bluuebunny/crossref_metadata_2025 huggingface dataset:
​​RESEARCH ON THE SATISFACTION OF EDUCATIONAL PRACTICE IN NORMAL COLLEGES A SURVEY OF STUDENT LEADER TEACHERS AND INTERNSHIP SCHOOLS​
Authors: Zheng Ya , Mohamed Noordin Zurainy
Published: December 2023

Educational practice is an effective form of cooperation between universities and primary and secondary schools. Teaching practice can promote the improvement of teaching quality in primary and secondary schools, and also promote the integration of college students' theoretical knowledge and practical experience, and promote their professional development. From the perspective of practice leader teachers and practice schools rarely involved at present, this study analyzes and understands the satisfaction survey of practice leader teachers and practice schools on the subject of educational practice (students, teachers and schools) through questionnaire design and data collection. The survey results show that the satisfaction of the intern and the intern leader teachers is between very satisfied and satisfied. The student leader teachers' satisfaction with the school and students ranged between very satisfaction and satisfaction, and more tended to be satisfied. The satisfaction with the school (C school) Educational practice management was between very satisfaction and satisfaction, and some contents were between satisfaction and basic satisfaction. It shows that the practice leader teachers and practice schools are basically satisfied with the subject of Educational practice and Educational practice.
BREASTFEEDING PROBLEMS AND AFFECTIVE FACTORS DURING POSTPARTUM PERIOD
Authors: PELİT AKSU Sıdıka , İŞ Mine , YAMAN SÖZBİR Şengül
Published: December 2023

This study aims to examine breastfeeding problems experienced by mothers with 0-1 month old babies and the factors affecting them. The research population consists of breastfeeding mothers with 0-1 month old babies who applied to a State Hospital Clinics of Gynecology and Pediatrics. In data collection, the study used “Demographic Question Form” and “Breastfeeding Experience Scale”. Data was collected face to face via questionnaire. Mothers who gave birth on the 33-37th weeks, those who do not have breastfeeding experience, those who did not breastfeed their baby within the first half hour, those who breastfed their babies as soon as they cried, those who use pacifiers or bottles and formula and supplementary, those who experience breastfeeding problems and those whose babies stayed in intensive care unit were found to experience bigger problems with breastfeeding (p
Transformational Educational Leadership Effect On Staff Members Engagement: The Mediating Impact Of Intrinsic Motivation
Authors: Kant Dr. Shashi , Asefa Kebede
Published: December 2023

Staff member’s engagement has been at the core of consideration for top management and scholars who stated that staff member’s engagement can be a key driver of an organization's business success. Many scholars have found in recent researches that a transformational educational leadership approach has a beneficial connection with staff member’s engagement. Therefore, this research oriented to investigate the connection of transformational educational leadership on staff members engagement through the mediating role of figurehead intrinsic enthusiasm. Researchers examine the information from a sample of 338 elevated education staff members working in the elevated educational institutes in Ethiopia by means of structural equation modeling (SEM) and confirmatory factor investigation (CFA) to examine the framed hypothesis. Afterward, the bootstrapping investigation was employed to verify the mediation examine in present research. The investigation manifested that transformational educational leadership approach had considered proficient impact on staff member’s engagement for the mediating role of intrinsic enthusiasm. The impact of transformational educational leadership on staff member’s engagement was found to be totally mediated by figurehead intrinsic enthusiasm. Hypothetically, present experiential investigation contributed to the novel knowledge on the exclusive mediating impacts of figurehead intrinsic motivation on the connections among transformational educational leadership and staff member’s engagement in the Ethiopia. Practically, present research has administrative connotation in the field of governmental administration, leadership and HRM.
Procesos metodológicos de la lectura denotativa y su importancia en la adquisición de la comprensión lectora
Authors: Velásquez Álava Wellington Leodan , Caicedo Vivero José Manuel , Sisalema Vera Carmen María , López Vera Ramon Vinicio
Published: December 2023

Una de la principales dificultades en los primeros años de formación académica de los estudiantes es la adquisición de la lectura, más aun de lo que se entiende como lectura comprensiva o comprensión lectora; pero para llegar a ese estadio se precisa del desarrollo de destrezas y de un proceso metodológico orientado a la práctica, la motivación y al desarrollo de destrezas, siendo así se planteó como objetivo fundamental del presente trabajo: “Desarrollar destrezas de comprensión lectora, mediante la aplicación de un proceso metodológico adecuado”; para ello se aplicó el método de investigación mixto tanto cualitativo como cuantitativo, así como los procesos de investigación – acción los cuales sirvieron para aplicar una ficha de observación de destrezas así como también planes de clase destinados a la aplicación del método integral con diversas lecturas. Mediante los resultados se evidenciaron mejoras durante los meses de aplicación llegando a mejorar de manera exponencial las destrezas de la lectura en los dicentes.
The Natural World Connected by Pulses
Authors: Hashimoto Junichi
Published: December 2023

