bluuebunny/crossref_metadata_2025 huggingface dataset:
corpo feminino e a moda: suas implicações
Authors: Brito da Rocha Dilson , Candida Teixeira Ana Clara
Published: December 2023

A partir das relações existentes entre o consumo de moda e as construções identitárias individuais e sociais, este artigo tem por objetivo discutir a relação que se estabelece entre o corpo e a moda em meio a um aprimoramento da mulher nas estruturas de poder. Abordar-se-á como a moda pode ser uma forma de expressão do corpo feminino, o qual é cotidianamente perpassado por um sistema de relações de influências, sendo moldado ao padrão contemporâneo. E, contudo, com o corpo feminino ganhando cada vez mais espaço no meio social como fator de molde, há uma valorização das imagens corporais, quais, por vezes, determinam o fator de aceitação social na vida das mulheres. Analisado a partir de noções simplistas e biológicas, foi sendo controlado ao longo de sua construção histórica, por diferentes práticas de dominação, se tornando alvo de forças políticas e econômicas. Mesmo atualmente onde a mulher ocupa maiores espaços dentro da sociedade, as crenças enraizadas socialmente não se fizeram de outro modo e a adequação do corpo feminino como atributo de beleza continua sendo alvo de preocupação e pertencimento. Por ser elemento extremamente próximo ao corpo, tanto física quanto simbolicamente, a roupa é indissociável dele, e por isso deve ser capaz de revelar muito sobre os discursos que o tocam, a própria vestimenta sendo um deles.
Estratégias de Aprendizado Tangencial aplicadas em um jogo de Modelagem 3D para Animação
Authors: Bruggner Grassi Nicholas , Marcelino Denis
Published: December 2023

Este trabalho consistiu em desenvolver um protótipo de jogo para computador com intuito de facilitar o aprendizado sobre práticas corretas de modelagem 3D para Animação. A abordagem do aprendizado tangencial foi utilizada, já que ela consiste em ensinar como consequência de uma experiência divertida, impulsionando o jogador a buscar além do material contido no jogo. No caso do projeto, utilizou-se fontes de ensino sobre modelagem 3D para animação para a elaboração das fases, levando dois momentos ao jogador: aprender para a resolução da fase, e um modo desafio da mesma fase. Dentre os motores de jogos disponíveis no mercado, foi escolhido a Unity devido a uma afinidade pessoal com o método de desenvolvimento de jogos que a própria apresenta. O resultado foi uma das três fases em uma versão reduzida explicando conceitos chave de modelagem 3D para animação, possuindo apenas o modo aprendizado. Futuramente, após finalizar a implementação do modo desafio, serão realizados testes com um número arbitrário de jogadores para avaliar a diversão e o ensino tangencial percebidos por diferentes perfis. A métrica utilizada para avaliar o aspecto divertido de cada fase será a disposição espontânea e voluntária do jogador em tentar concluir o desafio ao menos uma vez em cada fase.
Effluent Management in Oil and Gas Extraction
Authors: Umar Abdulmumin , Enejoh Omejeh Timothy , Jibrin Rufai
Published: December 2023

The oil and gas industry is characterized by petrochemical industrial wastewater known basically as effluent, which typically contains various organic and inorganic components, naturally present or added during oil and gas processes. Thus, proper management or treatment is needed for reuse, discharge, or final disposal requiring complexity of the wastewater composition needing stringent discharge procedures, standards requiring combinations of treatment methods. 

Effluent being a complex mixture of different organic and inorganic compounds (mostly salts, minerals, gas and oils), is majorly generated during oil/gas production. The volume of effluent is increasing around the world, and as a consequence, its discharge to the environment is one of the global concerns. The various methods of effluent management have their own advantages and disadvantages when used for offshore or onshore units. However, comprehensive and deep-understanding of each issue can provide a guideline for better and more practical solutions to its management. In this work, various physical and chemical treatment methods are reviewed and the most effective recommended to proper effluent management that meets all international standard and enhances sustainability. In this study the Pre-treatment, treatment and post treatment approaches employed reduced the amount of impurities present in the effluent with varying pH of 7.2 and 7.8, COD of 30 and 60mg/L, BOD value of 45 and 54 respectively, TSS value of 80 and 60mg/L and TDS of 5200 and 4800.
Gradation of Cosmic Rays
Authors: Hashimoto Junichi
Published: December 2023

Humans follow the diurnal rhythm of the sun to form an internal rhythm of 24-hour cycles. On the other hand, when such restrictions are removed, an internal rhythm of 25-hour cycles reminiscent of the lunar cycle emerges. In addition, women’s menstrual cycles are also seen to be in sync with the monthly rhythms. In order to elucidate the truth behind these events, I created a new theoretical system (gradation theory) by combining the two facts of the orbital motion of the moon and the cosmic ray arrival. By applying it, I found that the human body rhythm is formed in dependence on external factors. In addition, a logical answer was derived from it about the nature of sleep. In the future, sleep will take an increasingly prominent place in human endeavors.
The Church as a Family of God’s People: An African Perspective
Authors: Amadi Rev Fr. Dr Igbokwe Anthony
Published: December 2023

