bluuebunny/crossref_metadata_2025 huggingface dataset:
Conceptualizing Agri Nutri Information Framework for Mitigating Nutrition Security Challenges of India: A much-needed approach for Nutrition Security
Authors:   School of Agro and Rural Technology, Indian Institute of Technology, Guwahati- Assam, India, Idrishi Rubeka
Published: February 2022

India being an Agrarian economy relies mostly on its agricultural outputs every year, but the uncertainty in the agricultural system of India is very high. A large population (majorly rural) is undernourished, from which the tackle history has been very slow and is continuing which continuously questions about the nutritional security of India. Besides various efforts made by the Indian government, policymakers, and technology-driven approach there lies a huge gap between effective interventions to join these two nodes which are agriculture and nutrition. Understanding the importance of the Agri-Nutri Framework for diet improvement, generating incomes, maternal and child health, and care practices this paper collectively maps all the existing evidence along with agriculture- nutrition frameworks/ pathways studied till now. Thus, this paper gives a comprehensive and conceptually designed framework by delineating pathways between agriculture and nutrition, pathways of the nutritional and health impacts, and various impacts of the same on food policies, farm production, farm incomes, food prices, and agriculture–gender linkages.
Gestione dei liquidi e del sodio nella reidratazione per via endovenosa in età pediatrica
Authors: Ardissino Gianluigi , Vergori Antonio
Published: February 2022

Tornando indietro con la memoria a quasi 30 anni orsono, quando ero giovane specializzando in Pediatria, ricordo distintamente le personali incertezze e difficoltà ad acquisire un metodo per la corretta reidratazione del bambino. Ciascuno dei miei Maestri di allora sembrava utilizzare un approccio diverso e non univoco, come se l’argomento non avesse una sua regola precisa: c’era chi utilizzava sistematicamente la soluzione fisiologica, chi una soluzione ipotonica (a 20, 40 o 60 mEq/l di NaCl) e chi preparava la soluzione aggiungendo NaCl ipertonico alla glucosata. Per non parlare dei volumi da infondere e quindi delle velocità di infusione; anche questi gestiti con variabilità che non consentivano mai di derivarne una regola. In tali condizioni appariva impossibile imparare un metodo, forse anche perché, di fatto, un metodo non c’era. Le stesse mie difficoltà e incertezze le percepisco oggi negli specializzandi che si susseguono al nostro fianco come se il problema di una corretta reidratazione, per quanto basilare in Pediatria, rimanesse invariato nel tempo. La mia vita professionale mi ha poi portato dalla Pediatria alla Nefrologia pediatrica, ove l’equilibrio idrico ed elettrolitico sono elemento fondamentale del sapere. In tale contesto e per superare l’handicap una volta per tutte, ho sviluppato un metodo per la reidratazione del bambino che oggi credo sia giunta l’ora di condividere. Il metodo al quale alludo, infatti, si è rivelato efficace nel corso di decenni di attività non solo nelle condizioni di disidratazione semplice ma anche in condizioni estreme: dal prematuro di 380 g al ragazzone di 110 kg, dalla natremia di 99 mEq/l a quella di 203 mEq/l, dal disidratato con grave insufficienza renale (urea di 604 mg/dl) a quello con sindrome nefrosica (e albuminemia di 0,6 g/dl). A chi avrà la bontà di leggere questo nostro scritto e la pazienza di comprenderlo, promettiamo non solo di superare per sempre le incertezze e difficoltà che agitano i pediatri ospedalieri più giovani (e talvolta anche quelli meno giovani) nell’approccio alla disidratazione, ma promettiamo anche molte soddisfazioni nel veder puntualmente accadere quello che era stato preventivato e anticipato da una grande dimestichezza con la materia che consentirà loro di “giocare” con gli equilibri del sodio e dell’acqua e avere riscontri sempre positivi.
Il modello di gestione del bambino sovrappeso e obeso in Regione Emilia-Romagna: primi risultati
Authors: Fridel Marina , Broccoli Serena , d'Anchera Erica , Iaia Maurizio
Published: February 2022

Child and adolescent obesity is a complex, multifactorial but also largely preventable disease; as a consequence its management needs a multilevel and integrated approach to be successful. This article describes the Preventive Diagnostic Therapeutic Assistance Pathways (PPDTA) for children with overweight and obesity delivered by trained multidisciplinary teams in the Emilia-Romagna Region. The regional “Guidelines for early detection, assessment and treatment of childhood obesity” were launched in 2013 (DGR 783/2013) and in 2017 WHO/Europe mentioned them as good practice and Country example. Training in childhood obesity prevention and management was delivered for all the primary care paediatricians (PCPs) and the members of the multidisciplinary teams. The PPDTA is based on three progressive levels: Level 1: PCPs. Level 2: a multidisciplinary team consisting of paediatricians, sports medicine doctors, exercise specialists, dieticians and psychologists experienced in paediatric obesity defines the clinical condition of children referred by the PCPs and runs the lifestyle change multi-component interventions. Level 3: is carried out by specialized clinicians in the hospital setting on a multidisciplinary basis for children with more severe and complicated obesity. In case of therapeutic failure, the PCP refers the child to the second-level multidisciplinary team. The second-level assessment and intervention are conducted at public health departments or at public health centres. During treatment, each team member uses the same tools, such as motivational interviewing for encouraging behaviour change. A standard evaluation framework is in place to assess the quality and effectiveness of the weight multidisciplinary management services, with three types of regional evaluation indicators: anthropometrics, lifestyle changes (eating habits, sedentary and physical activity) and equity. An improvement in weight status was observed in both children and adolescents with overweight and obesity. Interventions targeting at specific behaviours, such as increasing fruit and vegetable intake, habitually eating a balanced breakfast and reducing sedentary behaviour have been found effective as well.
Uso di Cannabis in gravidanza: esiti a breve e lungo termine nella prole
Authors: Notarbartolo Veronica , Giardina Calogero Fabio , Lo Cascio Antonina
Published: February 2022