Even if this universe is subdivided into smaller scales, it retains a similar structure in the Sun, Earth, human body, atoms, etc. At every scale, its members are bound to each other and form an organic nature. The relationships between such members appear in the form of energy (pulses). Their pulsating and beating nature allows this natural world to continue to operate autonomously. A detailed examination of this has led to a systematic understanding of topics such as the role of humanity on the planet, the origin of the brain and the nature of desire. Along with such clarification work, theoretical proofs were also provided for the equivalence of electromagnetic waves and pulses, as well as the equivalence of rotation and pulsation. This will have a major impact on various fields in the future.
PENERAPAN MODEL PEMBELAJARAN DISCOVERY LEARNING UNTUK MENINGKATKAN KETERAMPILAN BERPIKIR KREATIF PADA MATERI LETAK DAN LUAS BENUA ASIA DAN BENUA LAINNYA
Authors: Wisudanti Ambar
Published: December 2023

The aim of research is to improve creative thinking skills student for subject “letak dan luas benua Asia dan Benua lainnya” by applying the Discovery Learning learning model.This research is Classroom Action Research which lasted for two cycles. The subjects of this research were students in class IX A of SMP Negeri 2 Girimarto in the 2022/2023 academic year, totaling 30 students. Data collection techniques were interviews, observations and tests, with data analysis in the form of content validity and triangulation. Classical completeness in cycle I was 66.67%, and research continued in cycle II with classical completeness 83.33%. Based on the research results, it can be concluded that creative thinking skills in social studies learning for class IX A students at SMP Negeri 2 Girimarto in the 2022/2023 academic year can be improved through the Discovery Learning learning model. The writer hope this research can make teachers more skilled in applying the Discovery Learning model to improve student’s creative thinking skills.
Vitamin D levels and VDR rs2228570 genetic variant in Autoimmune Thyroiditis
Authors: Shaikh Parveen , Shaikh Parveen , Nakashidze Irina
Published: December 2023

Autoimmune Thyroiditis (AIT) is a prevalent autoimmune disorder characterized by an immune response targeting the thyroid gland. Genetic factors play a significant role in AIT susceptibility, with immune-related genes, especially the vitamin D receptor (VDR) gene, potentially influencing AIT development. This comprehensive review delves into the intricate association between VDR gene polymorphisms, particularly rs2228570 (FokI), and AIT susceptibility, exploring various populations. Research has unveiled contrasting outcomes regarding the link between the VDR rs2228570 polymorphism and AIT risk across diverse ethnic groups. Certain populations have exhibited a noteworthy correlation, suggesting that population-specific genetic factors contribute to AIT risk. A recurring observation of vitamin D deficiency in AIT patients has correlated with elevated anti-thyroid antibodies, abnormal thyroid function , and thyroid volume. The results emphasize the possible role of vitamin D in the development of AIT, suggesting the importance of vitamin D supplementation to address deficiencies associated with AIT. In addition to VDR rs2228570, other genetic variants have also shown associations with AIT susceptibility, displaying varying results across different populations. Ethnicity emerges as a pivotal factor influencing these associations, underscoring the need to consider genetic variations in diverse populations. We emphasize the intricate interplay between VDR gene polymorphisms, vitamin D, and AIT susceptibility. Extensive research is essential to unveil the clinical significance of these genetic variations, offering prospects for enhanced diagnostic and therapeutic strategies for individuals with AIT.
Transfer Pricing and Intangibles: Report on the WU Transfer Pricing Symposium
Authors: Dziwiński K.
Published: December 2023

This article highlights key points discussed during the first WU Transfer Pricing Symposium titled “Transfer Pricing and Intangibles: Current Developments, Relevant Issues and Possible Solutions” organized by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business) and summarizes the topics analysed during four sessions of the event.
Administrative Principles Transfer Pricing 2023 – Structure and Overview of Significant Changes
Authors: Heidecke B. , Ebeling F.
Published: December 2023

This article provides an overview on the recently published German administrative principles on transfer pricing, looking into the novelties of the current version, which replaces that from 2021. The new principles apply to all years for which audit cases are still open in Germany and also to years that have not been audited. A special focus of the new administrative principles are rules on business restructurings.
Tax Treatment of Preferred Shares and Other Qualifying Debt
Instruments
Authors: Centeno B.
Published: December 2023

In light of a Draft Bill amending corporate income tax law that may
soon change the tax treatment of preferred shares, the author considers the
current treatment of such instruments and prospects for the future.
Partial Residence Clauses in US Treaty Practice
Authors: Brabazon M.
Published: December 2023

Partial residence clauses were a standard feature of pre-1996 US tax treaties. Many remain in force today. This article considers their history, design and judicial interpretation, their relationship with the transparent entity clause in current US and OECD Models and the OECD Partnership Report, and their influence on treaty interpretation.
Germany Extends Tour Operator Margin Scheme for Travel Services to B2B Sector
Authors: Grambeck H-M.
Published: December 2023

Germany has amended its VAT rules for travel services from 18 December 2019 as a consequence of an infringement procedure. In this article, the author explains the consequences of these new rules for travel service providers, as well as business customers, and points out some grey areas which imply uncertainties for the businesses affected.
New EU VAT Rules Applicable from 1 January 2011
Authors: Annacondia F. , Corput W. van der
Published: December 2023

