bluuebunny/crossref_metadata_2025 huggingface dataset:
History for the Future
Authors: MacCormack Ian
Published: December 2023

This article translates and interprets several stanzas of poetry from the Cuckoo’s Song (Dpyid kyi rgyal mo’i glu dbyangs), the 1643 political history of Tibet authored by the fifth Dalai Lama Ngawang Losang Gyatso. It focuses in particular on the words this work uses to reflect poetically on its own documentary and literary qualities, and hence on the relationship between its political subject matter and aesthetic manner of expression. The article argues that any broader assessment of the Cuckoo’s Song with respect to the immediate sociopolitical context of the nascent Ganden Phodrang regime should heed the ways in which this work self-consciously articulates the purpose and necessity of speaking history eloquently. Looking especially to the self-referential opening verses, it will be suggested that the Cuckoo’s Song portrays literary historiography as an intrinsically political act and politics as a necessarily aestheticized pursuit. What is ultimately at stake in this idea of history is the relationship between authorship and kingship as mutually constituting, world-ordering powers.
རྩོམ་ཡིག་འདིར་རྒྱལ་དབང་སྐུ་ཕྲེང་ལྔ་པ་ངག་དབང་བློ་བཟང་རྒྱ་མཚོ་(༡༦༡༧-༡༦༨༢)མཆོག་གིས་༡༦༤༣ ལོར་མཛད་པའི་བོད་ཀྱི་ལོ་རྒྱུས་དཔྱིད་ཀྱི་རྒྱལ་མོའི་གླུ་དབྱངས་ལས་ཤོ་ལོ་ཀ་འགའ་བསྒྱུར་འགྲེལ་དང་། བརྩམས་ཆོས་འདིར་སྙན་ངག་གི་ལམ་ནས་དེབ་ཀྱི་དངོས་ཡོད་ནང་དོན་མཚོན་པར་སྦྱར་གནང་པའི་ཐ་སྙད་དག་དང་ཡི་གེའི་སྦྱོར་བའི་ཁྱད་ཆོས་ཁག  ལོ་རྒྱུས་ཀྱི་བརྗོད་བྱ་དང་དེ་མཚོན་ཐབས་ཀྱི་མཛེས་དཔྱོད་བྱེད་སྟངས་བར་གྱི་འབྲེལ་བ་བཅས་རྩལ་འདོན་བྱེད་པ། གཞན་ཡང་དགའ་ལྡན་ཕོ་བྲང་གི་གཞུང་གསར་པ་དང་འབྲེལ་ནས་དཔྱིད་ཀྱི་རྒྱལ་མོའི་གླུ་དབྱངས་ལ་དཔྱད་བརྗོད་ཞིབ་རྒྱས་གང་འདྲ་ཞིག་བྱེད་རུང་བརྩམས་ཆོས་འདིས་ལོ་རྒྱུས་སྙན་འཇེབས་ལྡན་ཞིང་ལྷུག་པོར་སྨྲ་དགོས་པའི་དགོས་པ་དང་གལ་གནད་སྐོར་ཇི་ལྟར་བསྟན་ཡོད་པར་དོ་སྣང་བྱེད་དགོས་པ་དང་། རང་ཕྱོགས་ལ་མཆོད་པར་བརྗོད་པའི་འགོ་བརྗོད་ཀྱི་ཚིགས་བཅད་དག་གིས་ཡིག་ཐོག་གི་ལོ་རྒྱུས་རིག་པ་ནི་ངོ་བོའི་ཆ་ནས་སྲིད་དོན་གྱི་བྱ་སྤྱོད་ཅིག་དང་སྲིད་དོན་ནི་མེད་དུ་མི་རུང་བའི་དགེ་བའི་བྱ་སྤྱོད་ཅིག་ཏུ་བརྩི་དགོས་པར་བསྟན་ལ། མཐའ་དོན་ལོ་རྒྱུས་ཀྱི་བསམ་བློ་འདིས་གང་ཞིག་ཁེ་ཉེན་ལ་གཏད་ཡོད་ཅེ་ན། འཇིག་རྟེན་ལ་དབང་སྒྱུར་བའི་སྟོབས་ཤུགས་དག་སྟེ། རྒྱལ་པོའི་དབང་ལུང་དང་རྩོམ་པ་པོ་གནས་བབས་གཉིས་དབར་གྱི་འབྲེལ་བ་དེ་ཡིན་པ་བཅས་ར་སྤྲོད་བྱེད་པ་ཡིན།།
The Origins of the Dzogchen Eleven Words and Meanings
Authors: Yeshi Khenpo
Published: December 2023