Cannabis is the most consumed drug in Europe, especially among adolescents. In last years, several studies have demonstrated that its use is increased in pregnancy and this could be a risk factor for the onset of neurodevelopmental disorders in offspring. Moreover, it is well known that low birth weight and preterm labour are associated with Cannabis use in pregnancy. We present the case of a newborn, small for gestational age, with a meconium aspiration syndrome and acute neurologic signs, whose mother used Cannabis during pregnancy.
Ethnomedicinal Plant Resources of Lakhimpur-Kheri District, Uttar Pradesh (India)
Authors: Kar Rasananda , Joshi Bhavana
Published: February 2022

In the present paper, 71 plant species under 61 genera belonging to 35 families used in folk medicines to treat 51diseases and conditions have been documented. Over half of all species reported are used for skin diseases, fever and stomachache. Leaves and the roots are the most commonly used plant parts, with almost half of all plants reported. The most common methods of remedy preparation are decoction and powder. Some wild plants are also used as vegetables, fruits, fibre, ceremonial, sacred, traditional beliefs and other various purposes.
Phenological accounts of some important plant species of Tarai region of Kumaun, Uttarakhand
Authors: Mathur Anjali , Joshi Hema
Published: February 2022

The paper presents observations on phenological studies conducted on 112 plant species of tarai region between 2008-2011.
Style Drift and Alphas: A Case Study in International Retail Funds
Authors: Goldberg Cathy S , Graham Carol M , Delgado Francisco A
Published: February 2022

This paper examines style drift and alphas for a sample of 110 international retail funds offered to individual investors. We show that when fund managers “deviate” from their stated categories, alphas are biased upward. While previous studies in the international stock arena typically employ theoretical constructs to benchmark fund performance, we employ an actual investable vehicle (tradeable ETFs) in the same categories as the funds. For the period 2002-2020, we show empirically that managers do indeed deviate from their stated fund categories with subsequent upward bias to their fund alphas. For over half of the funds in our sample, we find significant drift to emerging markets and to the US equity market. We observe that alpha is biased upward an average of 86 basis points for the retail funds examined in this study.
Using Repeated- Reading and Listening –While- Reading via Text-To- Speech APPs. in Developing Fluency and Comprehension
Authors: Abdel-Reheem Amin Eman
Published: February 2022

One of the challenges in teaching a foreign language is: finding appropriate ways to enable students to develop their reading fluency and comprehension. Repeated reading and listening-while-reading are two significant strategies that enhance students’ fluency and comprehension. This study aimed to develop fluency and comprehension of EFL college students. During the treatment, the teacher trained the students to use some free Text to Speech apps that support oral repeated reading RR and listening while reading LWR activities. Pre-post tests were used to assess students’ reading fluency and comprehension. Data obtained from the tests were analyzed statistically through SPSS software. Results indicated development in students’ reading fluency and comprehension. Conclusions suggested the use of RR and LWR through Text to speech apps to assist the reading skills of higher education students. It is recommended that TTS Apps are promising tools that can be integrated into reading instruction.
A study of rainfall , upper winds and divergence patterns associated with recurved monsoon depressions
Authors: MATHUR SQN. LDR. N. K.
Published: February 2022

The present study was undertaken with a view to compute mean pattern of rainfall, upper winds and divergence field associated with monsoon depressions which had recurved and started moving northward. Mean charts were prepared by pooling together data of six such depressions using a moving co-ordinate system.
The importance of moving tropical disturbances over the Indian Ocean during the summer monsoon
Authors: CADET DANIEL
Published: February 2022

In this paper, some results are given which help support the idea that the tropical disturbances propagating over the Indian Ocean during the northern summer, are an important phenomenon of the broad-scale Indian monsoon.

Time-longitude sections of cloudiness over the Indian Ocean during one month and a half of the 1975 summer monsoon stress the existence of moving disturbances: eastward-moving ones in the northern Indian Ocean and westward-moving ones in the southern Indian Ocean. These perturbations as well as their zonal propagation are also evidenced at ground level. From a comparative analysis with balloon trajectories, it is shown that they can have an influence on the low-level air flow circulation over the Indian Ocean.