The desire to belong is one important aspect of humankind. Certainly to be a member of a family is a blessing and more so to belong to God’s family—the Church. The article discussed extensively the Church and the African family using historical method. It was discovered that the first two attempts of Christianity into Africa failed because it was not rooted in African culture. The article plumed into some aspects of African culture that could help the Church in Africa to stand solid. It became clear that the model of the extended family system in Africa was paramount. Furthermore, the Incarnation model where Jesus incarnated himself into the Jewish culture was also to be adopted. In light of these analyses and discussions, the article recommended the implementation of inculturation as a way forward for the building of a solid well rooted African Church as a family of God’s people.
Understanding The Impact of the Maritime Shipping Industry to a Sustainable Economic Development
Authors: Dihayco-Garciano Atty. Marichu , Garciano Dr. Joselito R.
Published: December 2023

Majority of the Maritime teachers belongs to the age bracket of forty-one years old and above. Forty-five percent among them have units in the Masteral program. Around seventy to eighty percent of the Maritime teachers strongly agree that shipping has been an important human activity throughout history, particularly where prosperity depended primarily on international and interregional trade; other important marine transportation activities include passenger transportation (ferries and cruise ships), national defense (Naval vessels), fishing and resource extraction, and navigational service (vessel-assist tugs, harbor maintenance vessels, etc.); and that the Maritime transport is the backbone of the global trade and the global economy. Seventy- three percent agree that the Maritime shipping is considered an environmentally friendly mode of transport. Sixty-four percent among the respondents agree that the importance of shipping in supporting and sustaining today's global society makes it indispensable to the world and to meeting the challenge of the 2030 Agenda for Sustainable Development. Another sixty-four percent agree that Globalization identified labor markets overseas that encouraged transport of semi-raw materials and intermediate products where manufacturing costs were lower and such that the fuel types used in marine transportation are different from most transportation fuels. Hence, faculty trainings and orientations stretching on the impact of the Maritime industry to a sustainable economic development need to be conducted, both internally and externally from the school campus. The Maritime curriculum indeed has to be revitalized and reinvigorated to suffice the pressing demands of the Maritime industry for economic globalization.
Investigation of the Combustion Properties of Bio-Coal Briquette Blends of Prosopis Africana Pods
Authors: Usaka Elvis , Edeoja Alex Okibe , Ibrahim Jacob Sunday
Published: December 2023

This study investigated the properties of bio-coal briquettes made by blending coal with Prosopis Africana pods in order to determine the optimum biomass composition. The briquettes were produced using a hydraulic press at 10 MPa applied to coal: biomass compositions of 100:0, 80:20, 60:40, 40:60, 20:80 and 0:100% by weight of mixture and particle size of 600 μm. Cassava starch and Calcium Hydroxide acted as binder and desulphurization agent respectively. The physical, mechanical and combustion characteristics of the briquette samples produced were determined based on ASTM standards. Results revealed that bio-coal briquettes from produced Prosopis Africana pods can serve as an alternative energy source for heating and cooking applications in Nigeria. The results of analysing data from the physical, ultimate and proximate properties of the produced briquettes indicated that the optimum biomass composition for producing briquettes from coal and Prosopis Africana pods is 40% as its taps into the superior combustion characteristics of both the coal sample and biomass sample.
Comparison of the Structural Performance of Ballasted and Non-Ballasted Pavement of the Railway with the Help of Beam Models on Elastic Bed and Finite Element Model
Authors: Hadimuljono Joewono , Sudrajat Muhammad
Published: December 2023

Today, many countries are opting for ballast less paving of railways using concrete line slabs as an alternative. Ballast paving is particularly prevalent in high-speed lines, urban railways, as well as bridges and tunnels designed for high loads and speeds. The priority lies in ensuring that these lines are paved with proper structural performance, especially considering the mechanics of the line and the choice between ballast pavement and line slabs. This article delves into the structural modeling and analysis process of ballast and slabs for railway lines. Models for both ballast and slab lines under passage have been developed. The study investigates the train wheel load and the impact of bed conditions. Theoretical solutions, including the beam model on an elastic bed for ballast lines and the two-beam model for line slabs, have been presented. Multiple finite element models were explored using ABAQUS software, confirming the accuracy of the theoretical results with acceptable precision. This work establishes a suitable model for calculating the effects of vertical force on the line pavement structure and provides applications for comparing design performance between ballast and slab lines. The results highlight the optimal performance of the modeling and the superiority of the line slabs.
Building Information Modeling and Artificial Intelligence Based Smart Construction Management: Materials and Electrical
Authors: Adeel Muhammad , Zaib Shah , Awaz Muhammad , Ali Md Azgor , Prodhan Md Safiq Raihan , Akter Mst Julia , Hasan Md Mahmudul , Kalsoom Habiba , Ul Nissa Laraib , Amir Rabia
Published: December 2023