The purpose of this paper is threefold: to provide a historical overview of Dzogpa Chenpo (rdzogs pa chen po), commonly referred to as the Great Perfection; to translate and interpret Nyima Bum’s (Nyi ma ’bum, 1158-1213) seminal work, his “Introduction” to the Great Perfection: Eleven Words and Meanings (rdzogs pa chen po tshig don bcu gcig pa); and to analyze its impact on later Dzogchen thinkers like Longchen Rabjam (Klong chen rab ’byams, 1308-1364) and Rikzin Gödemchen (Rig ’dzin rGod ldem can, 1337-1408). This paper aims to contribute to the broader understanding of Buddhist literature, with a specific focus on the Dzogchen Nyingthik (Heart Essence) tradition. Dzogchen remains a relatively untapped field of academic study, and this paper aims to illuminate its early development, enriching contemporary understanding among both scholars and practitioners.
རྩོམ་ཡིག་འདི་ལ་དགོས་དོན་གསུམ་ཡོད། རྒྱུན་ལྡན་རྫོགས་ཆེན་དུ་འབོད་པའི་རྫོགས་པ་ཆེན་པོ་ཡི་ལོ་རྒྱུས་སྤྱི་བཤད་བྱ་རྒྱུ་དང་། ཉི་མ་འབུམ་(༡༡༥༨-༡༢༡༣)གྱི་གསུང་གི་རྩ་བ་སྟེ་རྫོགས་ཆེན་ངོ་སྤྲོད་དང་རྫོགས་པ་ཆེན་པོ་ཚིག་དོན་བཅུ་གཅིག་པ་བསྒྱུར་འགྲེལ། དེ་ཡིས་ཕྱིས་ཀྱི་རྫོགས་ཆེན་པ་ཀློང་ཆེན་རབ་འབྱམས་པ་(༡༣༠༨-༡༣༦༤)དང་རིག་འཛིན་རྒོད་ལྡེམ་(༡༣༣༧-༡༤༠༨)ལྟ་བུར་ཤུགས་རྐྱེན་ཅི་འཐེབས་ལ་དཔྱད་ཞིབ། དེ་ནས་རྫོགས་ཆེན་སྙིང་ཐིག་གི་ཕྱག་སྲོལ་གཙོར་བཟུང་གིས་སངས་རྒྱས་པའི་རྩོམ་རིགས་ཀྱི་དོན་རྒྱ་ཆེར་རྟོགས་པར་བྱ་རྒྱུ་དང་། ལྟོས་བཅས་ཀྱིས་རྫོགས་ཆེན་གྱི་གཞུང་རྣམས་ཡོངས་གྲགས་ཀྱི་སློབ་གཉེར་བྱ་ཡུལ་དུ་མ་གྱུར་བར་སོང་། རྩོམ་ཡིག་འདིས་མཁས་པ་དང་ཉམས་ལེན་པ་རྣམས་ལ་གཞུང་འདིའི་ཐོག་མའི་འཕེལ་རིམ་དང་དེང་དུས་གོ་རྟོགས་ཆེ་རུ་འགྲོ་བའི་སྐོར་གསལ་བྱེད་བྱེད་པ་བཅས་སུ་དམིགས་ཡོད།
The Effectiveness of Aloevera Compress on Changes in Breast Swelling of Breastfeeding Women in the Working Area of the Srengat Health Center
Authors: Fransiska Septiana  , Dwi Lukmawati  , Neta Ayu Andera  , Ratna Mildawati
Published: December 2023

Breast swelling occurs in mothers who have given birth for the first time. Significant breast care can affect the smoothness of breast milk. Breast swelling pain that is not followed up can lead to further complications. Aloevera has many ingredients that are believed to reduce pain and swelling in the breast because it contains aloin and emodin. The purpose of the study was to determine the effectiveness of aloevera compresses against breast swelling of breastfeeding mothers in the work area of the Srengat Health Center. This research method is a pre-experiment with a one group pretest-postest design approach. The population in this study was all postpartum mothers in the working area of the Srengat Health Center. The sampling technique is by taking a large number of samples, which is as many as 22 people. Based on the results of the study, it shows that the value of p = 0.000 (p< 0.05) means that the administration of aloevera compresses is effective against changes in breast swelling in breastfeeding mothers in the work area of the Srengat Health Center Office. The decrease in breast swelling scale after buying aloevera compresses occurs due to the high content of amino acids, minerals, polysaccharides in aloevera which is believed to reduce breast swelling and inflammation. And serves as an anti-inflammatory that localizes both damaged agents and damaged tissues. By doing aloevera compresses on breast swelling, it can reduce swelling in the breast optimally.
BRAF Exon 15 Mutations in the Evaluation of Well-Differentiated Epithelial Nephroblastic Neoplasms in Children: A Report From the Children’s Oncology Group Study AREN03B2
Authors: Goldstein Jeffery A. , Renfro Lindsay A. , Jennings Lawrence J. , Mullen Elizabeth A. , Geller James , Vallance Kelly , Fernandez Conrad V. , Perlman Elizabeth J.
Published: December 2023

Context.—

The distinction between well-differentiated epithelial favorable-histology Wilms tumor (EFHWT) and metanephric adenoma (MA) in children has historically been determined by the required absence of both a fibrous pseudocapsule and mitotic activity in MA. More recently these features have been allowed in adult MA. Mutations in exon 15 of the BRAF gene are reported in up to 88% of MAs but have not been reported in EFHWTs in children lacking MA features.

Objective.—

To clarify the pathologic and molecular features used to distinguish between pediatric MA and EFHWT.

Design.—

Stage I epithelial tumors classified as EFHWT on central review (36 patients) were identified from the Children’s Oncology Group AREN03B2 study. Thirteen tumors had morphologic features overlapping those of MA and 23 lacked such features; 35 of 36 had tissue available for sequencing of BRAF.

Results.—

Patients with EFHWTs with MA features (13) were older (mean, 8.4 versus 1.9 years; P < .001), had smaller tumor diameters (mean, 6.0 versus 9.7 cm; P < .001), and had fewer mitoses (mean, 1 versus 48 mitoses per 10 high-power fields; P < .001) than patients with EFHWT lacking MA features (23). All EFHWTs with MA features contained at least a partial fibrous pseudocapsule; 7 of 12 (58%) had a BRAF exon 15 mutation. No BRAF exon 15 mutations were identified in 23 EFHWTs lacking MA features. None of the 13 EFHWT patients with MA features have experienced relapse (median follow-up 5.9 years).

