bluuebunny/crossref_metadata_2025 huggingface dataset:
Dede Korkut'taki Demirkapı
Authors: EYÜBOĞLU Dursun Can
Published: December 2023

Eski Türk yaşamının destani bir yansıması olan ve Türk tarihi, coğrafyası, dili, edebiyatı, kültürü, sanatı, müziği, hukuku, inanışları gibi birçok alanda değerli bilgiler içeren Dede Korkut Destanları dün olduğu gibi bugün de birçok araştırmacıyı kendine çekmektedir. Dede Korkut’ta birçok yer adı geçmektedir. Bunlardan biri Demirkapı/Demür Kapu Dervendi/Kapular Dervendi/Kapulu Kara Dervend/Karaderbent/Derbent’dir. Demirkapı’nın adı Dede Korkut Kitabı’nda beş boyda geçmektedir. Dede Korkut’taki Demirkapı, destanın alt coğrafyasında Türklerin anayurdu Orta Asya’da ve Avrasya’dadır. Dede Korkut’un alt coğrafyasının önemli bir tabakası Göktürk-Türgiş dönemiyle ilgili olup Dede Korkut’taki Aladağ, Karadağ, Karaçuk, Kazılık Dağı, Türkistan, Amıt Suyu/Amu Derya, Demirkapı vb. birçok yer adı destanın tarihi coğrafyasını yansıtmaktadır. Türk tarihinde birçok yer Demirkapı/Derbent olarak bilinmektedir. Bu yerler özellikle de Türk devletlerinin diğer devletlerle sınır bölgelerini oluşturuyordu. Bu Demirkapı’lardan ikisi çok ünlüdür ve eski Türk tarihinin bir yansıması olarak, Dede Korkut Destanları’nda adı geçen Demirkapı’lar bunlardır. Birinci Demirkapı, Orta Asya’da Amu Derya yakınlarındaki Demirkapı’dır. İkinci Demirkapı, Hazar Denizi’nin batı kıyısında, Kafkasya’nın kuzeyindeki Demirkapı’dır. Gerek Orta Asya, Avrasya, Doğu Avrupa coğrafyasında gerekse Anadolu-Azerbaycan coğrafyasında Demirkapı adını taşıyan çok sayıda yer vardır. Bu makalede, Dede Korkut’taki Demirkapı; destanın alt coğrafyası ve üst coğrafyasındaki yeri incelenmiştir.
Maybe all the camels are wrong
Authors: Wedel Matt
Published: December 2023

Suddenly it’s camel season here at SV-POW! In the last post, Mike was having some doubts about how far back camels could get their heads. That got me curious, so here are the results of 45 minutes worth of Google Image Search. This live baby camel (source) has its neck extended about as far as the presumably dead juvenile camel from the last post, so that pose is not just mechanically possible, but also achievable in life.
Things to Make and Do, part 6c: fragments of ostrich skull
Authors: Taylor Mike
Published: December 2023

After the third simmering, Veronica the Ostrich Head started to come apart beautifully — more so than she should have done in one or two places, as it became apparent that her skull, as well as being incompletely fused due to presumed subadult age at time of death, was slightly damaged.
Veronica the ostrich: right cervical rib #3
Authors: Taylor Mike
Published: December 2023

For reasons that seemed good to me at the time, I took my best shot at photographing the right cervical rib from cervical vertebra 3 of my ostrich, Veronica [see earlier Part A, Part B and Part C for context].  I thought you might like to see the result, so here it is: Third right cervical rib of subadult female ostrich (Struthio camelus), total length 23 mm. (Total length of the rib, I mean, not total length of the ostrich.) Left column:
How to Reform Taxation of Corporate Groups in Europe
Authors: Oestreicher A. , Spengel C. , Koch R.
Published: December 2023

There are at least two reasons why taxation of corporate groups in Europe calls for reform. Firstly, differences are to be found between the tax treatment of a corporate group and that of a single legal entity. Secondly, foreign subsidiaries are often subject to different tax treatment than their domestic counterparts. Against this background the paper discusses the provisions currently prevailing in the taxation of corporate groups in Europe, in view of tax neutrality criteria and the requirements arising from European law. Furthermore, a number of reform proposals are developed and evaluated. In this context it is considered whether, and if so how, shortcomings in prevailing corporate tax law (interperiod loss offset, deduction of participation-related expenses) could be overcome. Moreover, the introduction of group taxation elements departing from the separate-entity theory, as well as the introduction of a consolidated scheme, are considered as potential reform proposals.
A Computational Legal Analysis of Acte Clair Rules of EU Law in the Field of Direct Taxes
Authors: Schaper M.G.H.
Published: December 2023

What rules of EU law in the field of direct taxes are clear and can be applied at the national level without additional interpretative guidance of the Court of Justice of the European Union (CJEU)? This article applies computational methods, and network science in particular, to analyse which rules of EU law in the field of direct taxes may be considered “clear”. The aim of this article is to find units of information which have replicated through repeated application in the CJEU’s rulings and are thus dominant in this functional field of EU law. All 185 rulings handed down by the CJEU in the field of direct taxes in the period between 1983 and 2012 are analysed. The product of this research is reported in the Annex in which the most important settled and well-established rules of EU law in the field of direct taxes are organized in a legally relevant manner.
In Search of the Digital Nomad – Rethinking the Taxation of Employment Income under Tax Treaties
Authors: Kostić S.V.
Published: December 2023