With the development of society and technological progress, the requirements of government regulatory departments for engineering construction efficiency, quality, and safety are constantly increasing. The traditional extensive construction process can no longer meet the requirements of modern construction industry development. Based on the shortcomings of traditional construction processes, the concept of intelligent construction has been introduced. The construction of new smart and digital twin (DT) cities is entering an explosive period. The application of building rapid modeling technology based on artificial intelligence (AI) and building information modeling (BIM) integration in smart cities has gradually begun new explorations and attempts, and its application value is becoming increasingly prominent. A brand-new auto-machine learning (auto-ML) integrated algorithm technology platform for 3D building modeling is being developed and improved over time by combining AI and BIM technology in a deep way. This allows for fast and accurate modeling as well as high-value scenarios in the smart city industry, including architecture, municipal engineering, roads, and bridges.
NEARPOD BIKIN GURU TIDAK REPOT
Authors: Nurhasanti Sri
Published: December 2023

This writing is formerly in the intention to make the writer easy in her teaching and learning in her class in the early of the existence of Covid – 19, when the students were too lazy to engage with the teaching and learning material. In order to solve this problem, then the teacher tried to find out the best teaching and learning media to make the students happy and enjoyable with the English lesson. Finally, the teacher found Nearpod as the best way to engage the students with the learning and makes them interested in learning English.   If formerly the active participation of the students in the teaching and learning is less than 50 %, after using this application, the involvement of the students’ participation increase as well as the result of the average class score. Formerly, the average score is between 78- 85 for grade IX F from the average minimum score 76. Besides that, the average scores of the other classes also increase. The number of students’ passing grade is also increasing from the former time. Before using this application, there are only about 16 -20, however, now it becomes around 29 even 32. The average score of every class is also increasing from 50 – 60, becomes 78 – 85. The weakness of this application is in the internet access. However, to cover this problem, the teacher still can send the asynchronous link to join back in another time.
Mickey Mouse: A British Tax Evader
Authors: N. S.
Published: December 2023

This short historical article from the Bulletin’s archive humorously describes the serious question of whether a discretionary tax amnesty by the revenue authority of the United Kingdom was lawful.
The Right to Recover Output VAT on Bad Debts: The Greek Legislation and the VAT Directive
Authors: Kouni D.
Published: December 2023

Bad debts have increased dramatically since the Greek financial crisis, with significant impact on the sustainability of businesses and their ability to survive. The VAT associated with these bad debts constitutes a de facto additional financial burden for businesses, which is why the VAT Directive allows for a mitigation of that cost. In this article, the author claims that the Greek VAT legislation on bad debt seems incompatible with the VAT Directive and should therefore be improved. The author also recalls that the VAT Directive provision on bad debt has direct effect and, in her opinion, Greek businesses could challenge the Greek VAT legislation, and obtain the right of a full refund of bad-debt-related VAT directly, before the national courts.
Casenote – Decision on Application of the Non-Discrimination Article under India’s Treaty with Japan
Authors: Susarla K. , Ravisankar R.
Published: December 2023

This article analyses the decision of the Delhi Bench of the Indian Income Tax Appellate Tribunal on the applicability of the provisions of non-discrimination as contained in article 24 of the India-Japan Double Taxation Avoidance Agreement on payments made by resident Indian entities to Japanese entities.
Permanent Establishments: The Latest Trends from the Brazilian Tax Authorities – A Case Law Update
Authors: Canen D.
Published: December 2023

In this article, the author demonstrates how permanent establishments (PEs) are treated under Brazilian domestic tax legislation, and examines recent jurisprudence that has held that there are PEs where they were previously not considered to exist and how this could affect business activities in Brazil.
Employee Share Schemes – Benefiting the Start-Ups
Authors: Joseph Anton
Published: December 2023

In June 2015, the Tax and Superannuation (Employees Share Schemes) Act No. 105 of 2015 on Employee Share Schemes was legislated, replacing the old rules contained in Division 83A of the Income Tax Assessment Act 1997 (ITAA 1997). This article looks at the changes brought about by the new law.
Opinion Statement of the CFE on ECJ Advocate General Opinions in Tax Matters
Authors: Confédération Fiscale Européenne
Published: December 2023

This is an Opinion Statement prepared by the ECJ Taskforce Members of the taskforce who took part in the discussion of this case were: Stella Raventos Calvo (chair), Isabelle Richelle, Philip Baker, Michael Lang, Pasquale Pistone, Daniel Gutmann, Volker Heydt, Franck Le Mentec, Albert Raedler, Axel Cordewener, Friedrich Roedler and Servaas van Thiel. The views expressed in this statement do not necessarily represent the views of individual members of the taskforce or of organisations with which any of the members are associated. of the Confédération Fiscale Européenne (CFE). The CFE is the leading European association of 32 national tax advisory organisations representing over 180,000 tax advisers.
Addressing the Ability of Tax Systems to Accommodate Financial Product Innovation: So Far, Have the Measures Adopted Been Effective?
Authors: Ruiz Colmenares M.
Published: December 2023

The author raises questions on the ability of tax systems to accommodate or respond to financial product innovations, by analysing whether they comply with three rules of thumb for tax policy design, namely: neutrality, simplicity and stability. From such a perspective, the author argues that the approach adopted contributes to having a more non-neutral, complex and unstable environment.
Resolution 5010/2021 on Transfer Pricing Reporting Obligations in COVID-19 Times
Authors: Meloni E.O.
Published: December 2023