The intensity of the Mascarene High Pressure, located near 3OGS, 5OGE, is studied in relation with the occurrence of the westward-moving disturbances. It is shown that these disturbances modulate the anticyclone intensity of the broad-scale monsoon system with a q\1asi-biweekly period. The relationship found by Findlater (1969) between the low-level cross-equatorial winds over Kenya and rainfall over the western coast of India is investigated with focus on the tropical disturbances propagating eastwards over the northern Indian Ocean. An increase of the intensity of the Somalia jet Occurs each time a perturbation originates over the western Arabian Sea and begins moving eastwards. The rainfall mechanism over the south part of the western coast seems to be linked to these perturbations and rainfall maxima occur a few days before the pressure minima. The relationship, with a 3-4 day lag between wind maxima over Kenya and rainfall maxima over the western coast can be well explained with the eastward-moving tropical disturbances
Measurements of crustal deformation in India
Authors: AGRAWAL P. N.
Published: February 2022

Development of instruments for the purpose of measurement of crustal deformation  at suitably selected location in Indian was started in 1967 at the Training in Earthquake Engineering , university of Roorkee. Now Several permanent observatory vaults have been constructed and limited measurement done employing the instrument developed. The basic consideration influencing the plan of such measurement in the field  have also been studied in detail. The paper briefly outline the salient features and the present status of these studied.
Estimated earthquake Probabilities in the northeast India and Andaman-Nicobar islands
Authors: RAO P. SITAPATHI , RAO B. RAMALINGESWARA
Published: February 2022

Gumbel's extreme values theory has been applied to estimate the probability of occurrence and return periods of the largest earthquakes in the northeast India and Andaman-Nicobar Islands The statistical model of Epstein and Lomnitz (1966) is discussed with reference to the Gumbel's extreme value theory. The mean lines of expected extremes based on 46 years data of yearly extreme values of earthquakes in the three regions are plotted separately and the mean return periods of the largest possible earthquakes with their probability of recurrence are estimated. The most probable largest earthquakes in the Richter scale that may occur in an year and in an interval of 50 years are also estimated and reported.
Precursory seismic observations in Himachal Pradesh S.K. 1976 and Shillong plateau
Authors: SRIVASTAVA H. N. , CHAUDHURY H. M.
Published: February 2022

Precursory changes in P-wave residuals were noticed before the earthquakes on 1 June 1969 (M=5.0) and on 15 May 1974 (M=4.8) near Shillong and another near Nurpur (Himachal Pradesh) which occurred on 23 January 1969 (M=4). For these earthquakes, decrease in P-wave velocity was observed one to two months prior to their occurrence.

Six monthly b values in Gutenberg Richter's frequency magnitude relationship showed a decrease in the value about 15 days and 3½ months before two other earthquakes of October 1969 and January 1970 in Himachal Pradesh. The decrease in b value for foreshocks as compared to the aftershocks was also noted for another earthquake on 5 November 1968.A well marked seismicity gap has been demarcated in Himachal Pradesh on the basis of epicentral distribution obtained with a close river valley project network of observatories. This could be Indicative of a possible damaging earthquake in the region.

The foreshock occurrence in the Himalayan region was investigated on the basis of data upto 1975. Although no relationship between the time of first foreshock and the main shock could be established, the results show that there is a time lag of about 10 hours between the observed foreshock and the main shock on several occasions. However, foreshocks could be detected much earlier in Himachal Pradesh where a close network of seismological observatories is being maintained.
Locating earthquake shocks by computer programming etc
Authors: PATHAK M. A.
Published: February 2022

The method for locating earthquake shocks, usually adopted, requires at least five different observatories and also the arrival time of seismic waves must be registered accurately.

An alternate method is, therefore, proposed based upon the tables of transit time difference of S and P waves, which requires only three results from three different observatories. Also the accuracy of registering the absolute arrival time of seismic waves has not much importance but only the relative time difference of arrival of primary and secondary waves is needed.
Ultrasonographic Assessment of Frequency of Maternal Hydronephrosis During Second and Third Trimster of Pregnancy
Authors: Jelany Saira , Farooq Syed Muhammad Yousaf , Rauf Fizza , Uzair Muhammad , Idrees Moeeza , Tariq Maryam , Iqbal Amjad , Gilani Syed Amir
Published: February 2022

The increasing occurrence of maternal hydronephrosis is causing concern across the world. Hydronephrosis during pregnancy is graded by using sonographic techniques. Objective: On ultrasonography, determine the consistency of maternal hydronephrosis during the second and third trimesters of pregnancy. Methods: A descriptive study was done at the Gilani Ultrasound center. There were following variables; trimesters, a baby's weight and three grades of hydronephrosis (Mild, Moderate and Severe). The data was collected based on these variables (Right, left). Pregnant women with kidney disease and without kidney disease were preferred. Pregnant women of all ages who are in their second and third trimesters of pregnancy are included in this study. Pregnant women in their first trimester and people with kidney problems were not included in the study. Toshiba and XARIO ultrasound machines and convex probe were used. SPSS version 21.0 was used to analyze the data. Results: With the standard deviation of 4.26, minimum 18.00, maximum 41.00 and mean of 6.85 out of 139 pregnant females were included according to age in this study.68 (48.9%) out of 139 were without hydronephrosis and 71 (51.1%) were with hydronephrosis.  Out        of        139 pregnant females 18 (25.4%) had moderate hydronephrosis, 53 (74.6%) had mild hydronephrosis. According to laterality 2 (2.8%) pregnant   females had bilateral hydronephrosis 20 (28.2%) had left  sided hydronephrosis and 48 (67.6%) had right sided hydronephrosis. During 3rd trimester 44 (62.0%) and during 2nd trimester 27 (38.0%). According to fetal lie 11 (15.5%) were transverse and 60(84.5%) were longitudinal. According to fetal position 46 (64.8%) were cephalic and 25 (35.2%) were breech. Conclusion: According to the findings, hydronephrosis is more common in the third trimester than in the second trimester. Mild hydronephrosis is more common than moderate and severe hydronephrosis.
The importance of sedation in patients admitted with COVID-19: a systematic review
Authors: Ferreira André Gonçalves , Ramos Elder Marcelo , Scriboni Andreia Borges
Published: February 2022