On 1 January 2011, the Member States of the European Union must (or
may) have transposed Art. 3 of Directive 2008/8 and the provisions of
Directives 2009/69, 2009/162 and 2010/23 into their national VAT legislation.
In this article, the editors present an overview which reflects the state of
affairs at the end of October 2010.
Regional Cooperation and Tax Information Exchange among Asia-Pacific Tax Authorities
Authors: Araki S.
Published: December 2023

The rapid growth of economic activities in the Asia-Pacific region brings with it a rising risk of cross-border tax evasion and avoidance. In this context, tax authorities in the region are more than ever required to work together to counter these risks, and the importance of tax information exchange within the region is increasing. While the OECD leads the global initiative to enhance transparency and the exchange of tax information, the frameworks of regional cooperation in Asia-Pacific are not as developed in comparison with other regions such as Europe, the Americas and Africa, and even with other financial enforcement authorities in the region. This article highlights issues with which Asia-Pacific tax authorities are faced with respect to tax information exchange, and suggests measures to enhance such exchanges among the tax authorities in the region.
International Assistance in the Collection of Taxes
Authors: Baker P. , Czakert E. , Eijsden A. van (Arie) , Grau Ruiz M.A. , Kana L.
Published: December 2023

This article reviews the discussion on international assistance in the collection of taxes, which was the subject of Seminar I of the 64th Congress of the International Fiscal Association, held in Rome, Italy on 2 September 2010.
New Preferential Intellectual Property Regime
Authors: Gallo G. , Balestieri S.
Published: December 2023

This note summarizes the recently enacted Italian preferential intellectual property (IP) regime that has been in effect since 1 January 2015.
Five Ways Tax Risk Is Rising – And How the C-Suite Can Respond
Authors: Coronado L.
Published: December 2023

Based on the findings of the 2021 EY Tax Risk and Controversy Survey, the author looks at some of the growing tax challenges facing the C-suite. The past decade has brought about significant developments within the world of taxation and for the C-suite that translates to a hotbed of potential tax risks and exposures. Identifying, managing and having a comprehensive game plan becomes key when navigating these increasingly choppy waters.
Digital Services Taxes across Europe in the Midst and Aftermath of the COVID-19 Pandemic: A Plausible Option to Raise Tax Revenue?
Authors: Alvarado M.
Published: December 2023

In this article, the author provides a comprehensive analysis of digital services taxes across Europe with a view to determining whether or not they are an option to address the budgetary concerns of European countries in the context of the pandemic.
Supreme Court Delineates Scope of New GST Law Quite Widely
Authors: Jain T.
Published: December 2023

In India various indirect tax laws were replaced by the goods and services tax (GST) legislation, which came into force in July 2017. A plain reading of GST law reveals that its scope is very wide in comparison with pre-GST laws. However, many taxpayers have continued to work upon the assumption that the tax positions taken by them under the pre-GST laws continue to hold good. Similar arguments were made in a recent case before the Supreme Court of India concerning lottery tickets. The Supreme Court’s decision rejected arguments based on pre-GST legislation and confirmed the wide scope of GST. In this article, the author examines the implications of this decision and urges taxpayers to undertake appropriate actions to correct their positions.
Hybrid Debt and Hybrid Equity Instruments and the Interest Limitation Rules in South Africa
Authors: Mazansky E.
Published: December 2023

In this article, the author examines the South African tax rules relating to hybrid debt and hybrid equity instruments, particularly with a view either to disallowing deductions or taxing receipts. Some observations are also made on the related interest limitation rules, which prevent excessive interest deductions.
Zero Rating Cross-Border Supplies of Goods under EU VAT – Triangular Takeaway Transactions
Authors: Swinkels J.J.P.
Published: December 2023

In its judgments in Euro Tyre Holding and VSTR, the Court of Justice of the European Union (ECJ) dealt with the VAT aspects of triangular intra-Community takeaway transactions. In this article, the author argues that the ECJ’s solutions are not limited to scenarios in which the goods are transported by or on behalf of the intermediate party, and that the ECJ has actually introduced an element of uncertainty into the EU system for taxation of intra-Community supplies of goods.
French Treaty Policy
Authors: Comolet-Tirman C.
Published: December 2023

In addition to their traditional function of eliminating tax frictions to promote France as a place to do business and the capacity of French firms to develop abroad, France’s tax treaties now represent a set of administrative cooperation tools that assist in countering international tax fraud and evasion.
Judicial review of tax determination in the United States
Authors: Rienstra J.G.
Published: December 2023

In this article, the author provides an overview of the US court
system with regard to judicial review of tax determinations by the US Internal
Revenue Service, including the courts of first instance and the courts of
appeal.
Ruling on Transfer Pricing and Business Restructuring
Authors: Joseph A.
Published: December 2023

The author considers Taxation Ruling TR 2011/1, which deals with the application of transfer pricing provisions to business restructurings of multinational enterprises where cross-jurisdictional transfers of functions, assets and risks of businesses occur. In this Ruling, the Australian Taxation Office reiterates its long-held position that Div. 13 of the Income Tax Assessment Act 1936 and Art. 9 (associated enterprises) of Australian income tax treaties are both based on the arm’s length principle, so there should be no fundamental inconsistency in the outcomes under the two sets of provisions.
Just a Brick in the Wall: Why Italy Is Violating Council Directive 2008/7/EC in the Pending Ente Cambiano Case
Authors: Arginelli P.
Published: December 2023