This article discusses the new compliance transfer pricing measures including specific COVID-19 regulations and a simplified compliance regime, among others, provided by the Argentinean tax authorities.
Updating the Netherlands Treaty Network with African States: Better but Not Enough!
Authors: Hamzaoui R.
Published: December 2023

This article examines the tax treaties and amending protocols concluded by the Netherlands with African states following the publication in 2013 of its treaty policy note, with an emphasis on the balance between source and residence state taxation, new anti-avoidance rules and the OECD/G20 Base Erosion and Profit Shifting initiative.
Supreme Administrative Court’s Precedent on the Implementation of a MAP Result
Authors: Raunio M..
Published: December 2023

In this article the author explains and analyses the Finnish Supreme Administrative Court’s ruling SAC 2023:32 issued on 17 April 2023. The case considered the deductibility of a provided group contribution in a situation where the taxable result of a Finnish company A Oy was reduced in a reassessment due to a transfer pricing adjustment in France. The Supreme Administrative Court ruled that based on a MAP resolution, a loss to be carried forward had to be assessed for A Oy even if according to the national tax provisions on group contribution a provided group contribution could not lead to a taxable loss. The case considered tax year 2010 but, as analysed by the author, is relevant also after the implementation of the Dispute Resolution Directive.
Taxation of Private Equity Profits – Commissioner Delays Issue of Final
Tax Determinations
Authors: Butler M. , Pengelly J.
Published: December 2023

An update on the ATO’s announcement to indefinitely delay the
finalization of the draft Taxation Determinations (TDs) on the taxation of
private equity companies on investments in Australia. This is of concern to the
public as the draft TDs are fundamentally flawed and it is uncertain as to
whether they will be finalized in their current state, or if the ATO is
undertaking further reviews in this regard.
Council
Authors: Morales T.
Published: December 2023

This overview highlights the Council’s (i) conclusions on the future evolution of administrative cooperation in taxation, (ii) update on its overview of preferential tax regimes examined by the Code of Conduct Group (Business taxation), and (iii) approval of conclusions on progress made during the Croatian Presidency.
Parliament
Authors: Valério C.
Published: December 2023

This overview highlights the Parliament’s ECON Committee opinion on the Unshell Proposal.
Analysis of the Case Law on the Scope of Article 17 of the OECD Model: Issues Resolved and Yet to Be Resolved
Authors: Romero Topete L.A.
Published: December 2023

This article examines the case law surrounding the scope of article 17 of the OECD Model, the issues that have been resolved and those that are yet to be resolved.
ATAD 2’s Punishment of Disregarded Entities: Potential Italian Remedies for Double Taxation
Authors: Catucci N. , Scimenes F.
Published: December 2023

Among tax practitioners, the interrelationship between the EU anti-hybrid rules in ATAD 2 (2017/952) Council Directive (EU) 2017/952 of 29 May 2017 Amending Directive (EU) 2016/1164 as Regards Hybrid Mismatches with Third Countries, Primary Sources IBFD [ATAD 2]. and the US "check-the-box" regulations have been a source of debate since the initial drafts of ATAD 2. The debate seems to have reached a dead end in respect of intercompany services remunerated on a "cost-plus" basis. The present article, against this background, focusses on an actual case for the purpose of illustrating certain unreasonable effects produced by the Italian anti-hybrid legislation.
Ex Post Facto Considerations in Transfer Pricing of Hard-to-Value Intangibles: Practical and Methodical Issues with the HTVI Approach
Authors: Hagelin J.
Published: December 2023

The OECD Transfer Pricing Guidelines released in July 2017 contain updates from the BEPS Final Reports on Actions 8-10 (Aligning Transfer Pricing Outcomes with Value Creation) following the work by the OECD to align domestic rules affecting cross-border activities, strengthen international tax standards and improve transparency. The new additions to the Guidelines include a definition of hard-to-value intangibles, as well as a discussion on asymmetric access to information for taxpayers and tax administrations in valuations of such intangibles, among other things. It is concluded in the Guidelines that, due to this asymmetry, ex post facto results should provide presumptive evidence for tax administrations of the reliability of ex ante projections made by the taxpayer at the time of a transaction, referred to as the HTVI approach. Although argued by the OECD to be consistent with the arm’s length principle, the approach raises a number of questions related to its compatibility with the existing transfer pricing regime developed by the OECD, as well as its application in general. This article explores the purpose of the HTVI approach, evaluates the guidance so far released on the topic and identifies potential issues that may arise from its usage.
Czech Supreme Administrative Court: Landmark Decision on Taxation of Unrealized Foreign Exchange Rate Gains
Authors: Vorlíčková L. , Zoubek J.
Published: December 2023

In this note, the author discusses a recent Czech Supreme Court decision wherein the Court determined that unrealized foreign exchange rate gains do not constitute taxable income.
Casenote – Rules on Source of Income
Authors: Wong A. (Adeline) , Wong K.J. , Kong S.Y.
Published: December 2023

This article discusses the recent Court of Appeal decision concerning the geographical source of interest income for Malaysian tax purposes, in Civil Appeal No. W-01-471-2010.
Tax Base Defence: History and Reality
Authors: Lowell C.H. , Wells B.
Published: December 2023