Analgesia and sedation are an integral part of the care provided to critically ill patients with COVID-19. These patients experience moderate to severe pain at rest and during standard care procedures. Objectives: The objective of this work is to identify the importance of sedation in patients hospitalized with COVID-19. Method: The Latin American and Caribbean Literature in Health Sciences (LILACS) and National Library of Medicine (MEDLINE) database were used to find scientific articles that were useful in clarifying this study. Results: An analysis and discussion of 5 experimental articles were carried out to fulfill the objective of this study. Conclusion: Regardless of the medications used, it is believed that it is essential that each ICU develop its management schemes for sedation, analgesia, delirium, mobility, and family involvement to achieve a consistent approach in the management of its patients and, thus, improve the clinical results.
TEKNIK PEMBESARAN IKAN KARANG DI KERAMBA JARING APUNG KAMPUNG BULO KECAMATAN TABUKAN SELATAN
Authors: Manganang Yessi , Saselah Jetti , Melupite Billy
Published: February 2022

Program Kemitraan Masyarakat tentang teknik pembesaran ikan di keramba jaring apung (KJA) Kampung Bulo Kecamatan Tabukan Selatan dilakukan untuk mengatasi permasalahan dari kelompok pembudidaya ikan dimana mereka selalu mengalami keterbatasan dalam penyediaan benih dan kurangnya pengetahuan tentang teknik budidaya ikan di KJA. Metode pengabdian dilakukan dengan cara pelatihan dan pendampingan bagi anggota kelompok untuk melakukan kegiatan pembesaran ikan. Adapun materi dan pelatihan yang diberikan adalah tentang teknik pembesaran ikan di KJA meliputi persiapan wadah, persiapan bibit dan penanganannya, pakan dan pengelolaan pakan. 

 

This Community Partnership Program (PKMS) on coral reef rearing technique in floating net cages (KJA) was conducted in Kampung Bulo, South Tabukan sub-district to overcome fisheries problems faced by the local fishermen. Their problems mainly stem from the lack of fish seeds and knowledge on how to cultivate fish in floating net cage. The method used in this PKMS included training and fisheries advisory service on how to rear coral reef fish in the floating net cage with main material presented covering floating net cage preparation, seed preparation and handling, feed and feed management.
PROGRAM KEMITRAAN MASYARAKAT STIMULUS PEMBUATAN PAKAN PROBIOTIK DARI BAKASANG UNTUK MENINGKATKAN SISTEM IMUN DALAM PENCEGAHAN PENYAKIT IKAN DI KAMPUNG BENGKA, KECAMATAN MANGANITU, KABUPATEN KEPULAUAN SANGIHE
Authors: Manurung Usy Nora , Susantie Darna
Published: February 2022

Budidaya ikan yang dilakukan oleh pembudidaya di Kampung Bengka, Kecamatan Manganitu masih bersifat tradisional dan sampai saat ini masih menggunakan pakan dari pabrik sebagai pakan utama dari ikan yang dibudidayakan. Kegiatan penerapan Program Kemitraan Pada Masyarakat Stimulus (PKMS) ini bertujuan untuk membantu petani ikan di Kampung Bengka Kecamatan Manganitu dalam pembuatan pakan probiotik dari bahan baku bakasang untuk meningkatkan sistem imun ikan, menanggulangi masalah penyakit ikan yang disebabkan oleh berbagai jenis patogen dan juga meningkatkan pertumbuhan ikan. Tahapan pelaksanaan kegiatan ini meliputi: penjelasan pengertian penyakit, faktor-faktor penyebab, cara-cara pencegahan dan pengobatan serta pembuatan pakan probiotik dari bakasang untuk meningkatkan sistem imun ikan. Dengan pemahaman yang benar dan kemampuan untuk melakukan tindakan apabila timbul masalah penyakit di lokasi budidaya, petani–petani ikan di daerah ini akan mampu menekan kerugian akibat penyakit dan dengan demikian penghasilan para petani dapat ditingkatkan. Selanjutnya hal ini akan berdampak pada peningkatan usaha budidaya ikan air tawar.