In this article, the author raises major policy questions, which emanate from the new digital economy setting, regarding the current normative framework for delineating taxation rights over employment income in our tax treaties, namely article 15 of the OECD/UN Models (2017). The author questions our reliance on the tax residence of individuals as the safe anchor for attributing taxation prerogatives, as well as our understanding of how and where employment is exercised. Furthermore, the author shows that labour law developments are making our tax treaty rules, which are currently based on the belief in the existence of a common international understanding of the concepts of employment and employer (employment relationship), increasingly inoperable. Based on the provided analysis, the author suggests amendments to article 15 of the OECD/UN Models (2017) to improve their alignment with the new digital reality.
Third-Party Liability for the Payment of Taxes and Their Fundamental Rights
Authors: Baker P. , Pistone P. , Perrou K.
Published: December 2023

This article examines, from a human rights perspective, certain instances establishing the liability of third parties, other than the taxpayer himself, for the payment of taxes, such as the obligation to withhold taxes or the joint and several liability of a third party (i.e. a company’s director) for the payment of taxes due by another person. Such obligations may imply a substantial liability for taxes and often are coupled with sanctions, and also a liability for the infringement of a growing number of formal obligations, including filing returns and reporting data, raising concerns of compatibility with the fundamental rights of taxpayers and private parties. The authors argue that it is doubtful whether the need to secure a more effective protection of the interest to collect taxes can justify exposing third parties to substantive obligations in connection with taxable events for which they are not directly liable or where no specific involvement of that person in a scheme of tax avoidance or evasion is established. Moreover, such compulsory involvement, which is currently imposed without remuneration and without any consideration of the additional burdens that it creates, raises some concerns from the perspective of fairness. The authors propose that a possible solution to some of these problems in the cross-border scenario could be found by amending the Recovery Directive (2010/24), so that states could rely more on mutual assistance within the European Union and less on third-party liability for the collection of taxes.
Risk Management at a Time of Systemic Uncertainty: Transfer Pricing Implications of Intra-Group Reinsurance Quota Share Arrangements
Authors: Siravo E. , Chand V. , Foth G.
Published: December 2023

This study addresses an underexplored and highly topical area regarding the international tax implications of risk management, examining some core methodological questions surrounding the transfer pricing aspects of intra-group reinsurance in depth. The study first provides an overview of traditional property and casualty reinsurance risk transfer structures. It then focuses, in particular, on proportional quota share reinsurance arrangements in both external and intra-group settings. Additionally, it highlights the key entrepreneurial risk-taking functions in the insurance sector and examines potential transfer pricing remuneration methods for quota share reinsurance arrangements in intra-group transactions. The latter points are illustrated through case studies.
VAT E-Commerce Package: Customs Bugs in the System?
Authors: Messina S.
Published: December 2023

The VAT e-commerce package heavily reforms rules applying to imports of small consignment goods. Yet, import VAT literature strictly focuses on a VAT perspective only. Vice versa, this article, favouring a customs law point of view, underlines issues that might undermine the effective enforcement of the new import VAT platform collecting model. The author reaches three main conclusions. Firstly, article 14(4)(2) would either fail to cover current business models or lead to uneven application among Member States. This would emerge from a cumulative interpretation of Directive (EU) 2017/2455 and Council Implementing Regulation (EU) (2019/2026). Secondly, since the introduced measures fail to take into account customs shortages and to coordinate with customs rules, they increase complexity rather than enhancing simplicity. Thirdly, the liability regime introduced by the reform might end up being stricter than intended. This, on the one hand, would shift liability from customs, posts and non-European suppliers to import platforms borne under an uncertain liability regime, which might require platforms to meet higher standards of proof, and, on the other, could prove to lead to indirect discrimination between EU and non-EU goods.
The Historical Origins and Current Prospects of the Multilateral Tax Convention
Authors: Avi-Yonah R.S. , Lempert E.
Published: December 2023

This article has three aims. First, it surveys the pre-BEPS efforts to create a multilateral tax convention (MTC) from the 19th century onward, and explains why these efforts have failed, leading to an international tax regime dominated by unilateralism and bilateralism. Second, it contrasts the success of multilateralism in investment and trade law. Third, it examines the BEPS era efforts to create an MTC and suggests that, while there has been more convergence of the tax laws of countries, a fundamental divergence of interests persists that will likely doom any such efforts to failure. The article concludes that, at this time, tax law still remains unsuitable to multilateralism, in contrast to investment and trade law, mainly due to the monetary impact.
International Taxation of Directors’ Fees: Article 16 of the OECD Model
or How To Reconcile Disagreement among Neighbours
Authors: De Jaegher C.
Published: December 2023

This contribution analyses the taxation of directors’ fees in an
international context, as prescribed under article 16 of the OECD Model. After
a preliminary assessment of the provision and its relationship to the other
provisions in the Model, two essential questions are defined. The first part of
this article focuses on the conditions for the application of article 16 of the
OECD Model and their interpretation in the Belgian-German double tax treaty
practice. In the second part of this contribution, it is examined how taxing
rights are attributed once the conditions of application of article 16 of the
OECD Model are fulfilled. In the light of the fundamental principles in the
allocation of taxing rights, it is analysed whether the article is consistent
with the other provisions on income from services in the OECD Model.
Joint Audits – Ten Years of Experience: A Literature Review
Authors: Criclivaia D.
Published: December 2023