The authors consider whether existing model treaties provide (i)
protection for the tax base of the respective countries and (ii) guidance to
MNEs for framing their effective tax rate strategies. The historical origin of
the OECD and UN Model Conventions is presented, along with suggestions for a
way forward under present circumstances.
The Multilateral Instrument Era – Measuring the Impact on India
Authors: Butani M.
Published: December 2023

In this article, the author discusses the ways in which the OECD’s BEPS Action 15 multilateral instrument may be adopted and interpreted in India. The author sets out the status of the instrument under the Indian Constitution, its interaction with domestic law and existing tax treaties, and the aids available to the courts for its interpretation. In this context, the article canvasses challenges faced by India arising from its OECD non-member observer status and its reservations in the OECD Commentary to certain interpretations of the language of the OECD model treaty.
The PPT in Post-BEPS Tax Treaty Law: It Is a GAAR but Just a GAAR!
Authors: Danon R.J.
Published: December 2023

In this article, the author discusses the principal purpose test (PPT) included in article 29 of the OECD and UN Models (2017), arguing in particular that while the PPT certainly permits a purposive interpretation, it may not be used to build into tax treaty law additional requirements that were never intended. Finally, the author concludes by looking at the other side of the coin and wonders whether a comparable “PPT” should not regulate the performance by States of their treaty obligations.
Opinion Statement of the CFE on the Consequences of Involvement in Missing Trader Fraud
Authors: Confédération Fiscale Européenne
Published: December 2023

This is an Opinion Statement prepared by the CFE Fiscal Committee. The CFE is the leading European association of the tax profession with 33 national tax advisory organisations representing over 180,000 tax advisers.
Practical Information on European VAT
Authors: Annacondia F. , Corput W. van der
Published: December 2023

As is traditional in the first issue of each year, the green annexpresents the key features of the VAT systems of most European countries (both EU and non-EU), including standard and reduced VAT rates, various thresholds, the format of the VAT identification numbers and contact details of the offices of the national tax administration which process VAT refund applications or provide information to non-resident businesses on national VAT rules. The overview is compiled by the editors on the basis of information provided by the International VAT Monitor’s correspondents at the beginning of 2014.
Slump Sale – Indian Government Plugs the Tax Loophole
Authors: Bilaney S.K.
Published: December 2023

Slump sale is one of the preferred strategies of business restructuring, as it is easy to execute, the tax implications are unambiguous and also it can be structured in a tax-efficient manner by exploring the loopholes in the provisions. Recent amendments by the Finance Act 2021 close these loopholes and this article analyses these implications on business restructuring and M&A deals.
A Comparison of R&D Tax Incentives in Turkey
Authors: Dilmen A. , Erdoğan E.
Published: December 2023

Tax incentives play a crucial role in the decision-making process of companies and individuals engaged in R&D. To stimulate R&D investment in Turkey, the government has introduced several pieces of incentive legislation, mostly tax allowance and exemption schemes, each taking a different approach. This article focusses on three major incentives, namely Law No. 4691 on the Technology Development Zones Incentive, Law No. 5746 on Promoting Research, Development and Design Activities and article 5(B) of the Corporate Income Tax Law.
Canada Revenue Agency
Reports on Its APA Programme for 2007-2008
Authors: Scott Wilkie J.
Published: December 2023

This article provides an overview of the current state of the APA
programme in Canada. Topics considered include reports on the APA programme
issued by the Canadian tax authorities and the transfer pricing methodologies
most commonly seen in Canadian APAs.
Treaty Benefits Denied for Capital Gains Where Shareholder Not “Real” Owner of Shares
Authors: Dugar A. , Bhandari L.
Published: December 2023

This case note reviews the ruling issued by the Authority for Advance Rulings to AB Mauritius, which stated that, because AB Mauritius held shares in an Indian company in name only, the gain derived on an intra-group transfer of the shares did not escape tax in India under article 13(4) of the India-Mauritius income tax treaty. Instead, the Authority determined, on the basis of the share purchase agreement and board meeting minutes, that, in reality, the shares in the Indian company were owned by AB Mauritius’s United States owners and the gain on the transfer of the shares was taxable in India in accordance with the India-United States tax treaty.
Consumption Taxes and Their Ramifications for Income
Distribution
Authors: Shome P.
Published: December 2023

This article is based on a presentation made by the author at the
Fourth International Tax Dialogue Global Conference on “Tax and
Inequality”, which was held in December 2011 in New Delhi, India. The
author discusses the distribution effects of consumption taxes such as the
value added tax, by reference to selected literature and tested
methodologies.
New Rules Proposed for Debt-Equity Classification
Authors: Carman P.
Published: December 2023

In April 2016, the US Treasury proposed new Regulations under section 385 of the Internal Revenue Code that are intended to govern the classification of instruments between related entities as debt or equity in a variety of circumstances. The author discusses the two aspects of the proposed Regulations that represent a significant change in direction compared to traditional US authorities on debt-equity classification.
Recent Developments Regarding German International Tax Law
Authors: Kahlenberg C.
Published: December 2023