 

Fish farming carried out by farmers in Kampung Bengka, Manganitu District is still traditional in nature and is still using factory feed as the main feed for cultivated fish. The activity of implementing the Partnership Program in the Community Stimulus (PKMS) aims to help fish farmers in Kampung Bengka, Manganitu District in making probiotic feed from raw raw materials to increase the fish immune system to overcome fish disease problems caused by various types of pathogens and also to increase fish growth. The stages of the implementation of this activity include: explanation of the definition of disease, causative factors, methods of prevention and treatment as well as making probiotic feed from bakasang to increase the fish's immune system. With the correct understanding and the ability to take action if disease problems arise in the cultivation location, fish farmers in this area will be able to reduce losses due to disease and thereby increase the farmers' income. Furthermore, this will have an impact on increasing freshwater fish cultivation businesses.
Short-term effects of the COVID-19 pandemic on vascular surgical training in Scotland: a trainee’s perspective
Authors: Walter AM , Bradley NA , Guthrie GJK , Suttie SA
Published: February 2022

Abstract Background: The COVID-19 pandemic has caused signiﬁcant disruption to surgical training worldwide due to several factors, including the postponement of elective operating. This study aimed to evaluate the impact of the COVID-19 pandemic on vascular surgery trainees in Scotland. Methods: A voluntary questionnaire was offered to all specialty trainees in vascular surgery in Scotland, comparing two one-year periods before (period A, 1 March 2012 to 28 February 2020) and during (period B, 1 March 2020 to 28 February 2021) the COVID-19 pandemic. The questionnaire assessed multiple areas including demographics, annual review of competence and progression (ARCP) outcome, logbook completion and supervision level of eight index procedures. Results: All of the 11 eligible trainees completed the survey (100% response rate). No trainee had their ARCP outcome affected by the pandemic. Six (54.5%) had courses affected and seven (63.6%) were subject to rota changes. Of the eight index procedures, ﬁve procedures (62.5%) trended towards fewer procedures performed in period B (emergency open aneurysm repair (OAR), emergency endovascular aneurysm repair (EVAR), carotid endarterectomy (CEA), vascular access, percutaneous transluminal angioplasty (PTA)) and three (37.5%) trended towards more procedures performed in period B (elective OAR, elective EVAR, lower limb bypass), though these trends did not reach statistical signiﬁcance. Four (50%) of the index procedures were performed more frequently as primary operator. Conclusions: The pandemic has forced changes in surgical training but vascular trainees in Scotland have had minimal negative impact. This needs to be maintained for the trainees to progress in their surgical training, achieve required experience and competencies, in turn providing optimal patient care.
Environmental Taxes in OECD Countries: Recent Developments
Authors: Poncela Ana Carrera
Published: February 2022

The measures adopted so far by Public Administration to prevent the deterioration of the environment have proved insufficient, revealing a situation that is getting worse very rapidly. In this context, ‘green taxes’ appear to be the most interesting alternative at hand.This paper presents a summary of the general consensus, now emerging from related literature: it both provides the underlying principles for this form of taxation and explores its economic effects. At the same time, it reviews the current state–of–affairs by observing the countries of the OECD, and Spain. Finally, it introduces a series of conclusions, reflecting on the future of environmental taxation in Spain.
Action Against Capital Funds the Danish Rules on CFC Taxation and Thin Capitalization are Inadequate
Authors: Ronfeldt Thomas
Published: February 2022

This article focuses on the acquisition of Danish companies by foreign capital funds. Capital funds have now been denounced as tax evaders in Denmark, and the Danish government, including the Danish ministry of taxation, introduced measures to safeguard against the actions of capital funds on Danish territory in 2007. This article discusses the consequences of these measures and analyses their core elements in the light of Community law. Special attention is given to Danish rules on thin capitalization, CFC taxation, and the most recent safeguard against foreign takeovers which applies new a EBIT model.
The Columbus Container Services ECJ Case and Its Consequences: A Lost Opportunity to Shed Light on the Scope of the Non–discrimination Principle
Authors: Calderón Carrero Jose Manuel
Published: February 2022

This article examines the European Court of Justice’s (ECJ’s) judgment in the Columbus Container Services BVBA & Co. v. Finanzamt Bielefeld–Innenstadt (hereinafter ‘Columbus Container Services’) case (C–298/05). After a brief description of the facts and the decision, the authors critically analyze the ruling, in light of potential acceptance of horizontal comparability as opposed to the traditional migrant/non–migrant approach of the ECJ. A study of the ECJ’s case law on horizontal pairs of comparison, together with a possible legal background for this approach (single market principle), allows the authors to conclude that the German rules under scrutiny (switch–over clause in quasi–CFC situations) were in breach of fundamental freedoms. Finally, the authors also consider hypothetical consequences of Columbus Container Services for other problems at stake such as the future of anti–avoidance rules in the European context, rules on classification of foreign entities, consolidation regimes that might imply treaty overrides, or the compatibility of the credit method itself with EC law.
Article 21 of the OECD Model Convention: Past, Present, and Future
Authors: Detweiler Andrea
Published: February 2022