Conclusions.—

Pediatric epithelial neoplasms with features of MA that show partial encapsulation and/or modest mitotic activity may be classified as MAs. Although BRAF mutation supports the diagnosis of MA, it is not required for the diagnosis.
Using Qualtrics XM to Create a Point-of-Use Survey to Assess the Usability of a Local Implementation of Primo
Authors: Black Matthew , Ganshorn Heather , Wheeler Justine
Published: December 2023

In 2020, Libraries and Cultural Resources (LCR) at the University of Calgary used Qualtrics XM to design and pilot a point-of-use survey to collect user feedback on the usability of our implementation of Primo, Ex Libris's web-scale discovery service. Over a two-week period, users were presented with the pop-up survey while searching and asked to provide feedback. This article summarizes how we designed and implemented this point-of-use survey and the lessons learned from this project.
Response to "From ChatGPT to CatGPT"
Authors: Floyd David
Published: December 2023

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Hipóteses de influência da relação social, do hábito e da conscientização no comportamento de escolha dos modos de transporte
Authors: De Oliveira Militão Andrade Gabriel , Moraes Oliveira Neto Francisco
Published: December 2023

O investimento na infraestrutura de modos sustentáveis nos centros urbanos não tem causado mudança na demanda e freado o uso crescente do automóvel. Dessa forma, se faz necessário compreender os determinantes subjetivos do comportamento da demanda que podem ser capazes de promover o uso de modos sustentáveis. Portanto, o objetivo deste artigo é identificar na literatura como os aspectos psicológicos – relação social, hábito e conscientização – podem influenciar o comportamento de escolha do modo. Estes aspectos são vistos como potenciais causadores de mudança do uso do automóvel. A partir de uma análise de trabalhos teóricos e empíricos, identificou-se as principais teorias, fatores psicológicos e hipóteses de relações destes fatores com o comportamento de escolha do modo de transporte. O trabalho contribui, então, na definição de uma representação conceitual apresentando as hipóteses de relações entre fatores psicológicos no processo comportamental de escolha do modo, que pode servir como base para estudos futuros.
Social Media Utilisation and its Implications for Student Ethics in Higher Education
Authors: Deviv Selvia , Asri  , Lawa Farida Rurung
Published: December 2023

Social media has become an integral part of the educational life of higher education students in Indonesia. Its use provides a variety of benefits, ranging from facilitating access to information, collaboration between students, to facilitating the exchange of ideas. However, in the perfection of its benefits, social media also poses serious challenges related to digital ethics, including the problem of cyberbullying, the spread of hoaxes, and privacy violations. Research on the impact of social media use shows a significant influence on learners' behaviour and achievement, both positive and negative. The importance of paying attention to how learners interact, manage content, and their adherence to digital ethics rules and norms is highlighted. Through an in-depth understanding of the usage patterns and impact of social media on students' ethics, this research aims to provide important insights for students, lecturers, and educational policy makers. It is hoped that the results of this research will not only provide a foundation for responsible policies on social media use in educational settings, but also trigger students' awareness of the impact of their online behaviour on the real world.
Editorial: Valuing Indigenous Voices Despite the “No” Vote
Authors: Marsden Jane
Published: December 2023

Despite only 39.9% of “yes” votes in the October 2023 voice to parliament referendum, almost nine in 10 Australians (87%) believe that First Nations peoples should have a voice in matters influencing them, according to a comprehensive post-referendum survey (Biddle et al., 2023). Over three-quarters of “no” voters (76%) support this view. Reflecting the survey findings, two articles (Carmody, 2023; Latham et al., 2023) in the December 2023 issue of the Psychotherapy and Counselling Journal of Australia advocate for valuing the cultural skills, experiences, and knowledge of Aboriginal and Torres Strait Islander peoples in therapy and therapist education. Another article (O’Hara, 2023a) explores how the counselling and psychotherapy profession defines itself, an important concept given the forthcoming two-year review of national standards by the Federal Government. An attachment-based model for supervision (Soliman, 2023), a literature review on dog-assisted therapy for children with anxiety (Wu & Wei, 2023), a conversation analysis of silence in psychotherapy (Berger & Rae, 2023), and the Power Threat Meaning Framework and self-discrepancy theory (O’Hara, 2023b) are also featured. This issue is the first to showcase new sections called Practice Reflections and Viewpoints.
Philosophy in the City, a project in Mexico City Practice
Authors: Charabati Esther
Published: December 2023

This paper aims to describe the process of constitution of the project Philosophy in the City, which aims to bring philosophical reflection to the streets through philosophical cafés and philosophy workshops with children. The first Cafe Filosófico in Mexico City was created by Esther Charabati 22 years ago and is still being held weekly. Philosophy in the City is a project born in Mexico City in 2016, at the Facultad de Filosofía y Letras in the Universidad Nacional Autónoma de México. It is an interdisciplinary group of young people -from the careers of Philosophy, Pedagogy, and Psychology- committed to taking philosophy out of the classroom and taking it in public spaces. In 2022 its members carried on more than 700 philosophical cafes in public spaces. Philosophy in the city has a permanent presence in libraries, book fairs, and in various social networks.
ÖZEL GÜVENLİĞİN ULUSLARARASI SORUNLAR ÜZERİNDEKİ ETKİSİ: RUSYA-UKRAYNA SAVAŞINDA WAGNER GRUBU ÖRNEĞİ
Authors: ÖZTOPAL Mustafa Kemal
Published: December 2023