Aiming to identify new opportunities for future research on joint audits (JAs), a literature review is conducted to reveal the major insights arising from the last ten years (e.g. the countries implementing JA, the number of ordinary and pilot project cases, costs and failures of JAs). In terms of the methodology applied, a total of 116 published works, spanning authors from 17 countries, were found. The analysis included: the year of publication; most-cited articles and authors; most-active journals and publishers; authorship and affiliation; type of study; and related topics addressing the JA. The findings provide evidence that there are an increasing number of JA studies, approximately 11 publications per year, but that this overall trend is mainly the result of an increase in studies published in Germany. The data suggests that the number of publications addressing JA is decreasing in other countries. The data demonstrates a strong correlation between the number of JA cases and the number of publications. Ninety-five per cent of German studies are published in German, which makes it difficult to capture the experience and knowledge worldwide. None of the research papers found address the topic of JAs on an empirical basis. Most publications have focused on an examination of the legal framework, JA pilot projects analysis, real cases discussion and research on the obstacles to an efficient JA procedure. Various authors have presented their own approach to defining, providing a final result and the legal bases of the JA, which are sometimes similar to the OECD proposal to audit cross-border activities jointly, and sometimes different. Representatives of the tax administration are responsible for publishing half of all publications. The Bavarian Ministry of Finance seems to be the world’s leading testing ground on JAs to date.
The Definition and Ownership of Intangibles: Inside the Box? Outside the Box? What is the Box?
Authors: Wilkie J.S.
Published: December 2023

The examination by the Organisation for Economic Co-operation and Development (OECD) of how to take account of “intangibles” in a transfer pricing analysis opens the door to a critical review of important but sometimes understated questions about the significance of the “arm’s length principle”, and the capacity of that principle and the Transfer Pricing Guidelines that manifest it to capture “economic value” inherent in a multinational enterprise as an economic “firm” though possibly not transferred according to typical transactions on which transfer pricing analysis generally depends. This paper examines the meaning of “intangibles” and “ownership” in the context of transfer pricing generally and the OECD’s Discussion Draft entitled “Revision of the Special Considerations for Intangibles in Chapter VI of the OECD Transfer Pricing Guidelines and Related Provisions” (6 June to 14 September 2012). It considers, as does the Discussion Draft, whether legal or accounting notions need or should be expected to govern the significance of these terms in a transfer pricing analysis. The paper also raises questions about how, and how readily, the manner of conceiving “intangibles” contemplated in the Discussion Draft would be accommodated by countries’ tax and private law, and discusses how significant the answers to these further questions may be not only for the effective application of OECD guidance on “intangibles” but in relation to more general questions about how countries may successfully and sustainably assert jurisdiction to tax income of an MNE which somehow may be connected to or originate in those countries.
International
Tax Coordination for a Second-Best World (Part III)
Authors: Schön W.
Published: December 2023

In the first two parts of this article (1 World Tax Journal 1
(2009), p. 67 and
2 World Tax Journal 1
(2010), p. 65) the author has laid out basic elements of an
international world order for the taxation of business profits. Under the
assumption that no general principles (ability-to-pay or benefit principle)
preordain the allocation of taxing rights among countries, this framework
should take into account the mechanics of tax competition among jurisdictions,
as well as the internal business model of internationally active corporations.
Insofar, the article pleads for a “continuity approach” which tries to avoid
sudden switches of tax treatment which might prevent efficient allocation of
resources within a business framework. In particular he proposes international
tax allocation on a “sales and services” basis exceeding the traditional
permanent establishment threshold, he compares treatment for incorporated and
non-incorporated establishments and advocates equal treatment of controlling
and portfolio shareholdings. Source taxation of interest and royalties may
contribute to the “continuity approach” in order to keep all kinds of business
income within the same tax treatment, but this is not advisable as far as tax
competition goes. In this third part of the article, the choice of
business organization by multinational enterprises is the object of the
analysis. The starting point is the current “arm’s length vs. formulary
apportionment” debate. The author pleads for an extended version of the arm’s
length standard which he sees to be in line with the “continuity approach” as
it interferes as little as possible with business decisions such as “make or
buy”, “integrate or non-integrate” or the choice between a corporate group and
a unitary enterprise. Nevertheless, while the allocation of income to the
corporate entities within a multinational group should follow the contractual
arrangements between the parties at arm’s length, this should not be the last
word: the non-resident related party should be taxed on “synergy rents” it
derives from the group structure, in particular the use of intangibles and
other production factors relying on sunk specific investment. Insofar, the
personal allocation of income and the territorial allocation of revenue should
not automatically correspond; it is up to the source state to tax rents derived
by the non-resident party as far as tax competition allows such a
move.
Assessment of the Interest Barrier Rule of Article 4 of the EU Anti-Tax Avoidance Directive for a Sample of European Firms
Authors: Petutschnig M. , Rechbauer M. , Rünger S.
Published: December 2023