On 19 December 2014, the German Federal Council (Bundesrat) approved the Law To Adapt the German Tax Code to the Union Customs Code and To Change Further Fiscal Provisions (ZollkodexAnpG), which contains important amendments regarding international tax law. This article briefly describes the changes.
Resale Price and Cost-Plus Methods: The Expected Arm’s Length Space of Coefficients
Authors: Rombolotti A. , Schipani P.
Published: December 2023

In this article, the resale price and cost-plus methods are considered from the perspective of the manufacturer and the seller, and it will be shown that these two perspectives, in fact, lead to one single framework underlying the setting of transfer prices.
New Provisions Enacted To Counteract Artificial Structures Implemented To Avoid Real Estate Transfer Tax
Authors: Eckl P.
Published: December 2023

The author, in this note, provides an overview of the tax implications of new rules enacted to restrict artificial structures designed to avoid the imposition of real estate transfer tax.
Recent Luxembourg Tax Trends in the Private Equity Environment
Authors: Schaffner J. , Duro C.
Published: December 2023

In this article, the authors discuss recent trends in the “private equity” and alternative investment fund environment in Luxembourg in light of recent international tax law developments, including the OECD’s BEPS initiative, the EU Anti-Tax Avoidance Directives and recent Luxembourg case law.
Ruling on Adequacy of Audit Reports To Substantiate Transfer Pricing
Calculations
Authors: Peixoto Orsini E. , Peixoto Orsini Marcondes D.G.
Published: December 2023

The authors analyse a ruling by the tax authorities on transfer
pricing documentation, specifically with regard to whether audit reports may be
used as supporting documentation for transfer prices purposes.
South Africa’s New Real Estate Investment Trust Legislation
Authors: Mazansky E.
Published: December 2023

In this article, the author describes South Africa’s new Real Estate Investment Trust regime and its tax implications.
Loss Utilization
Authors: Wong Adeline , Tan Y.L.
Published: December 2023

This comparative survey article on Malaysia is based on a paper presented at the Baker & McKenzie 30th Annual Asia-Pacific Tax Conference held in Hong Kong from 13-14 November 2014. The 31st Annual Asia-Pacific Tax Conference is to be held in Singapore in November 2015.
VAT on Real Estate Transactions – A Comparative View of Saudi Arabia and the United Arab Emirates
Authors: Vanhee T. , Thomas G.
Published: December 2023

On 1 January 2018, Saudi Arabia and the United Arab Emirates introduced VAT. In this article, the authors discuss the VAT regime which has been implemented for the real estate sector in Saudi Arabia and the United Arab Emirates for businesses and individuals, focusing on similarities and differences between the implemented legislation.
The OECD Intangibles Project and the Concept of “Intangible Related Return”
Authors: Garbarino C. , D’Avossa M.
Published: December 2023

This article examines the OECD’s recent work regarding certain transfer pricing aspects of intangibles as reflected in BEPS Action Plan No. 8. In particular, the authors provide a description of the project, as well as the activities undertaken by Working Party No. 6 up to March 2014, describe the interim work performed by Working Party No. 6 in connection with the attribution of the “Intangible Related Return” to members of a multinational group and address comments on the “Intangible Related Return” concept received by Working Party No. 6 from business commentators.
Taxation of Management Fees
Authors: Singhal T.G. , Doshi A.D.
Published: December 2023

Multinational companies investing in India should be aware of the tax
implications of implementing management services agreements with their local
subsidiaries, etc. The authors provide an overview of the Indian tax issues
associated with such agreements and also review the impact of a number of cases
as well as tax treaties on the payment of management fees to
non-residents.
Intangible Transactions and Profit Allocation in the Semiconductor Industry
Authors: Lin Yishian
Published: December 2023

Intangible assets are the core value of the semiconductor industry. Complexity arises in the profit allocation among related parties because the arm’s length principle is hard to apply due to the unique nature of intangible transactions. This article explores the commercial activities of the semiconductor business and analyses possible solutions from some BAPA cases in local practice.
Taxation of Virtual Wealth
Authors: Bal A.
Published: December 2023

Recently, online games and communities have experienced significant growth. This article explores the income tax consequences of virtual activities and attempts, inter alia, by considering the examples of the United States and Germany, to answer the question of whether or not earnings from online games and communities are taxable.
United Arab Emirates: Corporate Tax Relief on International Investment
Authors: Hull H.R.
Published: December 2023

The UAE’s new Corporate Tax Law introduces a competitive tax regime, granting tax relief to a number of business activities. The UAE also has an extensive treaty network, providing relief on international transactions. This article focuses on corporate tax and treaty relief on inbound, throughbound and outbound investment.
Commission
Authors: Valério C.
Published: December 2023