Güvenlik ihtiyacı insanlık tarihi kadar eski bir ihtiyaçtır. Bu ihtiyaç bireylerin olduğu gibi toplumların ve devletlerin de en temel ihtiyacı olarak süregelmiştir. Güvenlik, tehdit algısı ve savaşların yapısında meydana gelen değişimler, güvenlik kavramının zaman içerisinde değişmesine sebep olmuştur. Klasik anlamda devletin tekelinde olan güvenlik hem yapısal değişiklikler hem de liberal anlayışın küresel çapta yaygınlaşması sonrası hızlanan özelleşme dalgasından nasibini almıştır. Güvenliğin özelleşmesi, iç güvenlik konusunda bazı kolluk hizmetlerinin özel güvenlik şirket ve personelince icra edilmesini, dış güvenlik konusunda ise özel askeri güvenlik şirketlerinin yaygınlaşmasını beraberinde getirmiştir. Bunlardan özel askeri güvenlik şirketleri özellikle büyük devletler tarafından farklı çatışma sahalarında birçok görevde kullanılmaktadır. Bu çalışmanın temel amacı özel güvenlik ve özel askeri güvenlik şirketi kavramını açıklamak ve bir özel askeri güvenlik şirketi olarak Wagner Grubu’nun Rusya-Ukrayna Savaşı’ndaki rolünü analiz etmektir.
KASTAMONU’DA KIZ ÇOCUKLARININ EĞİTİMİ (1876-1914)
Authors: NAMAL Yücel , TOPARLAK ŞAHİN Melek
Published: December 2023

Osmanlı Devleti’nin batılılaşma sürecinde, modern bir toplumun oluşması için eğitimin önemli bir faktör olduğu anlaşılmıştır. Tanzimat ile başlayan batılılaşma faaliyetlerinde eğitim alanında yapılan çalışmalar kızların eğitimi konusu da önemli bir adım olmuştur. II. Meşrutiyet döneminin getirmiş olduğu özgürlük ortamı ve batılılaşma sürecinin gerektirdiği modernleşmenin yansımalarının en fazla hissedildiği alanlardan biri de eğitim olmuştur. II. Meşrutiyet Dönemi’nde Kastamonu’da erkek öğretmen sayılarında ciddi bir artış olurken kadın öğretmen sayısının azlığı dikkat çekicidir. 1899’da Kastamonu Kız Sanayi Mektebi açılmış, ancak ilerleyen yıllarda Kastamonu’da eğitim gören kız öğrencilerin sayısının az olması eğitim konusunda yeni atılımların yapılmasına ortam hazırlamıştır. I. Dünya Savaşı öncesinde Kastamonu il genel meclisinin bütçe görüşmelerinde kız çocuklarının eğitiminin öneminden bahsedilmesi ve bu konuda çalışmalar yapılması bu durumun bir göstergesidir. Çalışmamızda Kastamonu’da faaliyet gösteren kız iptidai, kız rüştiye mektepleri ve kız sanayi mektepleri ele alınmıştır.
Princípios e Práticas Cirurgia Médica e Odontológica - Edição VIII
Authors: Barroso L. De Freitas Guilherme , Reder Custodio de Souza Ariádine , Maria Moura de Paulo Martins Vieira Egidia , Flávia Ana
Published: December 2023

As técnicas cirúrgicas evoluíram enormemente nos últimos 25 anos, desde os
procedimentos pré-cirúrgicos até os cuidados após cada procedimento, passando
logicamente pelo invento das cirurgias robotizadas e até mesmo à distância. Os editores
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The Paris Camel is Just Plain Dumb
Authors: Taylor Mike
Published: December 2023

Many thanks to Mark Evans of the New Walk Museum, Leicester, for this photograph of yet another camel skeleton, this one from the MNHN in Paris, France:   Head and neck of Bactrian camel (Camelus bactrianus) in right lateral view. Photograph by Mark Evans.   This is especially interesting because it’s our first Bactrian camel — the Cambridge Camel and the Oxford camel are both dromedaries.
Bir Organizma Olarak Odunpazarı Modern Müze: Bağlamsal Mekanik Üzerine
Authors: KARABIYIK ÖZKESEK Hatice Emel
Published: December 2023

Bu çalışmanın konusu; tasarımcısı tarafından ‘yaşayan bir bina’ olarak tanımlanan Odunpazarı Modern Müze’nin (OMM) canlılığının sorgulanması ve araştırılmasıdır. Bir canlıya benzetilen yapıya bu niteliği kazandıran unsur, dinamik olarak bağlamsal verilerin aktarımını sağlayan kabuktur. OMM’nin canlı nitelikli kabuk katmanı, yaşam benzetmesine dayanarak biyolojideki epitel doku ile ilişkilendirilmiştir. Böylece hem bir organizmanın canlılığını sağlayan etmenlerin OMM aracılığıyla mimarlıktaki yerine ulaşmak hem de iki farklı alan arasında benzeşim kurularak yeni araştırma alanlarına katkı sağlamak amaçlanmıştır. Sonuçta, yapı kabuğunun bağlamsal ve fiziksel verilerle sağladığı etki-tepki hareketi ve dokunun aktif aktarım hareketleri, dinamizm ve bağlam kavramlarında kesişmiştir. Ayrıca, dokunun aksiyonlarını karşılayan mekanik ifadesi de mimariye aktarılarak sentezlenmiş ve ‘bağlamsal mekanik’ kavramı ile değerlendirme sonuçlandırılmıştır. Literatürden ve mimari örneklerden de faydalanılarak ‘bağlamsal mekanik’ çeşitli kavramlarla beslenmiştir. Böylece iki olgunun da bağlamsal mekaniği, OMM kabuğu ve epitel doku analojisi dışında metaforik bir anlam yüklenerek kurulmuştur. OMM’nin kesitleri ve fotoğrafları ile bağlamsal mekanik üzerinden analiz edilmesi ile çalışma sonlandırılmıştır.
R&D Tax Incentive Regimes – A Comparison and Evaluation of Current Country Practices
Authors: Spengel C. , Stage B. , Steinbrenner D.
Published: December 2023