This study investigates the economic consequences and the effectiveness of the interest barrier rule of article 4 of the EU Anti-Tax Avoidance Directive on an EU-wide basis. The analyses performed are based on a sample of 492,977 firms from 21 EU Member States. The economic consequences of the interest barrier rule are fairly small. Without an allowance and an exemption for stand-alone firms, the findings indicate that between 13.97% and 17.29% of all EU firms will be affected by the interest barrier. This percentage decreases substantially, to between 0.51% and 0.81%, if an allowance of EUR 3 million is granted. When evaluating the effectiveness of the interest barrier, the results show that the interest barrier is effective in aligning interest deductibility with real economic activity in the vast majority of EU Member States. Moreover, it is more effective than a thin capitalization rule with a safe harbour debt-to-equity ratio. The results obtained provide valuable insights for lawmakers as to how to choose effectively among the legislative options provided by article 4 of the EU Anti-Tax Avoidance Directive.
Fairness in International Tax Recovery Assistance: The European Court of Justice as a Driving Force for the Respect of Fundamental Tax Debtor Rights
Authors: Vandenberghe L.
Published: December 2023

This article addresses some aspects of the impact of the fairness requirement on international administrative cooperation for the cross-border recovery of taxes and the influence of the case law of the European Court of Justice (ECJ) in this area. This case law relates to the interpretation of EU law in this field (currently the Recovery Directive (2010/24)). Council Directive 2010/24 of 16 March 2010 concerning mutual assistance for the recovery of claims relating to taxes, duties and other measures, OJ L 84 of 31 March 2010, p. 1, Primary Sources IBFD [hereinafter Recovery Directive (2010/24)]. This directive has effect from 1 January 2012. It is, however, also relevant for the interpretation and application of other international agreements relating to mutual assistance in the recovery of taxes.
Freedom of Religion and Church Taxes in Europe
Authors: Obrist T. , Gonin L.
Published: December 2023

Although freedom of religion seems, prima facie, to have little
relevance to taxation, church taxes raise many interesting legal questions in
relation to this human right. In this contribution, the authors identify
potential issues linked to the levying of church taxes when taxpayers are
individuals. They also raise the question as to whether taxpayers' freedom of
religion is violated when they pay general taxes whose revenue is used,
directly or indirectly, to finance the activity of a religious organization
they do not belong to. In addition, they pay attention to the question of
entitlement to the freedom of religion of spiritual communities, other
non-profit aiming legal persons as well as profit aiming legal persons, and
examine whether a compulsory church tax for legal persons violates their
freedom of religion.
A Common Corporate Tax Base for Europe: An Impact Assessment of the Draft Council Directive on a CC(C)TB
Authors: Spengel C. , Ortmann-Babel M. , Zinn B. , Matenaer S.
Published: December 2023

After intensive and extensive preparation, the European Commission released the long-awaited proposal for a Council Directive on a Common Consolidated Corporate Tax Base (CCCTB) on 16 March 2011. In the context of the Europe 2020 Strategy, major objectives of the proposed CCCTB are the elimination of transfer pricing concerns, the removal of double taxation due to conflicting tax claims between Member States and, of course, the reduction of tax compliance costs. However, as the second and the third step of the proposed CCCTB, i.e. the consolidation and the allocation mechanism, still suffer from considerable shortcomings, we recommend introducing the CCCTB in two steps. In this context, our paper focuses on the first step of a CCCTB, i.e. the common corporate tax base (CCTB). The paper combines qualitative and quantitative analyses on the key differences and similarities between the proposed CCTB and current tax accounting practice in all 27 Member States, Switzerland and
the United States It offers not only a broad geographical scope, but also great detail in analysing the differences in tax accounting and quantifying the change in tax burden induced by the introduction of a CCTB in each Member State, Switzerland and the United States.
References to the OECD Commentaries in Tax Treaties: A Steady March from
“Soft” Law to “Hard” Law?
Authors: West C.
Published: December 2023

This article addresses, in part, the use of the OECD Commentaries with
respect to the interpretation of bilateral tax treaties. However, the article
has as its focus those instances in which a tax treaty or protocol to a tax
treaty, in the main, directly reference the OECD Commentaries as an
interpretational rule. Such direct references to the OECD Commentaries spark a
number of questions and reopen issues such as the hard law/soft law dichotomy;
the static versus ambulatory nature of the OECD Commentaries; policy reasons
for such inclusions and the consequences of such inclusions. This article
equally provides the base from which the rise of such references can be
monitored. The article collects and analyses the direct references, stratifying
these “rules” into types while looking for trends. While the number of
instances remains low relative to the total number of bilateral comprehensive
tax treaties worldwide, the inclusions of such rules equally open the debate
regarding the formation of customary international law. Currently, these rules
may simply achieve the aim for which they appear to have been created, being
the affirmation that the parties consider the OECD Commentaries as a key
interpretational resource and, although still to be tested, to force the courts
to actively consider the rules in making judgments in tax treaty matters.
Tax Abuse and Aggressive Tax Planning in the BEPS Era: How EU Law and the OECD Are Establishing a Unifying Conceptual Framework in International Tax Law, despite Linguistic Discrepancies
Authors: Piantavigna P.
Published: December 2023