In this article, the author discusses the request by the Italian Supreme Court for a preliminary ruling from the ECJ regarding the compatibility of the 2016 Italian legislation reforming the governance and regulation of cooperative banks with the EU Capital Duty Directive (2008/7). In particular, that legislation imposes a levy on cooperative banks that avoid a requirement to join a cooperative banking group by contributing their business to a joint-stock company that carries out the banking activity. The author argues that the legislation violates the prohibition against Member States levying indirect taxes on capital contributions contained in article 5 of the Capital Duty Directive (2008/7).
Advance Pricing Agreements: The Journey Thus Far
Authors: Phatarphekar K. , Arora A.
Published: December 2023

The authors review the Indian advance pricing agreement programme and
experiences to date.
Bank-Originated Securitizations: Australian Taxation Office Publishes Technical Discussion Paper
Authors: Joseph A.
Published: December 2023

The author considers the technical discussion paper published by the Australian Taxation Office on securitizations and the Taxation Laws Amendment (Taxation of Financial Arrangements) Act 2009.
Changes in German Tax Law under the UCITS IV Transformation Act
Authors: Angsten S.
Published: December 2023

The UCITS IV Transformation Act was recently published in the Federal Law Gazette. This article summarizes the major changes with special emphasis on the German Investment Tax Act implemented by the UCITS IV Transformation Act. The author adds some thoughts to anticipated developments in the asset management market of investment funds.
An Analysis of “Google Taxes” in the Context of Action 7 of the OECD/G20 Base Erosion and Profit Shifting Initiative
Authors: Uslu Y.
Published: December 2023

In this article, the author considers the influence of “Google Taxes” in relation to Action 7 of the OECD Base Erosion and Profit Shifting initiative regarding the prevention of the artificial avoidance of the status of a permanent establishment.
Mandatory Disclosure Rules Applicable to Reportable Arrangements: Portuguese Implementation of DAC6
Authors: Ochôa J.
Published: December 2023

In this article, the author discusses the origins of the mandatory disclosure rules in Portugal and implementation of the DAC6 in that Member State. In particular, he discusses the Portuguese approach to the transposition of the DAC6 and his interpretation of the Implementing Law.
The Microsoft Case: The International Taxation of Software Transactions in India
Authors: Mehta A. (Amar)
Published: December 2023

In this article, the author considers the implications of the recent decision of the Income Tax Appellate Tribunal in the case of Microsoft Corporation v. ADIT (2010) with regard to the taxation of payments in respect of software.
Commissionaire Agency Permanent Establishment Structures
Authors: Carreño F.
Published: December 2023

Part of the Comparative Survey. The French Supreme Administrative
Court recently decided in the
Zimmer
case that
a French subsidiary of a foreign parent company, which operated in France under
French law as a commissionaire, did not constitute a taxable French permanent
establishment in France of the foreign company. The case has been explained in
"
Zimmer
Case: The Issue of the
Deemed Existence of a Permanent Establishment Based on Status as a
Commissionaire" by Mr Pierre-Jean Douvier and Ms Xenia Lordkipanidze
(17 International Transfer Pricing Journal 4, 2010).
Country report about this issue on Spain.
An Analysis of the Supreme Court Judgment in the Vodafone Case
Authors: Patel V.T. , Shah R.
Published: December 2023

The authors analyse the Supreme Court’s ruling in the Vodafone case, in which the Court held that an offshore share transfer between two non-residents was not subject to tax in India.
Tax Offence of Failure To Pay VAT
Authors: Harteveld P. , Scotto d’Abusco A.
Published: December 2023

Due to the persisting economic crisis, companies and other VAT registered persons increasingly struggle to cope with VAT payment deadlines and may fail to pay their VAT debt within the set deadlines. This failure, in certain circumstances, can be punished by Italian criminal tax law. Nevertheless the Italian Supreme Court seems to have, at least in more recent circumstances, taken a more lenient approach before considering a taxable person guilty. In this article, the authors provide a general overview of the criminal tax offence, and conclude with a brief description of some current and potential future developments.
Incentives for High-Tech Manufacturing Enterprises
Authors: Strachuk V.
Published: December 2023

This note discusses tax and non-tax incentives offered to businesses resident in the new Chinese-Belarusian “Great Stone” Industrial Park.
Application of the DEMPE Concept in the Pharmaceutical Industry
Authors: Vallat G.
Published: December 2023

With the recent implementation of BEPS Action 8 and the revised chapter VI of the 2017 OECD Guidelines, a number of questions has arisen around transactions involving the use of intangible assets and especially around the substance required to claim their ownership – the so called DEMPE functions. The purpose of this article is to understand the practical application of the DEMPE concept to pharmaceutical companies active in the development, manufacturing and distribution of generic drugs.
How to Revitalize the EC Arbitration Convention: The New Recommendations of the Joint Transfer Pricing Forum
Authors: Di Cesare F.
Published: December 2023