This article evaluates qualitatively and quantitatively the current R&D tax incentive regimes in place in ten important foreign direct investment (FDI) countries (Belgium, China, France, Germany, Ireland, the Netherlands, Spain, Switzerland, the United Kingdom and the United States) considering effects on location attractiveness, innovative activity and profit shifting. The environment of offered R&D tax incentives has been highly dynamic in very recent years. Furthermore, the importance of innovative activities is accentuated during an economic crisis. First, the authors qualitatively analyse the different design features of the existing R&D tax incentives in their sample countries. Second, the authors use forward-looking effective average tax rates to measure their effect on location attractiveness quantitatively. The authors’ main finding is that input and output-oriented R&D tax incentives continue to play an important role internationally and that the regimes in place have a considerable impact on forward-looking effective average tax rates, i.e., on countries’ tax attractiveness for R&D investments.
Tax Discrimination
and Capital Neutrality
Authors: Mason R.
Published: December 2023

States use their tax systems to influence inbound and outbound
investment, but the non-discrimination article of the OECD Model limits states’
ability to apply tax preferences for resident investors over non-resident
investors. This paper attempts to lay out the tax policy issues underlying the
non-discrimination article, and to do this, it will give background on the
traditional capital neutrality benchmarks – namely, capital export neutrality
(CEN) and capital import neutrality (CIN). The specific questions framed by the
seminar organizers make reference to the non-discrimination principle under EC
law, so the paper will also compare the OECD Model non-discrimination principle
with that of the EC Treaty.
Taxation of Income of International Transportation under the Tax Treaty Framework: An Undesirable Compromise for the Source Countries?
Authors: Das P. , Krishnia S. , Singh Ajanta
Published: December 2023

Under the tax treaty framework, the taxing rights of income from international transportation is allocated exclusively to the country of residence or country of the place of effective management. The basis of such a tax policy is stated to be administrative inconvenience in allocating income over jurisdictions. However, this long-standing policy is questionable on several grounds in light of its fundamental inconsistency. Furthermore, tax treaty rules often influence domestic tax systems leading to tax competition amongst countries to attract businesses and, therefore, would undermine the international tax system, also creating opportunities for tax avoidance. It should also be considered that, in an analogous situation in the case of digitalized businesses, the debate on Pillar One shows that, at least theoretically, a solution for the allocation of global income to various market countries can be envisaged. Against this backdrop, this study re-examines the present policy and tax treaty framework regarding income from international transportation and provides a more consistent solution that would usher in tax certainty without creating opportunities for tax avoidance.
On the European Commission’s Understanding of the Arm’s Length Principle in International Taxation versus State Aid Matters
Authors: Castagna S.
Published: December 2023

The European Union is bound to a duty of consistency between its internal policies and external action and a duty of sincere cooperation with its Member States. When addressing the status of the OECD Transfer Pricing Guidelines and the OECD arm’s length principle, the European Commission has adopted two different views: one in matters of domestic income taxation of third states and its Members, and another dealing with EU State aid. This article addresses the consequences of such behaviour. It concludes that the aforementioned duties require the European Commission to deem the OECD Transfer Pricing Guidelines as the only possible implementation of the arm’s length principle when addressing State aid transfer pricing matters. The European Commission can, however, still decide to engage Member States to further its positions on the matter in order to develop the understanding of the arm’s length principle and the OECD Transfer Pricing Guidelines at the OECD level.
How to Move Forward with Country-by-Country Reporting? A Qualitative Content Analysis of the Stakeholders’ Comments in the OECD 2020 Review
Authors: Müller R. (Raphael) , Schoenrock M. , Spengel C.
Published: December 2023

Country-by-country reporting (CbCR) has become the global standard on corporate tax transparency within only 6 years after the release of the OECD BEPS reports in 2015. Recently, the European Union extended the scope of CbCR towards public disclosure of the reports. Despite the widespread adoption of CbCR, its strengths and limitations are still controversially discussed. This article investigates whether the current OECD approach is fit for purpose and which modifications would improve the consistency and effectiveness of the reports. The analysis builds on a qualitative assessment of stakeholder comments received by the OECD during a public consultation process which was part of the major 2020 review on CbCR. The authors critically review the proposed adjustments as well as current developments and derive recommendations for moving forward. The key recommendation is that the OECD should focus on technical adjustments such as a multi-year approach and harmonized notification requirements. However, major conceptual changes should be streamlined with the outcomes of the negotiations on a global minimum tax to reduce complexity and improve legal certainty for affected firms.
The ECJ’s Decisions in the Danish “Beneficial Ownership” Cases: Impact on the Reaction to Tax Avoidance in the European Union
Authors: Zalasiński A.
Published: December 2023

This article provides a critical analysis of the long-awaited Danish beneficial ownership cases, delivered by the Court of Justice of the European Union in February 2019, concerning the prevention of tax avoidance/tax abuse in respect of the Parent-Subsidiary Directive and the Interest and Royalties Directive. The author discusses one of the aspects of the concerned decisions that is an attempt of the Court to clarify that the “abuse of rights” concept constitutes a general principle of EU law that applies to all areas of EU legislation in a uniform manner. He also analyses the possible consequences of the decisions for EU tax litigation and even for the negotiations of future corporate tax harmonization.
Building the EU Tax Sovereignty: Lessons from Federalism
Authors: Bizioli G.
Published: December 2023