The article aims to demonstrate how EU law and the OECD are establishing a unifying conceptual framework in which the two different seminal phenomena, “tax abuse” and “aggressive tax planning”, can be acknowledged in the new (global) operating environment. The purpose of this article is to critically assess the meaning of these concepts, broadly used in several EU and OECD soft law instruments. These concepts cannot be completely formalized or objectified, but the resulting uncertainty of their application can be reduced to an acceptable level. In the search for a useful reference point to delimit tax abuse from aggressive tax planning, particular attention is paid to the definitions conveyed (and the wording used) by EU institutions and the OECD. Indeed, the purpose of this article is also to establish a starting point for the discussion on linguistic discrepancies that can arise, and it provides for a preliminary categorization of them. Further to the analysis of these discrepancies, the article explains the reciprocal influences between the European Union and the OECD, and highlights how the promotion of a theoretical understanding and careful empirical handling of the relevant practices should enrich the discussion and foster consistent implications. In particular, how consensus on the development of a linguistic and conceptual framework could enhance the resolution of some issues is emphasized and, more specifically, to what extent EU law allows the BEPS Project to be applied in the EU area, knowing that EU institutions cannot provide for any ex ante guarantee on the compliance of BEPS with EU law. To ensure that the important goals of global tax coordination – that the implementation of the BEPS Project implies – are achieved, this contribution aims to delineate preliminary clarifications in these areas.
Controlled Foreign Corporations as Fiscally Transparent Entities. The Application of CFC Rules in Tax Treaties
Authors: Canè D.
Published: December 2023

Controlled foreign corporation rules are a fundamental piece of the international tax regime. They preserve national tax bases from erosion and profit shifting, counteract tax deferral and implement capital export neutrality policies. However, the application of these rules should be coordinated at treaty level, which would also serve to avoid undesirable policy effects. The legal framework of tax treaties, as integrated by the Multilateral Convention, is now ready to support such a coordinated application of CFC rules. The new set of provisions for transparent entities can be used to this end, on the assumption that certain CFCs should also be treated as transparent entities. Indeed, CFC rules patterned after the transparency approach produce effects and involve problems comparable to transparent partnerships. This article elaborates on some of these problems and illustrates how the new provisions dedicated to transparent entities interact with each other and allow a balanced application of treaties to CFCs as well.
Non-Discrimination and the Taxation of Cross-Border Dividends
Authors: Gammie M.
Published: December 2023

At a domestic level, dividend tax systems are usually designed to relieve the economic double taxation of corporate profits and are related to the personal taxation of savings income. Increasingly over the last 40 years, however, international considerations have intruded upon domestic tax policy. Source country taxation of corporate profits and residence country personal taxation of dividends have limited domestic tax policy options and decoupled corporate and personal tax systems. This article examines the issues for dividend tax policy in an international setting and the role of bilateral tax treaties in addressing those issues. The article explains how, within the European Union, the freedoms guaranteed by the EU Treaties have dictated Member States’ tax policy options. It concludes that general non-discrimination principles, in contrast to specific treaty provisions, have a limited role to play in resolving the competing claims of source and residence countries to tax the return on corporate activity.
IP Box Regimes and Multinational Enterprises: Does Nexus Pay Off?
Authors: Müller J.M. , Spengel C. , Steinbrenner D.
Published: December 2023

Over the last decades, the OECD and the European Union (EU) aimed at regulations that prevent aggressive intellectual property (IP) tax planning of multinational enterprises (MNEs). These regulations should stop the international race to the bottom of effective tax burdens. Contemporaneously, EU Member States enacted favourable tax systems for corporate research and development (R&D) activities in order to increase their location attractiveness. Especially, the output-oriented R&D tax incentives, namely IP box regimes, gained attention from a tax fraud perspective as well as popularity by national governments to generate public revenues. In this article, we qualitatively and quantitatively examine the European IP boxes. Thereby, we analyse their impact on IP tax planning and location attractiveness in light of the changes introduced by the OECD’s modified nexus approach. Our results demonstrate that even after introducing the nexus, a considerable reduction in effective average tax burdens is possible. Nonetheless, in line with the policy intention, the nexus effectively prevents excessive reductions of MNEs’ tax burden. Moreover, we account for changes in IP tax planning and observe implicit subsidies for the combination of output- and input-oriented tax incentives. Thus, these combinations reduce MNEs’ tax liabilities and finally, increase the location attractiveness in the post-nexus era.
Aligning Profit Taxation with Value Creation
Authors: Richter W.
Published: December 2023

The OECD seeks to align transfer pricing and profit taxation with value creation. This article argues that taking this objective seriously requires profit splitting. This is shown by applying Shapley value theory to the problem of allocating a firm’s profit tax base to the jurisdictions in which the firm is active. The application of cooperative game theory is justified with the argument that interjurisdictional cooperation on legal issues is a necessary condition for firms earning profit abroad. The profit tax base should therefore be allocated to jurisdictions according to standards generally considered as equitable when distributing the gains of cooperation. At least, this should be the primary objective, which finds its limitations only in the consideration of information and efficiency-related costs. This insight provides the basis for arguing for a two-step approach to profit taxation that has similarities to residual profit allocation but is conceptually and practically different.
PENDAMPINGAN GERAK DASAR PERATURAN BARIS BERBARIS (PBB) BAGI MAHASISWA PRODI PGSD STKIP CITRA BAKTI
Authors: Wani Bernabas , Natal Yanuarius R. , Bali Fromantius
Published: December 2023