On 14 September 2009 the European Commission issued a communication, COM (2009) 472 final, to the Council, the European Parliament and the Economic and Social Committee on the work of the EU Joint Transfer Pricing Forum from 2007 through 2009, along with a related proposal for a revised Code of Conduct for the effective implementation of the EC Arbitration Convention. If Member States do actually adopt the revised Code of Conduct, one may expect an enhanced exploitation of this formidable tool which has been devised to reduce double taxation arising from transfer pricing adjustments. This article considers the recommendations made by the Joint Transfer Pricing Forum, as well as the progress toward the efficient utilization of the Arbitration Convention and indeed the remaining flaws which will hinder its proper functioning.
Recent Developments in Taxation of Foreign Income and Assets in Pakistan
Authors: Hassan B.
Published: December 2023

This article provides recent legislative changes governing the taxation of foreign income and assets in Pakistan.
Voluntary Transfer Pricing Adjustments and Voluntary Payments of Tax: A
US Overview
Authors: Herrington M, , Lowell C.
Published: December 2023

The current international tax climate is high on the political agenda.
Public pressure and possible consumer actions may lead to voluntary payments of
corporate income taxes. Sometimes tax authorities morally appeal to companies
and individuals to make tax payments also where the statute of limitations has
expired. At other times tax authorities make repayments of taxes on the basis
of hardship considerations. The present survey of the International Transfer Pricing Journal will focus on the
phenomenon of voluntary payment of taxes and voluntary adjustments of transfer
prices. Country report on the United States.
The Multistate Tax Commission’s Alternative to Litigation
Authors: Bland R.
Published: December 2023

In this article, the author provides an overview of the Multistate Tax Commission’s alternative dispute resolution programme, which assists states as well as taxpayers with managing the risks and costs associated with litigating state tax disputes.
Tax Aspects of Financial Market Transactions
Authors: Takano C.A. , Przepiorka M.
Published: December 2023

The authors provide an overview of the aspects of the taxation of transactions on the Brazilian financial market, presenting the main issues that can affect the attraction of foreign investment, as well as challenges that arise under the current Brazilian legal framework in light of relevant tax issues worldwide, such as exchange of information on tax matters and the classification of hybrid financial instruments.
Infrastructure Projects, Public Project Partnerships and Taxation of Tax-Preferred Entities
Authors: Joseph A.
Published: December 2023

Infrastructure development is lagging behind and it is essential that public private partnership be encouraged to engage in that sector. This will require a concerted effort by the government to amend existing laws to facilitate such participation.
The New Portuguese Windfall Tax and Its Potential Effects
Authors: Moniz R. Botelho
Published: December 2023

In this note, the author provides an overview of and comments on Portugal’s new windfall tax on profits generated by companies operating in the fossil fuel industry.
Two Paths for Developing Anti-Avoidance Rules
Authors: Cui W.
Published: December 2023

The author discusses the administration of anti-avoidance rules in China, and puts forth the argument that anti-avoidance rules are being applied in China not only in the absence of the rule of law, but also parallel to the rule of law. He suggests that Chinese taxpayers and tax administrators collectively have the choice of pursuing discussions about the boundary between legitimate and illegitimate tax planning along two alternative paths. In one of these paths the rule of law figures as an important norm, while in the other it does not, and he discusses how each works in China.
Namaste and Welcome to Mumbai
Authors: Kaka P.F.
Published: December 2023

In my first year as President, I have the double pleasure of
presenting the 68th Congress of the International Fiscal Association (IFA), to
be held in Mumbai from 12 to 17 October 2014, and of welcoming you to my home
town.
More Legal Certainty regarding the EU VAT Treatment of the Charging of Electronic Vehicles (but This Is Not the End of the Road!)
Authors: Lamensch M.
Published: December 2023

In this column, the author analyses two guidelines of the VAT Committee related to the EU VAT treatment of charging electronic vehicles.
Pensions and Social Security Payments in Recent Tax Treaties
Authors: Law S.B.
Published: December 2023

In this article, the author examines how 73 tax treaties that entered into force in 2010 deal with different types of cross-border pensions and social security payments.
DAC6: Interpretation of the Hallmarks and the Main Benefit Test in Belgian and International Tax Practice
Authors: Philippe D.-E.
Published: December 2023

The Belgian tax authorities have announced that they will be carrying out the first DAC6 audits as from September 2022. In this article, the author focusses on the interpretation of reportable arrangements, as well as the impact of DAC6 on well-known planning structures in the Belgian and international tax practice (for example, arrangements involving the use of holding vehicles, fund structures, management incentive schemes and corporate restructurings).
Structuring tax-efficient investments from the European Union
Authors: Trivedi T.
Published: December 2023

A succinct and useful article on tax considerations that need to be
taken into account when structuring investments from the European Union into
India, including types of cross-border transactions, structuring principles,
entity structure planning, and international holding structures.
Favourable Ruling of the Danish National Tax Board on the Danish Anti-Avoidance Rules Regarding the US Check-the-Box Rules
Authors: Wind Andersen K. , Tabbert B.
Published: December 2023

Denmark’s National Tax Board published a binding ruling on 7 October 2013 that held that a transfer of shares in a Danish company did not trigger Danish taxation even though the US parent had made a check-the-box election with regard to the Danish entity. This note comments on the decision.
Taxation Changes in 2013
Authors: Waidyasekera D.
Published: December 2023