This paper describes the past, present, and future of Article 21 of the Organization for Economic Cooperation and Development (OECD) Model Convention (MC), also known as the ‘Other Income’ Article. Special attention is paid to the underlying principle of this Article and what income is covered. The League of Nations began dealing with double taxation in the early 1920s. In its draft conventions, there was no Other Income Article in its modern structure. However, the correlation of different articles in effect was no different than the modern Article 21(1) OECD MC. The Organization for European Economic Cooperation (OEEC) and OECD, which succeeded the League of Nations in its research on double taxation, were the first to adopt an Other Income Article in its modern structure. There was still some uncertainty in the beginning, however, as to what income was covered. Today, the OECD MC is still the most widely followed model in negotiations on double taxation conventions (DTCs). There are, however,some deviations from many articles. The income covered by the Other Income Article today seems quite clear. The underlying principle, which was the same from the very beginning of defining principles of international taxation, now possibly will undergo a change influenced by other MCs and current treaty practices.
IRS Issues Long–Awaited Temporary Regulations on Cost–Sharing Arrangements
Authors: 0 Baker & Mckenzie North America Transfer Pricing Group
Published: February 2022

The members of the Baker & McKenzie North American Transfer Pricing Group provide an overview of the long–awaited temporary cost–sharing regulations.This team includes Phil Carmichael (New York), Brian A. Cromwell (Palo Alto), Holly Glenn (Washington DC), Robert S. Kirschenbaum (Washington DC), Gregg D. Lemein (Chicago), Marc M. Levey (New York), Holly K. McClellan (Chicago), Margreet G. Nijhof (Amsterdam), John M. Peterson (Palo Alto), and Salim R. Rahim (Washington DC).

On 31 December 2008, the United States Treasury issued temporary regulations under Internal Revenue Code section 482 related to cost–sharing arrangements (CSAs). These long–awaited regulations are immediately effective and substantially change the landscape for CSAs as a result of the valuation concepts and methods applicable to contributions of resources, capabilities, and rights to the CSAs. The temporary regulations do, however, provide important grandfather rules for existing CSAs that are less draconian than the transition rules of the 2005 proposed cost–sharing regulations.Under these grandfather rules, taxpayers with pre–existing CSAs must take certain compliance steps during 2009 to maintain the qualification of their CSA.
The Limits of the EC Concept of ‘Direct Tax Restriction on Free Movement Rights’, the Principles of Equality and Ability to Pay, and the Interstate Fiscal Equity
Authors: Zalasinski Adam
Published: February 2022

The European Court of Justice’s (ECJ) direct tax case law based on the EC fundamental freedoms seems to have evolved over the last twenty years. Currently, the Court in answering questions referred by domestic courts seems to look for the boundaries of the fundamental freedoms as interpreted in direct tax cases. However, the final clarification has not been adopted yet. It appears that the issue is closely linked with the proper definition of the limits of the notion of ‘direct tax restriction on free movement’, which is prohibited under the Treaty. This article is aiming to systematize this difficult and delicate area of the ECJ’s jurisprudence and provide some suggestions for solutions.
Comments on the Proposed Article 7 of the OECD Model Convention
Authors: van Wanrooij Josine S.A.
Published: February 2022

This article discusses the ‘Discussion draft on a new Article 7 (Business Profits) of the OECD Model Convention’, dated 7 July 2008. The focus is on the first three paragraphs of Article 7 of the Model Convention (MC). Based upon this Draft, the term ‘profits of an enterprise’ of the first paragraph should be interpreted based upon the functional separate entity approach. Moreover, under the second paragraph the separate and independent enterprise fiction should be strictly applied. In line with this fiction, the Transfer Pricing Guidelines are now embedded in Article 7 of the MC. The current text of the third paragraph is completely deleted. The new text regards the attribution of ‘free’ capital to a permanent establishment.
Is a Closer Cooperation between the Organization of Economic Cooperation and Development (OECD) and the European Union (EU) Needed? A Practical Approach to Real-World Tax Issues C
Authors: Obhof Thomas J.
Published: February 2022

Over the last fifty-two years, the European Community (EC) has grown from six loosely connected states into a strong twenty-seven nation, federationlike power. The Community currently maintains a close cooperation with many organizations, one being the Organization of Economic Cooperation and Development (OECD). In today’s economic quagmire, the need to unite and work even closer on global issues is at its zenith. A consolidated Community voice, along with a unified Community mission to the OECD, could alleviate problems, misinterpretations, strengthen OECD policy, and save individual nations money. The author intends to show how certain Community procedures, in conjunction with an even closer cooperation with the OECD, could change current international tax policy, combat tax havens, and alleviate the need for a European Model Tax Convention.
The Achilles’ Heel of the Arm’s Length Principle and the Canadian GlaxoSmithKline Case
Authors: Vidal Jean-Pierre
Published: February 2022

By definition, a multinational earns income in more than one country. Two approaches can be used to establish the tax payable to each country: the separate accounting approach and the formula apportionment approach. Usually, it is assumed that the separate accounting approach is the obvious choice. However, as illustrated by a recent Canadian tax court case, this method has an Achilles’ heel. Since uniqueness and market imperfections are at the heart of the economic profit made by multinationals, it would only seem natural that the comparables necessary to calculate the arm’s length prices do not and cannot exist. These facts plead against the separate accounting approach.
Enhancing International Cooperation among Tax Authorities in the Assessment and the Recovery of Taxes: The Proposals for New European Directives
Authors: Caram Andres
Published: February 2022

On 2 February 2009, the European Commission issued two proposals for new Directives to improve the mutual assistance between the competent authorities of the Member States in the assessment and recovery of taxes, which repeal existing Directives issued in 1976 and 1977.