Pendampingan gerak dasar peraturan baris berbaris telah menjadi bagian integral dalam pembentukan disiplin, kerja sama, dan pengembangan keterampilan fisik dalam berbagai konteks sosial. pengabdian yang dilakukan dalam upaya meningkatkan pemahaman dan implementasi efektif dari latihan gerak dasar peraturan baris berbaris. Pendampingan ini bertujuan untuk membentuk disiplin melalui aturan yang ketat dan latihan yang terkoordinasi, mengintegrasikan nilai-nilai disiplin, kerja sama, dan kepatuhan sebagai bagian dari pengembangan individu dan kelompok. Masalah yang dihadapi oleh mahasiswa prodi PGSD adalah kurangnya pemahaman tentang peraturan baris berbaris dan tata cara baris berbaris yang diwujudkan dalam bentuk Latihan fisik yang diperlukan, Tujuan dari pengabdian ini adalah untuk memberikan pengetahuan dan pemahaman kepada  mahasiswa prodi PGSD tentang gerak dasar Peraturan Baris Berbaris (PBB), Kegiatan ini dilakukan kepada mahasiswa prodi PGSD di kampus STKIP Citra Bakti Ngada, Kecamatan Golewa, Kabupaten Ngada selama satu bulan. Metode yang dilakuakn dalam pengabdian ini adalah pemaparan materi serta praktek langsung dilapangan selama 1 bulan, Hasil dari latihan gerak dasar PBB adalah mahasiswa mampu memahasmi dengan menyeluruh mengenai gerak dasar pada PBB, Adapun gerak dasar PBB yang dilakukan yaitu: sikap sempurna, istirahat ditempat, lencang depan, lencang kanan, hadap kiri,hadap kanan, balik kanan, hadap serong kanan, hadap serong kiri, berhitung, hormat dan jalan ditempat. Gerak dasar PBB telah dilakukan dengan baik dan memberi dampak positif bagi mahasiswa prodi PGSD.
MỘT SỐ DẤU HIỆU NHẬN BIẾT VÀ BIỆN PHÁP XỬ TRÍ, DỰ PHÒNG ĐỘT QUỴ NÃO
Authors: Nguyễn Hoàng Ngọc
Published: December 2023

TÓM TẮT: Đột quỵ não hiện đang là vấn đề thời sự của thế giới. Ở Việt nam, đột quỵ não gây tử vong đứng hàng thứ ba, gây tàn phế đứng thứ nhất. Bệnh có thể xảy ra do nhiều nguyên nhân khác nhau, song cần hết sức lưu ý trên những người có bệnh tăng huyết áp, hội chứng rối loạn chuyển hóa, bệnh vữa xơ mạch máu,bệnh đái tháo đường, những người bệnh có tiền sử đột quỵ não… Khi xảy ra đột quỵ não, người bệnh cần được phát hiện sớm, xử trí ban đầu đúng và can thiệp kịp thời tại các cơ sở y tế đủ năng lực. Dự phòng bệnh lí đột quỵ não trên các đối tượng có yếu tố nguy cơ cao, nhận biết sớm các dấu hiệu bệnh lí và chẩn đoán đúng, can thiệp kịp thời làm giảm tỉ lệ di chứng nặng nề, nâng cao chất lượng điều trị. Chúng tôi nêu một số dấu hiệu nhận biết bệnh lí đột quỵ não, biện pháp xử trí ở quân y các tuyến và dự phòng bệnh để quý độc giả cùng tham khảo.
CƠ CẤU BỆNH VÀ MỘT SỐ YẾU TỐ LIÊN QUAN TẠI KHOA Y HỌC CỔ TRUYỀN, BỆNH VIỆN TRUNG ƯƠNG QUÂN ĐỘI 108, TỪ NĂM 2017-2021
Authors: Lê Thị Quế  , Vũ Văn Đại  , Đào Thị Thúy Ngọc , Nguyễn Thanh Tùng
Published: December 2023

Mục tiêu: Mô tả thực trạng cơ cấu bệnh lí và một số yếu tố liên quan đến cơ cấu bệnh lí, tại Khoa Y học cổ truyền, Bệnh viện Trung ương Quân đội 108.
Đối tượng, phương pháp: Nghiên cứu mô tả cắt ngang hồ sơ bệnh án của 100% lượt người bệnh điều trị tại Khoa Y học cổ truyền, Bệnh viện Trung ương Quân đội 108, lưu trữ từ năm 2017-2021.
Kết quả: Tại Khoa Y học cổ truyền, Bệnh viện Trung ương Quân đội 108, từ năm 2017-2021, có 4.886 lượt người bệnh điều trị nội trú. Người bệnh trung bình 63,7 ± 15,1 tuổi, tỉ lệ giới tính nam/nữ là 1,30. Tỉ lệ người bệnh ở độ tuổi từ 61-75 tuổi là 41,1%; sinh sống ở khu vực thành thị là 75,6%; hưởng chế độ bảo hiểm y tế là 97,3%; điều trị nội trú từ 10-14 ngày là 45,3%; có can thiệp bằng các thủ thuật điều trị loại 2 là 87,2%; kết quả điều trị khỏi hoặc đỡ, giảm chiếm 99,2%. Cơ cấu bệnh lí thể hiện 10 nhóm bệnh thường gặp là: thoái hóa cột sống (21,4%), liệt nửa người (7,7%), thoái hóa đa khớp (3,7%), suy nhược thần kinh (3,6%), nhồi máu não (3,2%), đau lưng (2,9%), bệnh cột sống khác (2,8%), thoái hóa khớp gối (2,7%), u lành tính cột sống (2,2%), đau đầu (2,1%). Khác biệt có ý nghĩa thống kê về tỉ lệ 10 nhóm bệnh thường gặp (p < 0,05) và có mối liên quan giữa cơ cấu bệnh với độ tuổi, giới tính, khu vực sinh sống của người bệnh (p < 0,05).
Viejos y nuevos desafíos en la educación superior argentina
Authors: Marquis Carlos
Published: December 2023