This article examines the taxation changes that have taken place in Sri Lanka during the year 2013.
Split Payment across the European Union – Review and Analysis
Authors: Gryziak B.
Published: December 2023

In this article, the author discusses the split-payment mechanisms either implemented or drafted among the EU Member States. In principle, there are two basic ways to implement such a mechanism: (i) a VAT account scheme (implemented in Poland and Romania, as well as in pre-accession Bulgaria); and (ii) a VAT withholding scheme (drafted in France and the United Kingdom). Mixed mechanisms also appear (in Italy and the Czech Republic). In the opinion of the author, the VAT withholding mechanism might be the best way to implement split payment.
Fiat State Aid Case Putting the EU Arm’s Length Principle to Bed?
Authors: Verlinden I. , De Baets . , De Deurwaerder J. , Timmermans V.
Published: December 2023

This article discusses the Fiat case next to the (potential) interplay and consequences thereof for the pending (informally called) Apple and Belgian Excess Profits cases.
Taxation under Dodd-Frank – Part 1
Authors: Hammer V. , Bush J.
Published: December 2023

One page of the behemoth Dodd-Frank Wall Street Reform and Consumer Protection Act is devoted to tax, but its tax implications range far beyond that page. This two-part article discusses the tax aspects of seven sections of the new law. The first part deals with bank capital and liquidity, “living wills”, the Volcker Rule, and banks as dealers in derivatives. The second part deals with securitization, derivatives and executive compensation.
Denying Tax Amortization for Goodwill in Corporate Restructuring – A Controversy Surrounding the Scope of Intangibles
Authors: Memon N.
Published: December 2023

This article analyses the tax amortization of goodwill against the backdrop of M/S Standard Chartered Bank Pakistan, a case decided by the Sindh High Court. The author reviews literature to ascertain the scope of intangibles. His findings suggest that goodwill is a melting pot of unidentifiable intangibles, He argues that the Court misapplied the ejusdem generis rule when interpreting the definition of goodwill in tax law of Pakistan.
VAT and Business Models for Charging Electric Vehicles
Authors: Merkx M.
Published: December 2023

Electric vehicles will play an important role in the future of mobility. In this article, the author addresses the VAT consequences of business models that offer recharging services by multiple providers through a single subscription. According to the author, the current VAT consequences undermine these business models and a deeming provision creating a chain transaction should be implemented.
Amendments to Finland's CFC regime
Authors: Helminen M.
Published: December 2023

After the 2006 judgment of the European Court of Justice in
Cadbury-Schweppes, it was clear that Finland's CFC regime, introduced in 1995,
had to be amended in order to bring it into line with the ECJ's judgment.
Finland amended its CFC regime accordingly, with effect from 1 January 2009.
After giving some background and describing Finland's old regime, the article
discusses the 2009 changes, including (among others) the exclusion of certain
states from the CFC regime, the treatment of permanent establishments and
losses, and the elimination of double taxation.
The Tax Treatment of Shareholder Loans in Germany
Authors: Weiss M.
Published: December 2023

This article describes the tax treatment of shareholder loan impairments under German tax law within the context of the German national participation exemption regime. In particular, the changes introduced by a recent amendment to the German Income Tax Act are highlighted. The article traces the historical development leading up to the legislative change and analyses the key features of the new provision.
Developments Regarding the Transfer Pricing Method for Exports of Commodities
Authors: Sá R.C., Caldas de
Published: December 2023

The author considers developments and advantages in the use of the PECEX method, which is used to determine transfer prices for exports of commodities, as well as challenges taxpayers may still face when applying this method.
Centralization of Intangibles and Transfer Pricing under BEPS and Finnish Tax Law
Authors: Penttilä S. , Isomaa-Myllymäki A.
Published: December 2023

This article discusses principal and holding company structures used by MNE groups, in particular those related to intangibles, including an assessment of such structures under the arm’s length principle of the OECD Transfer Pricing Guidelines and Finland’s domestic transfer pricing legislation. The article examines the pressure to change existing structures as a result of the OECD BEPS Project.
Adoption of Substantial Amendments to Transfer Pricing Legislation
Authors: Cooper J.L.
Published: December 2023

Ukraine’s transfer pricing rules have been substantially amended as part of a recent tax reform. This article presents an overview of the legal framework for transfer pricing in Ukraine in light of these changes and provides some insights into expected future developments.
The Place of Supply of Admission to Scientific and Educational Events within the European Union
Authors: Amand C.
Published: December 2023

The VAT package has simplified the B2B rules of the place of supply of services within the European Union. However, admission to scientific and educational events is still deemed to take place where these events take place. In this article, the author observes that the new rules applicable since 2011 are a source of double taxation and non-taxation. The author also analyses the concept of “undisclosed agent” and of “voucher” with regard to the distribution of tickets regarding admission to events.
Taxation of Dividends, Interest, Royalties and Technical Service
Fees
Authors: Bian J.
Published: December 2023