The role of taxation within the European Union has risen (and is rising) over the years due to the establishment of the Economic and Monetary Union and the economic/financial and COVID crises. It is well established that taxation is characterized as an obstacle for the functioning of the internal market and the interpretation of the fundamental freedoms has a direct impact on the design of the domestic tax systems. The first part of this article addresses the clash between the supranational economic freedoms and the domestic tax systems in the light of the federal experience of “two levels of government”. The second part, differently, sheds light on the role of taxation within the Economic and Monetary Union. After having enucleated a principle of solidarity according to article 122(2) of the Treaty on the Functioning of the European Union, the article inquires the foundations and the limits of the European Union’s authority to tax. In particular, it aims at demonstrating that the financial assistance to the Member States in exceptional circumstances should be funded through the EU budget and EU taxes.
Lessons to Be Learned from the Dutch Childcare Allowance Scandal: A Comparative Review of Algorithmic Governance by Tax Administrations in the Netherlands, France and Germany
Authors: Hadwick D. , Lan S.
Published: December 2023

In January 2021, the cabinet of Mark Rutte, Prime Minister of the Netherlands resigned after the revelation that the Dutch tax administration had infringed fundamental rights of an estimated 35,000 welfare recipients. The Dutch childcare allowance scandal or toeslagenaffaire unveiled the ways in which the Dutch tax administration made use of artificial intelligence algorithms to discriminate against and violate the rights of welfare recipients. The Netherlands is not the only EU Member State using artificial intelligence for the selection of taxpayers for audits. Accordingly, the toeslagenaffaire can offer valuable lessons for the protection of taxpayers’ rights in the context of algorithmic governance in other Member States. Following the introductory section 1. of this article, section 2. outlines the important elements of the toeslagenaffaire and identifies qualitative requirements for the protection of taxpayers’ rights. In section 3., a joint comparative study of French and German algorithmic governance is conducted to determine whether lessons were learned from the toeslagenaffaire.
Preventing Tax Base Erosion and Profit Shifting Occasioned by Offshore Indirect Transfer of Assets: Perspectives from Africa
Authors: Oguttu A.W.
Published: December 2023

One of the tax base erosion and profit shifting (BEPS) schemes that has been a major concern in developing countries over the last few years is the “offshore indirect transfer” of business assets to low-tax jurisdictions that facilitate tax planning so as to avoid capital gains tax in the countries were the asset is located. Often these schemes involve assets that are based in developing countries. Besides the BEPS challenges posed, offshore indirect transfers can also result in double non-taxation and double taxation in the country where the asset is located and the residence country of the seller and/or the buyer of the asset. This article discusses these tax challenges from the African perspective by discussing various cases and reports of offshore indirect transfers in different African countries. The article provides recommendations regarding the domestic tax provisions that African countries should have in place in order to effectively protect their tax bases, as well as measures to effectively detect these schemes and collect the tax due. The article also discusses the double tax treaty provisions that countries ought to have in place to effectively protect against the erosion of their tax bases. The recommendations in this article will be useful for tax policy makers, tax treaty negotiators and tax administrations in developing countries, particularly those in Africa, in their endeavours to protect their tax bases from the scourge of offshore indirect transfers of assets located in their jurisdictions.
The European Company (Societas Europaea – SE) Caught In Between Cross-Border Mobility and Lock-In Effect – An Empirical Analysis on the Influence of Exit Taxation upon Cross-Border Mergers and Seat Location Decisions
Authors: Schmidtmann D.
Published: December 2023

Ever since the European Company (Societas Europaea - SE) was introduced in 2004 to complete the single European market and to facilitate freedom of establishment of companies, the number of established SEs has increased substantially. The SE Statute provides for cross-border mobility enabling the SE to engage in regulatory, legal and international tax arbitrage to attain competitive advantages. The uneven regional distribution of SEs as well as the low existing numbers of transferred seats and cross-border mergers indicate that the arbitrage opportunities the SE offers are not being made use of to the expected extent. This paper examines empirically the correlation between exit taxation provisions of Member States of the European Economic Area and the current distribution of SEs and their formation by cross-border merger as well as their decision to transfer the registered office by employing two simple econometric models: a chi-square independency test and a regression analysis. The results emerging from this study suggest that exit taxation provisions affect the numbers of cross-border mergers and transfers of the registered office, the direction of the merger and the direction of the transfer of the registered office. The potential realization and taxation of accrued gains causes lock-in effects.
The Economic Unit of Effective Tax Rates
Authors: Ruf M.
Published: December 2023

This paper clarifies the appropriate economic unit of effective tax rates. Effective tax rates should give the percentage of the economic profit to be paid to the state as taxes. Only effective tax rates defined in this economic unit allow for an economically meaningful comparison with the statutory tax rate in order to reveal inter-industry distortions and inter-asset distortions caused by taxation. The widely used effective tax rates of King and Fullerton (1984) and Devereux and Griffith (2003) both follow this concept.
See King, M., and Fullerton, D., The Taxation of Income from Capital (University of Chicago Press, 1984); Devereux, M., and Griffith, R., “Evaluating Tax Policy for Location Decisions”, 10 International Tax and Public Finance (2003), pp. 107-126. This clarification of the appropriate economic unit of effective tax rates allows for a general definition of effective tax rates. Based on indifference considerations, effective tax rates giving the percentage of the economic profit to be paid to the state as taxes can be calculated for arbitrary investments, including complex simulation models (such as the European Tax Analyzer). Such effective tax rates can also be compared directly to statutory tax rates or to the effective tax rates of King and Fullerton (1984) and Devereux and Griffith (2003).
Ibid.
Evolution of the Concept of Technical Services and the Policy Considerations Driving Their Development
Authors: Duarte da Conceiçāo Machado P.
Published: December 2023