This overview highlights the Commission’s (i) announcement of an SME relief package and confirmation of the BEFIT proposal; (ii) proposal for a solidarity contribution on surplus profits of the fossil sector; (iii) enactment of an amendment to the regulation to implement DAC7; (iv) signing of agreements to strengthen customs and tax cooperation with Ukraine; (v) referrals regarding the Netherlands to the ECJ over cross-border pension rules; (vi) closing of the infringement procedure against Germany regarding communication of measures implementing ATAD 2; (vii) closing of the infringement procedures against Bulgaria regarding ATAD 1 and ATAD 2; (viii) closing of the infringement procedure against Germany regarding disproportionate obligations concerning joint and several VAT liability of online marketplaces and sellers.
Investigations by European Commission into Transfer Pricing Underlying Certain Tax Rulings in the European Union
Authors: Sporken C.J.E.A. , Cattel Y.C.
Published: December 2023

The authors analyse the recent investigations commenced by the European Commission regarding the compatibility with State aid rules, of rulings granted by the tax authorities of several EU Member States.
Judicial System of Indonesia
Authors: Dewanda E.
Published: December 2023

In this article, the author describes the judicial system in Indonesia, including the constitutional framework for the court system, the various levels of court and the judicial procedures applicable in regard to tax litigation.
New Guidelines from Ministry of Finance on Tax Treatment of Decrease in Value of Loans to Affiliated Companies
Authors: Rasch S. , Maier J.
Published: December 2023

The Annual Tax Act 2008 brought new rules on the tax treatment of losses resulting from loans to affiliated companies. In response to two notable court rulings, the Ministry of Finance has now issued guidelines on the same subject, which primarily apply to fiscal years before the law itself was revised. This article discusses certain aspects of the new rules in greater detail, by means of several examples.
The Link between Transfer Pricing and EU Customs Valuation Law: Is There Any and How Could It Be Strengthened?
Authors: Tuominen J.
Published: December 2023

The primary purpose of this article is to investigate the link between transfer pricing rules and EU customs valuation rules under the currently applicable EU customs law. Moreover, it aims to present different potential solutions which could be considered in order to solidify the link between the two different topics.
Moving Towards a
New Transparent Tax World
Authors: Owens J.
Published: December 2023

In this short article, Jeffrey Owens, Director of the OECD’s Centre
for Tax Policy Administration, sets out his views on the progress achieved in,
and the future steps to be taken towards, the realization of tax transparency
in today’s world.
The Use of Tax Treaties and Treaty Shopping: Determining the Dividing
Line
Authors: Vitko V.
Published: December 2023

This article explores the dividing line between the appropriate use of
tax treaties and treaty shopping in international tax law. To this end, the
author considers international soft law, tax treaties, national law, and the
judicial doctrines that have been developed within national legal
systems.
Transfer Prices of Related-Party Transactions from Direct and Indirect
Tax Perspectives
Authors: Jain N. , Nguyen P.
Published: December 2023

This article discusses the regulatory and practical aspects of customs
and transfer pricing rules governing related-party transactions, including the
conflicts that arise as a result of the different rules.
Presumptive Taxation under Bangladesh VAT
Authors: Saleheen A.M.
Published: December 2023

The Bangladesh VAT system, which was introduced more than 20 years ago, is predominantly characterized by elements of presumptive taxation, in the form of turnover tax and notional valuation of transactions for VAT purposes. Those presumptive elements are remnants of the previously applicable excise duty. In this article, the author examines “presumptive taxation” in general and in the area of VAT in particular, and concludes that the presumptive elements in the Bangladesh VAT system are not only discriminatory but also have an adverse effect on the coherence of the modern tax.
An Overview of the Court System of South Africa with Emphasis on the Resolution of Tax Disputes
Authors: Hattingh J.
Published: December 2023

This article provides an overview of the South African court system insofar as tax cases are concerned. It was originally written as a supplement to IBFD’s Tax Treaty Case Law Database and is intended for those who consider South African tax cases, but who may not have a detailed understanding of the underlying court or tax administrative systems.
Everybody’s Got Something To Hide Except Me and My NFT’s Monkey – An Analysis of the European Commission’s DAC8 Proposal on Automatic Exchange of Cryptoasset Information
Authors: Michel B.
Published: December 2023

In this article, the author analyses and comments on the European Commission’s DAC8 proposal to implement the automatic exchange of information with regard to cryptoassets and related matters.
Dealing with Data in a Digital Economy
Authors: Jong S. de , Neuvel W. , Uceda Á.
Published: December 2023

The OECD initiated on 22 September 2017 a public consultation to further investigate key issues related to tax challenges raised by the digital economy and solutions to address these challenges. The submissions of different commentators to the public consultations have not been discussed thoroughly yet and the authors of this article examine these submissions here. The authors discuss the comments provided specifically on value creation, intangibles and the role of data in the digital economy from the point of view of different stakeholders: tax advisors, businesses and non-profit organizations.
The Court of Justice of the European Union – Recently Decided and Pending Cases
Authors: Annacondia F.
Published: December 2023

In this overview, the editor provides a list of judgments of the Court of Justice of the European Union (ECJ) and Opinions of the ECJ’s Advocates General delivered in VAT cases in the past 12 months. The overview also contains a list of the remaining cases pending before the ECJ on 31 August 2023, and a list of cases that have been removed from the ECJ’s register in the past year.
The Latest Generation of Tax Functions and the Role of Technology
Authors: Baumann-Larsen S. , Giannelli A.
Published: December 2023

