board.

A New Computational Model of Step Gauge Calibration Based on the Synthesis Technology of Multi-Path Laser Interferometers

A step gauge is a commonly used length standard for international comparison, and its calibration accuracy is often used as a sign to measure a country’s length Calibration and Measurement Capability (CMC). Based on this, some developed countries and developing countries all over the world have been carrying out the research of precision calibration technology for step gauge. On the basis of summarizing the current situation of step gauge calibration technology in other countries, this paper presents a new computational model of step gauge calibration based on the Synthesis Technology of Multi-Path Laser Interferometers (SMLI) and an auto-collimator, which can synthesize the three laser light paths into the measured centerline of step gauge. It is very important to obtain a good measurement accuracy for the step gauge, conformed to the Abbe principle, no matter where it is installed on the CMM measurement platform. In this paper, the development of the mathematical model, the data collection algorithms, data analysis techniques, and measurement uncertainty budgets are discussed. Finally, the experimental measurement is carried out and the measurement accuracy is verified to be effective. The results show that this method can effectively avoid the influence of Abbe error in length measurement, and significantly enhance the calibration accuracy of the step gauge.