When dealing with situations in which technical services are paid by an enterprise to a non-resident service provider, the tax implications from both a domestic and treaty standpoint are quite varied. Although typically subject to withholding tax in the source state, the specific treaty and domestic law provisions that apply to cross-border technical services have changed over the past decades. Yet, more profound changes are still needed, especially when developing countries are involved. Developing countries have played a significant role in driving policy changes in respect of the taxation of technical services. This, however, should not be seen as an initiative going against the interests of developed countries under the auspices of the globalized attempt to counter BEPS. In this sense, assessing how the meaning and interpretation has (or should have) evolved over time and which policy considerations have driven such changes is fundamental for the evaluation of the allocation of taxing rights between the source and residence states in terms of effectiveness.
International Taxation in the Digital Economy: Challenge Accepted?
Authors: Olbert M. , Spengel C.
Published: December 2023

The digitalization of the economy is considered as a key driver of innovation, economic growth and societal change, and is a major challenge for the international tax system. The OECD has addressed this challenge in its extensive Action 1 Final Report as part of its BEPS project. This article critically depicts the OECD’s view and reform proposals on taxing businesses in the digital economy. Further, recent literature contributions on the matter are synthesized. While taxing profits according to value creation is detected as the new paradigm in international taxation, this review reveals that the understanding of the digital economy and corresponding reform proposals for taxation are premature. The authors show that the OECD has systematically missed the opportunities to define the paradigm of value creation and to analyse digital business models accordingly. Considering the current challenges, the key pressure area for taxing digital businesses in the near future is transfer pricing. Drawing from practical case studies and research in industrial economics, accounting and management science, this article derives a concept for value creation in digital businesses. Based on this concept, the authors propose a framework to refine transfer pricing guidance in order to come closer to the goal of aligning profit taxation with value creation.
Towards eXplainable Artificial Intelligence (XAI) in Tax Law: The Need for a Minimum Legal Standard
Authors: Kuźniacki B. , Almada M. , Tyliński K. , Górski L. , Winogradska B. , Zeldenrust R.
Published: December 2023

Tax administrations globally increasingly rely on artificial intelligence (AI) systems for automation. However, automation has a huge potential impact on the rights of taxpayers subject to algorithmic assessments, which is compounded by the opacity of complex AI systems. This article argues that adequate protection of taxpayers’ rights demands the use of eXplainable AI (XAI) technologies that can render the functioning and decisions of tax AI systems understandable for taxpayers, administrative appeal bodies and the courts. This demand follows from the constitutional principles that guide taxation. Still, it is insufficiently addressed by soft and hard law instruments on AI, which do not address the particular information needs of the tax domain. To address this gap, the authors conclude the article by mapping technical and legal challenges for the proper application of explanation techniques to tax AI to ensure that automation does not come at the expense of taxpayers’ rights.
The Effects of Value Added Tax (VAT) on the Rate of Government Growth: An OECD Panel Study
Authors: Özdemir A.R.
Published: December 2023

Value added tax (VAT) has been a handy instrument, particularly in the financing of European governments during the last quarter of the twentieth century, when their expenditures were rising rapidly. This suggested to many that there could be an association between the share of VAT revenues in total government revenues and the rate of government growth. This paper investigates the effects of VAT on government growth using ordinary least squares with panel corrected standard errors for OECD countries. The results strongly suggest that unlike “cascading type of turnover taxes”, VAT does not increase the rate of government growth, rather, it can account for current slowdowns in government growth rates for OECD countries.
The Single Tax Principle: Fiction or Reality in a Non-Comprehensive International Tax Regime?
Authors: Gil García E.
Published: December 2023

It is possible to talk about an international tax regime taking into account the international regime theory developed in the framework of international relations. As this is defined as a set of rules and principles that regulate the international tax arena, this contribution analyses if the single tax principle can inspire such an international tax realm. The author explores the roots and developments of the single tax principle and focuses on the purposes of double tax conventions in order to determine whether single taxation is actually a desired outcome of tax treaties. The author also tackles international custom and arrives at the conclusion that the international tax regime does not rise to the level of customary international law. In this regard, the international tax regime is based on competition rather than on coordination, being regarded as a non-comprehensive regime. The question that arises, then, is whether single taxation can act as a coordination mechanism to turn the international tax regime into a comprehensive one.
Exit Taxes in Norway
Authors: Zimmer F.
Published: December 2023

Recently introduced exit taxes in Norway apply to capital gains on
shares held by individual taxpayers emigrating from Norway, to the emigration
of companies and to capital gains on the transfer of assets and liabilities
outside the Norwegian tax area. This article describes and analyses these rules
with special reference to EEA/EC tax law and their relation to tax treaties. In
particular, the requirement, in some instances, to provide a guarantee for exit
taxes, taxation without any option of deferral on the migration of companies,
and taxation of the transfer of inventories and intangible assets are
discussed. As regards tax treaties, the focus is on whether or not the
alienation of the assets has taken place before the exit, and the relationship
between exit taxes and tax treaty rules allowing for an extension of the tax
liability.
Access Fees to Cultural Heritage Cities: A Way to Promote Sustainable Tourism?
Authors: Tosi L. , Bagarotto E.-M.
Published: December 2023

Art cities face specific problems determined by tourism pressure in terms of higher public expenditure (to ensure the provision of public services, the restoration and management of cultural sites and infrastructure for tourists), as well as negative consequences, such as pollution, traffic, expropriation of the social identity of the city, a loss of traditional shops and an increase in prices. Regarding the tax law field, many countries have tackled this issue through the introduction of a tourist tax, which affects tourists who stay overnight in the city’s facilities. However, the tourist tax is not an effective tool for promoting sustainable tourism because it does not affect the so-called “excursionist tourists” (day trippers), who do not stay overnight in the city, but still largely contribute to the aforementioned problems. Using the example of the city of Venice, this article proposes a simpler and more integrated approach that delimits the application of access fees only to tourists arriving through specific carriers (in particular, cruise ships) and the access to specific demarcated areas in the city (such as St. Mark’s Square). The suggested system could become a template applicable to all cities characterized by the strong presence of tourists to pursue the ultimate goal of making all tourists – including excursionist tourists – contribute to the city’s public expenses.
An Unfinished Patchwork: An Assessment of the Current International Tax Dispute Resolution System from a Developing Country Perspective
Authors: Quiñones N.
Published: December 2023