Relevant improvements of the proposed Directives are their broader substantive scope, the establishment of time-limits to provide the requested information, the use of new information technologies, the limitation of bank secrecy, and the non-imposition of a disproportionate administrative burden on the requested authority.

The issuance of the new Directives confirms the importance given by the European Commission to the cooperation among tax authorities to prevent international harmful tax practices that jeopardize the operation of the internal market and means a major boost for the harmonization process in the field of direct taxation within the European Community (EC).
Permanent Establishments in the Construction Industry
Authors: Bagri Neha , Rawal Radhakishan
Published: February 2022

In the case of Krupp Uhde GmbH, the Mumbai Tribunal has given a key decision on Construction Permanent Establishment (PE). Key learnings from the decision are as follows:

– For calculating the threshold period, consolidation of unconnected projects needs to be done only in cases where the Tax Treaty specifically provides for it.

– Date of commencement of existence of PE would depend on whether the activity is undertaken on stand-alone basis or is dependent on any past activities relating to the project.

– Intervening period caused on account of temporary and seasonal interruptions cannot be excluded.

– Threshold period is to be counted activity-wise, irrespective of the years involved.
Transfer Pricing and Community Law: The SGI Case
Authors: Baker Philip
Published: February 2022

This editorial has been written four days after the European Court of Justice (ECJ) released its judgment in the SGI case. By the time it is published, much may well have been written about that case. However, here are some preliminary observations.

Some cases have the potential to become seminal judgments and leading cases: this is perhaps one of those. At issue in the case was that compatibility of cross-border transfer pricing legislation within the European Union (EU) where no similar legislation operated in a domestic context. Had the case been decided the other way, Member States would have had to re-think both their transfer pricing legislation and other cross-border anti-avoidance legislation. Even so, there are important details in the judgment that may have wider ramifications.
A Mundane Journey to Vodafone Ruling and Its Aftermath in India
Authors: Sinha Vikash K. , Kumar Awanish
Published: February 2022

This article tends to underline the taxation of cross-border mergers and acquisition (M by analysing the recent Vodafone ruling rendered by the Mumbai High Court. It explains the whole transaction like a fairy tale and then move onto to highlight the actual problems as perceived by revenue. It further analyses the ruling in great detail and also points out what Vodafone could have done to avert the situation. Moreover, it also advocates for an international tax regime and sought to give some pragmatic solutions to the problem of taxation of cross-border M
Between Extremes: Merging the Advantages of Separate Accounting and Unitary Taxation
Authors: Joisten Christian , Herzig Norbert , Teschke Manuel
Published: February 2022

This article deals with the conflict between the different concepts of international profit distribution. There is a broad understanding that separate accounting is far from perfect. The separate-entity approach is criticized as it disregards economic integration and fails to account for synergy effects. The conceivable alternative – referred to as single-entity approach or unitary taxation – relies on formula apportionment that is seen as an arbitrary method of profit distribution. Therefore, one might come to the conclusion that both systems are flawed from a theoretical viewpoint as well as from their practical implementation. An alternative would be to regard separate accounting as the basic system and to supplement it with aspects of unitary taxation where necessary. By combining these methods one can benefit from the advantages of both while to some extent limiting the disadvantages of each.
The Inheritance Tax in Spain from the Perspective of Free Movement of Capital and Right of Establishment
Authors: Martínez Francisco Adame
Published: February 2022

This article analyses if fiscal measures established by European regions in this tax for the transmissions of properties, companies, or exploitations, and only applied when the goods or the activities are located in their territories, are compatible with the free movement of capitals as construed by the ECJ. The main issue is if under the case law of the Court there is any imperious reason of general interest that can justify the difference of fiscal treatment. Another interesting problem studied is the compatibility with the right of establishment of fiscal measures that condition the benefits in this tax to the recruiting or the maintenance of a number of workers in a certain area of a State member.
Advance Pricing Agreements: The Way Forward for India
Authors: Mahajan Kartikey , Singh Jasmeet
Published: February 2022

This article critically examines the importance attached to the introduction of Advance Pricing Agreements (APAs) in India under the upcoming Direct Taxes Code. After evaluating the types, constituents, and procedure of an APA and comparing the international standards adopted by many countries, the authors try to highlight the best possible APA mechanism that can best serve the needs of India-related transactions. Thus, the authors try to highlight the modifications required in the provision related to APA under the Direct Taxes Code, which will lead to an effective implementation of the APA programme.
Tax Burden on Foreign Direct Investments in the Asia-Pacific Region, India, and Russia
Authors: Finke Katharina , Fuest Clemens , Lohse Theresa
Published: February 2022

This article describes the tax regimes for corporations in the Asia-Pacific Region, India, and Russia and assesses the effective tax burden on domestic and cross-border investments of German and US-American investors. The calculation of effective tax burdens is based on the renowned methodology of Devereux/Griffith. This approach allows condensing the most relevant provisions of tax regimes into a broadly accepted tax burden measure. The results help evaluate the attractiveness of the respective investment locations from a tax perspective and identify the most relevant tax drivers.
The New Italian CFC Rules: EU Holding Companies Challenge the ‘Artificial Arrangement’ Assessment
Authors: Muni Simone , Scarioni Paolo
Published: February 2022