This article explores how and why tax functions are needed to transform the role of people, processes and technology in driving forward change. At a time when tax administrations are being asked to do more with less, there is no better time to explore tax technology and its benefits.
Taxation of Fees for Technical Services and Royalties
Authors: Sanghvi S. , Shaktawat R.
Published: December 2023

This article discusses the controversial issue of the taxability of income as royalties or technical fees, both from the perspective of domestic law and tax treaties.
Council
Authors: Valério C.
Published: December 2023

This overview highlights the Council’s decision to authorize Latvia to continue applying restrictions on the right to deduct VAT in relation to passenger cars and the ECOFIN’s debate on the rules on global minimum taxation and other tax policy issues.
Commissionaire Structure as an Agency Permanent Establishment – Uncertain Profit Allocation
Authors: Leegaard T.
Published: December 2023

The author, in this note, critically examines the decision of the Borgarting Court of Appeals in the Dell Products case, wherein the Court held that the taxpayer, an Irish resident company, had an agency permanent establishment in Norway and consequently upheld the estimated assessment issued by the Norwegian tax authorities.
Interest Deductibility: Implementation of Action 4 of the OECD/G20 Base Erosion and Profit Shifting Project and the Future of Transfer Pricing of Intra-Group Finance
Authors: Burnett C.
Published: December 2023

This article considers multinational enterprises’ capacity to deduct interest expenses in light of the implementation of Action 4 of the OECD/G20 Base Erosion and Profit Shifting Project and the OECD’s current work on transfer pricing of financial transactions. It concludes that there has been a “step change” in moving away from a traditional “arm’s length” approach, and makes predictions about the tax planning responses to existing and upcoming interest limitation rules, and possible counter-responses.
The Border Adjustment: What Companies Need to Know
Authors: Reichert T. , Urken P.
Published: December 2023

In this article, the authors analyze how the adoption of a border adjustment by the United States would affect corporations. They demonstrate that this would cause both double taxation of import flows and non-taxation of export flows, contrary to the principles of international tax treaties and the recent OECD base erosion and profit-shifting initiative.
Non-Discrimination and Transparent Entities
Authors: Brabazon M.L.
Published: December 2023

This article surveys and assesses the application of the non-discrimination rules in tax treaties to situations involving fiscally transparent entities.
The General Anti-Avoidance Rule – An Indian and International
Perspective
Authors: Naskar A. , Gupta S. (Shubhangi)
Published: December 2023

This article is the winning entry to the 8th Nani A. Palkhivala
Research Paper Competition which was conducted by the All India Federation of
Tax Practitioners. The authors comprehensively discuss the proposed
introduction of a general anti-avoidance rules in India.
A Conundrum within the Conundrum: The Requalification of Loans as Equity under the OECD Guidance on Financial Transactions
Authors: Piran G. , Piva M.
Published: December 2023

In this article, the authors raise questions regarding the applicability of the recent OECD Guidance on Financial Transactions to the requalification of debt instruments as equity. The authors demonstrate that the current guidance is potentially inapplicable in many EU Member States and, perhaps, even in most OECD jurisdictions. Moreover, even where applied, such requalification might result in mismatches. Although Italy is taken as the example, the question addressed potentially involves a number of jurisdictions.
The EOI Standard – Past, Present and Future
Authors: Kaur D. , Saw R.
Published: December 2023

The release of the OECD’s progress report, during the April 2009 G-20 summit, categorizing harmful tax jurisdictions in accordance to their acceptance/implantation of the exchange of information (EOI) standard has seen an increase in the implementation of the EOI standards including signing of Tax Information Exchange Agreements. The authors discuss the EOI standard and the implementation issues with a focus on affected Asian jurisdictions.
The BEPS Report on Risk Allocation: Not So Functional
Authors: Hafkenscheid R.
Published: December 2023

In this article, the revised interpretation of the arm’s length principle on risk allocation as presented in the BEPS Final Report on Action 8-10 is discussed. By analysis of the main points, the author contests this interpretation and suggests an alternative approach.
Business-Friendly Real-Time Reporting in the European Union – Are We Moving in the Right Direction?
Authors: Jafari S.
Published: December 2023

Real-time reporting systems are becoming more and more common in the European Union. Although proven successful in terms of fighting fraud, the way of implementing real-time reporting can have an enormous impact on businesses. In the Column, the author explains that the tax authorities should make sure that such a system is business-friendly, has guaranteed confidentiality and is in line with the proportionality principle.
Review of the Structural Tax Reduction Policy Following the International Financial Crisis
Authors: Zhang Y. (Ying)
Published: December 2023

This article reviews the implementation of the structural tax reduction policy introduced by the Chinese government to overcome the effects of the international financial crisis. It also analyses key aspects and the impact of the policies on the Chinese economy, and finally comments on the tax reform methods that China may follow in the post-financial crisis era.
Transfer Pricing Audits of Manufacturing Companies in Indonesia: Quo Vadis?
Authors: Adoe Andreas
Published: December 2023

The author looks into approaches taken by the tax authorities during tax audits, and attempts to clarify transfer pricing issues in the manufacturing sector through an analysis of various Tax Court rulings.