The twenty first century has seen a number of rapid developments in the international tax dispute resolution system, culminating with the Pillar One tax certainty block as proposed by the Inclusive Framework on BEPS. The present article provides an overview of these developments and assesses if the international tax dispute resolution system has achieved the long-desired stability, discussing the challenges posed from the perspective of low and middle-income countries as well as of taxpayers operating on a global scale. The research concludes that the current system may be viewed as an unfinished patchwork, which is why it does not meet the effectiveness, transparency, coordination, predictability, fairness and simplicity objectives needed to achieve stability. With this assessment, taxpayers and developing countries should focus on a comprehensive reform of the system. The article also calls for further research on the impact of international tax dispute resolution reform on the developing world.
Transnational Tax Information Exchange Networks: Steps towards a Globalized, Legitimate Tax Administration
Authors: Stewart M.
Published: December 2023

In a global era, tax administrators must extend their reach beyond the borders of the nation state. They must cooperate actively with administrators from other countries and work to build transnational institutions and networks that give them the capacity to enforce national tax laws in respect of multinational and mobile capital and labour. This article discusses a range of trends indicating that national tax administrators are, finally, beginning to achieve the levels of transnational tax cooperation required to maintain national tax sovereignty. The article then explores the important question of legitimacy of these transnational networks, which will be crucial for their sustainability and effectiveness in the long term.
A New Scenario in International Tax Law: Two Proposals to Rethink the OECD Model in Response to the Generalization of Distance Work by Employees
Authors: Rovira Ferrer I.
Published: December 2023

This article analyses the necessity to adapt the OECD Model Tax Convention (OECD Model) for remote work. It argues that a legally binding agreement must be reached on two fundamental aspects: tax liability criteria for remote workers’ earnings and conditions determining when an employee’s remote work creates a permanent establishment (PE) for the employer. The article investigates the current regulation of these issues in the OECD Model, identifies problem areas and proposes reforms. In particular, it suggests a reformulation of tax liability determination for income from remote-working employment based on a reconsideration of the “source state” concept. Additionally, the article proposes creating an ad hoc decision tree to provide a clear and efficient method for verifying the potential existence of a PE due to an employee’s remote work.
Robots and Tax Reform: Context, Issues and Future Perspectives
Authors: Barros M.
Published: December 2023

The increasing use of machines equipped with artificial intelligence has caused great concern worldwide in terms of the impact of automation on existing jobs, with some studies showing that up to half of current human workers are threatened by this process. Though the replacement of human workers by machines has been experienced in the past (e.g. in the first, second and third industrial revolutions), it is believed that this time the impacts will be more drastic because, for the first time in history, machines are capable of substituting humans not only in repetitive functions but also in cognitive tasks. In addition to mass unemployment, the replacement of human workers by robots could lead to a great loss of state revenue, as revenues from taxes on wages would be reduced. It is also believed that there will be a significant reduction in the collection of indirect taxes, due to less consumption as a result of the job losses. Conversely, public expenditures are expected to increase, especially on unemployment insurance, welfare programmes, health and education. Some proposals have been made for taxing the robots; these are presented in the current article, together with some personal contributions on the subject.
The Use of Country-by-Country Reporting for Tax Risk Assessment: Challenges and Potential Solutions
Authors: Picariello S. , Chand V.
Published: December 2023

This article provides some considerations on the use of the country-by-country reporting for tax risk assessment through an in-depth review of the potential issues associated with the implementation, design and appropriate use of the country-by-country report. After providing a broader conceptual framework that outlines the general benefits of incorporating the report into a tax authority’s risk assessment framework, the article specifically suggests potential areas for improvement in respect of how to address the different issues and examines whether modifications should be made to the standard, especially in light of the forthcoming 2020 review.. Such recommendations are addressed to tax administrations and multinational enterprise groups, since inefficient use will be burdensome for both parties The analysis also takes into consideration the recent public consultation draft issued by the OECD.
PENINGKATAN KETRAMPILAN KADER POSBINDU INSTITUSI KAMPUS UNJA PONDOK MEJA DALAM MENDUKUNG KAMPUS SEHAT UNIVERSITAS JAMBI
Authors: Ridwan M. , Ningsih Vinna Rahayu , Halim Rd.
Published: December 2023

Posbindu institusi merupakan sebuah Upaya untuk mendeteksi penyakit tidak menular di tempat kerja. Deteksi dini dilakukan kepada dosen  mahasisiwa dan tenaga kependidikan. Kegiatan ini bertujuan untuk melakukan pelatihan kader agar dapat meningkatkan  cakupan pelayanan di Kampus unja pondok meja. Kegiatan ini diharapkan dapat mempercepat layanana Posbindu setiap bulannya denganbanyaknya kader yang terlatih. Metode yang di gunakan  ceramah dan praktikpelaksnaan Posbindu. Hasil kegiatan ini adalah terlatihnya kader baru posbindu di kampus unja Pondok meja dan dapat meningkatkan ketrampilan masing -masing kader dalam menjalakan posbindu institusi. Kesimpulan pelatihan dengan ceramah dan praktik lebih cepat meningkatkan pemahaman dan ketrampilan kader posbindu. Perlunya pendampingan secara berkelanjutan dari puskesmas dan dukungan dari penentu kebijakan di perguruan tinggi untuk keberlnajutan program posbindu institusi.