The author provides a detailed description of the taxation of
dividends, interest, royalties and technical service fees in China. The article
also looks at the tax treaty issues and recent measures introduced by the tax
authorities to counter tax avoidance.
Tax Treaty Classification of Netherlands-Source Income from Lucrative
Interests (Carried Interest)
Authors: Pötgens F.P.G.
Published: December 2023

This article discusses the tax treaty classification of
Netherlands-source carried interest (income from lucrative interests) earned by
non-resident taxpayers. The Netherlands legislator has created a specific
regime to tax this type of remuneration in order to discourage the granting of
such benefits. However, the article establishes that the effectiveness of this
regime may be restricted by Netherlands tax treaties and the Netherlands tax
liability of non-residents.
Australia’s Commitment to the OECD BEPS Programme
Authors: Joseph A.
Published: December 2023

Australia has always supported OECD efforts with regard to base
erosion and profit shifting. The author reviews action points in the Australian
Treasury’s scoping paper on risks to the sustainability of the tax base,
showing alignment with OECD action points.
The Brazilian Tax Implications of Cross-Border Remittances Arising from International Cost-Sharing Arrangements
Authors: Castro L. Freitas de Moraes e
Published: December 2023

In this article, the author considers the international tax implications for the parties involved of international cost-sharing arrangements and, in particular, the arguments supporting the non-imposition of various Brazilian taxes with regard to payments made in relation to such agreements.
Tax Accounting for Russian Foreign Private Issuers and Multinational
Companies
Authors: Levchenko Alex
Published: December 2023

Russian tax rules place great importance on primary documentation.
Specifically, expenses incurred in the International
Financial Reporting Standards accounting sense in a current quarter may require
a signed contract, a duly completed invoice and a formal act of acceptance
signed by both parties before being recorded for tax purposes. This may delay
the recognition of the expense for tax purposes leaving open the question of
whether or not and when the expenses are tax deductible.
The Relationship between Controlled Foreign Corporation Rules and Tax Sparing Provisions in Tax Treaties: A New Zealand Case
Authors: Arnold B.J.
Published: December 2023

This article discusses a recent New Zealand Court of Appeal case involving the relationship between New Zealand’s CFC rules and the tax sparing provision in the China-New Zealand Income Tax Treaty (1986). The Court rejected the taxpayer’s claim on the basis of a narrow, literal interpretation of the elimination of double taxation article of the treaty.
Violation of the Principle of Neutrality – Provision of a Vehicle to an Employee
Authors: Zhang W. (Wei)
Published: December 2023

In this article, the author discusses the strict interpretation of the term “rent” in the ECJ case QM. He analyses the possibility that the transaction is subject to VAT where the customer resides only when the employee pays rent in money, otherwise the transaction would be subject to VAT where the supplier resides. The author considers that it seems inappropriate and against the meaning and purpose of the VAT Directive to tax hiring (rent) of a means of transport differently depending on the existence of a remuneration in money.
Transfer Pricing Actions under the OECD BEPS Project: Impact on Turkey and Attitude towards the Project’s Outcomes
Authors: Aydın E.
Published: December 2023

The author analyses the impact on the Turkish tax inspection system, tax law and companies, of the transfer pricing Actions under the OECD BEPS Project; and investigates the attitude of Turkish senior officials, tax inspectors and company executives towards the BEPS Project and its transfer pricing Actions. This article is based on a survey that was conducted by the author.
Parliament
Authors: Valério C.
Published: December 2023

This overview highlights the Parliament’s report on how to reduce the EU VAT gap.
VAT Has Come of Age
Authors: Brederode R. van
Published: December 2023

Review of Thomas Ecker,
A VAT/GST Model Convention
, Doctoral Series 25 (IBFD 2013), 472 pages.
Footballer’s Share of a Transfer Fee and the Quasi-Payroll Tax on Excessive Severance Payments
Authors: Molenaar D.
Published: December 2023

This note examines two conflicting Netherlands decisions regarding the applicability of the quasi-payroll tax on excessive severance payments to a footballer’s share of a transfer fee.
Tax on Tech Giants for Electronic Services
Authors: Kabagumya F.
Published: December 2023

The Uganda Revenue Authority has started collecting VAT from non-resident companies providing electronic services to non-taxable persons in the Ugandan economy, effective 1 July 2022. This article highlights the measures Uganda is set to take in ensuring that there is effective control of base erosion and profit shifting by tech giants whose services are being enjoyed and utilized in Uganda.
An Innovative Approach to Overcoming the “Joint-Decision Trap”: EU Law Requirements for AVMSD-Based Financial Contributions from a Tax Policy Perspective
Authors: Kirchmayr S. , Geringer S.
Published: December 2023

The legal regime for financial contributions, established in the Audiovisual Media Services Directive (2010/13) (AVMSD), differs fundamentally from other tax-related EU measures. Instead of prescribing a minimum standard, the AVMSD defines the legal boundaries in respect of implementation. This new approach might help the European Commission advance its agenda to increase the European Union’s influence in the area of taxation more effectively. This article assesses these developments from a tax policy perspective.
Final Report on Action 6 of the OECD/G20 Base Erosion and Profit Shifting Initiative: Prevention of Treaty Abuse
Authors: Pinetz E.
Published: December 2023