Este libro es el cuarto volumen de la colección de Las Agendas Universitarias que la Universidad de Palermo inició en 2004 con la publicación del primer libro y consolidó en esta década con la publi- cación de La Agenda II en 2015, La Agenda III en 2017 y ésta, La Agenda IV. En los libros anteriores se puso el acento en las políticas públicas, analizando las existentes y proponiendo las que parecían necesarias para el desarrollo y mejoramiento de las instituciones universitarias y del sistema que las contiene. El trabajo actual lleva como subtítulo Viejos y nuevos desafíos en la educación superior argentina. Propone discusiones y trata un conjunto de problemas, varios persistentes en el tiempo, otros novedosos y algunos prospectivos.
La Universidad ante el virus: lecciones y oportunidades
Authors: Rabossi Marcelo
Published: December 2023

Muchos cambios podrán esperarse vencida la situación de pandemia. Pero también algunas lecciones deberán aprenderse.

Previa a la llegada de la COVID-19, el flujo de alumnos internacionales en busca de educación de calidad superaba los 5 millones.
LOKALISASI PLAT NOMOR DENGAN JAVA MENGGUNAKAN DETEKSI TEPI CANNY DAN FILTER MORFOLOGI
Authors: Ulmiah Muis  , Yaumil Afwan  , Zahir Muhammad Adin
Published: December 2023

This study aims to introduce an automatic vehicle identification system based on vehicle licenses and license plate recognition. This Automatic Number Plate Recognition (ANPR) system software uses a series of image processing algorithms captured by a camera with a high degree of accuracy and has the efficiency to recognize license plates and then identify vehicles from datasets stored on a Personal Computer (PC). This study uses an algorithm for license plate localization by implementing the Canny edge detection algorithm and a morphological filter.The methodology used is to develop a Number Plate (NP) localization method including the following steps: (1) Color conversion, image enhancement (using sharpness filters and gamma correction), Canny edge detection and alignment (skeletonization); stage (2) morphological filter-based method to determine the Region of Interest (ROI), namely a rectangular box containing a Number Plate (NP). A rectangular bounding box is drawn across the area in the original image that contains the NP after the NP are localized. The bounding box is equal to the width of the image plus one pixel and the height of the NP plus one pixel.The results showed that this method succeeded in achieving a localization rate of about 72.0%. The method used for license plate localization is able to localize license plates with clear boundaries and unambiguous separation of other related components. This research can be further developed to include more functions so that it can be used by all elements of society from researchers to law enforcers.
MENCIPTAKAN KOTA CERDAS: MEMANFAATKAN AI (ARTIFICIAL INTELLIGENCE) UNTUK PENGEMBANGAN RUANG PUBLIK PERKOTAAN YANG CERDAS
Authors: Sriany Ersina
Published: December 2023

As cities continue to grow and face increasing challenges, the concept of smart cities has emerged as a solution to create sustainable, efficient, and livable urban environments. One crucial aspect of smart cities is the development of intelligent urban public spaces that cater to the diverse needs and preferences of residents and visitors. This paper explores the role of AI in the development of such spaces, focusing on how AI technologies can enhance their design, functionality, and user experience. It examines the application of AI in areas such as data analytics, user behavior analysis, sensor networks, and adaptive systems to create dynamic and responsive public spaces. Furthermore, it discusses the benefits, challenges, and potential ethical considerations associated with harnessing AI for intelligent urban public spaces development. Through this exploration, the paper highlights the transformative potential of AI in shaping the future of urban environments and fostering inclusive and sustainable communities.
PANDUAN PEMBELAJARAN MIKRO BAGI DOSEN DAN MAHASISWA
Authors: Hasnawati  , Aulia Evawani Nurdin
Published: December 2023

The aim of this research is to solve the problem of lecturers and students regarding the lack of microteaching guides at the Faculty of Art and Design, Makassar State University. Specifically, this research aims to develop a valid micro-learning guide for lecturers and students at the Faculty of Art and Design, Makassar State University. This type of research is research and development (R&D), is to develop microteaching learning guidelines. The development research model developed was adopted from the model developed by Thiagarajan, is to the Four-D model (Define, Design, Develop, and Disseminate). The Define stage is analyzing the needs of lecturers and students for microteaching learning. The analysis is carried out by observing and reviewing the needs of lecturers and students in microteaching learning, as well as reviewing literature related to microteaching. Design stage (design), after analyzing needs, the next step is to design a form of guide by making a storyboard, arranging the material included in the guidebook, creating learning scenarios, and creating assessment guides in microteaching learning. Develop stage (development), this stage is the stage of validating the micro learning guide that has been developed. and the Disseminate stage, the stage where the guidelines that have been developed are distributed to lecturers who teach microteaching courses and to students who program the courses. The number of validators involved in this research was two validators. Each one material expert and one media expert. Data collection techniques were carried out using observation, interviews, questionnaires and documentation techniques. Data analysis techniques were carried out using qualitative and quantitative descriptive analysis techniques. The research results show that the development of the microteaching guide went through four stages and was carried out in accordance with the research and development model developed by Thiagarajan, namely Define, Design, Develop and Disseminate. The microteaching guide for lecturers and students has been declared suitable for use in microteaching at the Faculty of Art and Design, Makassar State University.
Peningkatkan Kemampuan Berpikir Kreatif Peserta Didik Kelas VIII SMPN 18 Makassar melalui Penerapan Media Interaktif ClassPoint dengan Model Discovery Learning (Studi pada Materi Sistem Ekskresi)
Authors: Nurhayani H. Muhiddin  , Sitti Saenab  , Mutia Alfiyanti Muhiddin  , Ima Nur Hadisah Ilham
Published: December 2023