The new Italian CFC legislation applies, in some circumstances, also to companies resident within ‘non-blacklisted’ countries, unless it is proved, through a compulsory advance tax ruling, that the controlled foreign company (CFC) does not represent an ‘artificial arrangement’ aimed at achieving an undue tax advantage. This article is focused on the case of European holding companies and, after highlighting the conditions that trigger the application of the CFC legislation, analyses some elements and factors that could be used to evaluate whether or not a company represents an ‘artificial arrangement’ in the perspective of European Court of Justice (ECJ)’s judgments. Finally, this article discusses if the compulsory advance tax ruling is fully consistent with the freedom of establishment guaranteed by the European Treaty.
Flat but Fair: A Proposal for a Socially Conscious Flat Rate Tax in the Netherlands
Authors: Gradus Raymond
Published: February 2022

This article advocates the introduction of a flat rate income tax in the Netherlands. Such a system would lead to a better-functioning labour market and fewer administrative costs for employers. Progressivity would be achieved through tax credits at the household level. By itself, a flat rate tax usually has adverse distributional effects. However, if we allow the income-dependent health care contribution also to be given a flat rate, the distributional effects would be substantially less significant. This article further gives some recommendations for lowering the flat tax rate by shifting away from income taxes, increasing value-added taxes (VATs), and broadening the tax base. It concludes by showing that a marginal tax rate plus social security contributions of 33.25% is possible. The focus of this proposal is the Netherlands, but several aspects of it may be relevant to other EU Member States.
Domestic and Cross-Border Loss Relief in the European Union
Authors: Kok Reinout
Published: February 2022

In this article, the domestic and cross-border loss relief possibilities in the twenty-seven Member States of the European Union are being discussed. In this context, a comparable analysis of the various forms of domestic and cross-border loss relief within the Member States has been performed. It will be discussed under what conditions tax losses can be carried forward and carried back. Also the possibility of offsetting losses within a group of companies in the domestic context will be discussed. Regarding cross-border loss relief, this article shows in which Member States it is possible to offset losses of a foreign permanent establishment with profits of a local head office. Also, it is analysed which Member States allow cross-border loss reliefs in multinational groups of companies.
Valuation Issues in Transfer Pricing of Intangibles: Comments on the Scoping of an OECD Project
Authors: Oestreicher Andreas
Published: February 2022

After finalizing its revision of Chapters I and III of the Transfer Pricing Guidelines and adding a chapter on business restructurings last summer, in January 2011 the Organisation for Economic Co-operation and Development (OECD) embarked on a new project on the transfer pricing aspects of intangibles. Questions arising in this context cover a wide range of issues including, in particular, the methodologies and arameters used in valuation of such assets. Against this background, this article provides a brief summary of some fundamental valuation issues in transfer pricing of intangibles and looks at possible solutions. Corresponding guidance is based on relevant experience gathered when contributing to the discussion regarding transfer pricing aspects of valuing intangible assets that has been taking place in Germany over recent years.
Retroactivity: Swedish Practice on Legislation by Governmental Communication
Authors: Påhlsson Robert
Published: February 2022

Some European states apply an absolute prohibition of retroactivity in taxation, whereas others allow for retroactivity to various extent. A number of states apply different variations of a legislative technique that comprises press releases; special announcements; or, as in the case of Sweden, communications issued by the government. Such press releases and communications often have in common the effect of rendering legally binding, from the time of their publication, laws that are subsequently adopted by Parliament. In this article, this technique is subjected to discussion. An evaluation is presented on the use of retroactive tax legislation in Sweden over the past two decades.
Is the Tax Relevance of Data Really Explosive in the German Electronic Tax Field Audit?
Authors: Graf Kerssenbrock Otto-Ferdinand
Published: February 2022

German tax law requires retention of records whenever they are 'significant for taxation'. This applies to records written on paper and likewise to digital data. The latter are subject to electronic tax field audits. Tax auditors can require access to such digital data provided they are 'determining for the assessment of tax'. In both contexts - the obligation to retain records and the obligation to grant access to digital data - the taxpayer's duties depend on what is often unprecisely called the tax relevance of the data in question. It is the purpose of the following contribution to explore on the different content of the ambiguous term tax relevance in the different contexts and to explain where this term can be 'explosive' for German electronic tax field audits.
Amendments to Particular Turkish Tax Laws
Authors: Biçer Ramazan
Published: February 2022

The Law Numbered 6009 Regarding the Amendments in the Personal Income Tax Law (PITL) and Certain Laws has been promulgated upon its publication in the Official Gazette dated 1 August 2010 and Numbered 27659. The Law imposes changes in several tax subjects: income tax tariff applicable to the salaries and wages retrospectively from 1 January 2010, investment allowance limited to 25% of the corporate income without any period limitations, tax rate on gains derived on income stated in Temporary Article 63 of Income Tax Law, certain corporate income tax (CIT) exemption and exceptions, social and military exceptions in Value Added Tax (VAT) Law, and some other tax issues. In this article, these tax law amendments are deeply analysed from the points of personal income tax (PIT), CIT, and VAT and the subjects are expanded by examples.