The author, in this article, analyses the Final Report on Action 6 on “Preventing the Granting of Treaty Benefits in Inappropriate Circumstances” of the OECD/G20 Base Erosion and Profit Shifting initiative, especially with regard to the recommended inclusion of a principal purpose test and a new preamble in future tax treaties.
Tax Administrators, Taxpayers and Their Advisors: Can the Dynamics of the Relationship Be Changed?
Authors: Owens J.
Published: December 2023

In this article, Jeffrey Owens, the former Director of the Centre for Tax Policy Administration, OECD and now Senior Tax Policy Advisor to the Vice Chair Tax - of Ernst and Young gives his opinion on how to improve the relationship between tax administrators, and taxpayers and their advisors.
Selected Issues Regarding the New Italian Exit Tax Rules
Authors: Caltagirone L. , Villa R.
Published: December 2023

In this note, the authors analyse the extent to which the new Italian exit tax regime applies in the event of a qualified transfer of a branch of business characterized as the Italian permanent establishment of the foreign tax resident transferor, in relation to assets (and liabilities) that were not transferred but, at the same time, do not qualify (no longer qualify) as an Italian permanent establishment of the transferor.
How Often Do OECD Member Countries Update Their Tax Treaties?
Authors: Broekhuijsen D.M. , Vergouwen T.M. (Mees)
Published: December 2023

In this article, the authors report on the findings and the implications of their study on the time taken by the (founding) OECD member countries to update their treaty networks and align such networks with the (most recent version of the) OECD Model.
The Application of the Finnish General Anti-Abuse Rule in Light of Article 6 of the EU Anti-Tax Avoidance Directive (2016/1164) – Some Initial Thoughts
Authors: Scherleitner M.
Published: December 2023

In this article, the author discusses Finland’s decision to rely on its domestic GAAR in section 28 of the Act on Assessment Procedure for the sake of complying with the GAAR in article 6 of the EU Anti-Tax Avoidance Directive (2016/1164), and what this implies for the Finnish tax practice.
Anti-Abuse Measures in Tax Treaties Following the OECD Multilateral Instrument - Part 1
Authors: Bergedahl C.
Published: December 2023

In Part 1 of this article, the author examines the effects of the inclusion of anti-abuse measures in tax treaties following the implementation of the OECD Multilateral Instrument, together with the implications of this for the OECD Base Erosion and Profit Shifting initiative.
The Dutch Approach to the Attribution of Profits to Permanent Establishments
Authors: Sahin L. , Blanc B. le
Published: December 2023

In this article, the authors outline and comment on the Decree of the Dutch State Secretary of Finance on the attribution of profits to a permanent establishment, which was released in response to the 2010 amendments to Art. 7 of the OECD Model Tax Convention, as well as a recent announcement of the Dutch State Secretary of Finance regarding the Dutch tax treatment of foreign permanent establishments.
Oil Price Fluctuations and the Need for Tax Policy Reform in Qatar
Authors: Abdellatif M.M. , Eid A.G. , Tran-Nam B.
Published: December 2023

This article considers the implications for Qatar of fluctuating oil prices, the problems that this raises regarding the balance between reducing government expenditure and the adverse effect on growth, and the need to use tax policy to stabilize the economy and diversify revenue and develop a more comprehensive tax system.
Twenty Years of Change to the Treatment of Services in the OECD Model and the UN Model
Authors: Peters C.
Published: December 2023

In this article for the 75th anniversary issue of the Bulletin for International Taxation, Carmel Peters provides her views on the various changes that have been made to the treatment of services in the OECD Model and the UN Model since the turn of the century.
Controlled Foreign Company Legislation, Corporate Residence and
Anti-Hybrid Arrangement Rules
Authors: Maisto G.
Published: December 2023

An assumption of the OECD Base Erosion and Profit Shifting initiative
is that a holistic approach should be adopted. This article suggests that the
reshaping of controlled foreign company rules should be coordinated with
changes to corporate tax residence and anti-hybrid arrangement rules.
Transfers of non-performing loan portfolios
Authors: Gotlib G. , Burman G. , Hoberman J.
Published: December 2023

In recent years, Argentina and other Latin American countries have
faced some significant macro-economic and financial crises. These crises
generated related losses, but also notable business opportunities. This article
considers the acquisition of a large portfolio of distressed debt, particularly
certain legal, tax and accounting issues. The recent worldwide financial crisis
may generate similar opportunities, and the experience noted in this article
may be useful for potential investors and sellers.
Technology Can Solve MTIC Fraud – 2
Authors: Williams C. (Chris)
Published: December 2023

In his recent article “Technology Can Solve MTIC Fraud – VLN, RTvat, D-VAT certification”, Richard Ainsworth discussed the three main options that claim to be capable of resolving missing-trader VAT fraud, and concluded that real-time VAT collection (RTvat) is the only solution that is actually capable of preventing that type of fraud and limiting several other forms of fraud. In this follow-up article, Chris Williams briefly responds to Richard Ainsworth’s reservations as regards the central auditing function that forms part of RTvat’s proposal for real-time VAT collection. Richard Ainsworth has the final word in this discussion on the merits of real-time VAT collection in general and RTvat in particular.