This study aims to determine 1) the level of creative thinking ability of class VIII students of SMPN 18 Makassar before and after the application of ClassPoint interactive media with the Discovery Learning model. 2) increasing the creative thinking skills of class VIII students of SMPN 18 Makassar through the application of ClassPoint interactive media with the Discovery Learning model 3) There is a significant increase in the average value of creative thinking skills after applying ClassPoint interactive media with the Discovery Learning model. This type of research is experimental research (experimental research) using the Pre-Experimental Design. The treatment is the application of ClassPoint Interactive media with the Discovery Learning model in the experimental class. The research population was all class VIII students at SMPN 18 Makassar for the academic year 2022/2023 which consisted of 10 classes with a total of 300 students. The research sample was determined by Purposive Sampling Technique so that class VIII8 was assigned with a total of 30 students. The instrument used in the study was a test instrument in the form of essay questions containing indicators of the ability to think creatively as many as 10 items. Data collection was carried out by giving a Pretest and Posttest. Data were analyzed with descriptive statistics and inferential statistics. The results of the descriptive statistical analysis of students' creative thinking abilities before application (pretest) were in the very less creative category with a value of 12.40 and after the application of ClassPoint interactive media with the Discovery Learning model (posttest) were in the moderately creative category with a value of 55.60. The increase in students' creative thinking skills is in the medium category with an N-Gain of 0.49. The results of inferential statistical analysis show that there is a significant increase in the average value of creative thinking skills after the application of ClassPoint interactive media with the Discovery Learning model.
Kesantunan Berbahasa Siswa Madrasah Aliyah Arifah Gowa Kelas X Dan Relevansinya Dengan Kompetensi Sosial Pembelajaran Bahasa Indonesia
Authors: Idawati Garim  , Juwita Pakri
Published: December 2023

Penelitian ini bertujuan mendeskripsikan bentuk kesantunan Siswa Madrasah Aliyah Arifah Gowa Kelas X yang relevan dengan kompetensi sosial pada pembelajaran bahasa Indonesia. Penelitian ini merupakan penelitian kualitatif deskriptif. Data dalam penelitian ini adalah tuturan siswa dalam bentuk kata, klausa, dan kalimat yang mematuhi dan melanggar prinsip kesantunan berbahasa berdasarkan teori Leech dan memiliki relevansi dengan kompetensi sosial. Hasil penelitian menunjukkan bahwa realisasi kesantunan berbahasa Siswa Madrasah Aliyah Arifah Gowa Kelas X terbagi atas pematuhan i prinsip kesantunan yang relevan dengan kompetensi sosial. Kesantunan Siswa Madrasah Aliyah Arifah Gowa Kelas X memiliki relevansi dengan kompetensi sosial meliputi pematuhan maksim pujian yang relevan kompetensi jujur. Kesantunan yang patuh pada maksim kebijaksanaan, maksim kedermawanan, dan maksim kerendahan hati memiliki relevansi dengan kompetensi tanggung jawab. Beberapa kesantunan yang patuh pada maksim kedermawanan dan maksim simpati juga memiliki relevansi dengan kompetensi peduli.
PERAN MODAL SOSIAL TERHADAP TINGKAT KESEJAHTERAAN PELAKU INDUSTRI RUMAHAN (PENJAHIT BUSANA) DI KOTA MAKASAR
Authors: A. Nur Maida  , St. Aisyah Hading  , Hamida Suryani
Published: December 2023

Micro-scale enterprises are one form of business venture to realize the level of community welfare in a non-formal environment. Home industry actors (fashion tailors) have their own ways of developing their businesses, for this reason this study aims to: 1. determine the transfer of knowledge obtained by home industry actors (fashion tailors) and 2. identify the role of social capital in the welfare level of home industry actors (fashion tailors) in Makassar City. The method in the research conducted was descriptive qualitative, namely with interview techniques, documentation, and questionnaires. The results of the research analysis show that 1. the transfer of knowledge obtained by home industry players (fashion tailors) in Makassar City in Parang tambung Village, Tamalate District is obtained from experience, knowledge and skills learned, attending training conducted by the Department of Labor and Cooperatives, courses and opportunities conducted by several free institutions, joining several tailoring communities and some of them continue the inheritance of parents' businesses that have been carried out, some open their own businesses with capital skills or loans based on education that is relevant to the field being run. And this industrial business is running well with promising profits. 2. the role of social capital on the welfare level of home industry actors (tailors).