bluuebunny/crossref_metadata_2025_split huggingface dataset:
Article: The Need for Global Minimum Tax: Assessing Pillar Two Reform
Authors: Tandon Suranjali 
Published: August 2022

In 2021, the Organisation for Economic Co-operation and Development (OECD) announced its proposal to introduce a global minimum tax. This proposal signals that Base Erosion and Profit Shifting (BEPS) program achieved limited success and tax avoidance continues as some countries tax at low or zero tax rates. This article reviews the existing international tax rules to demonstrate that their inefficient design is among the key factors that have compelled developed countries to support a global minimum rate.
In contrast to the previous approach where the OECD identified harmful tax practices, pillar two seeks to address tax competition. In doing so tax rates and incentives will be re-calibrated so as to ensure that a corporation pays 15% in each jurisdiction. For this the rules allow the residence countries to tax back the difference between the minimum and effective tax rate (ETR). The design of the rules indicates that developing countries will not gain tax revenues from this proposal. A more important point for developing countries to consider is that tax structures depend on regulation and structure of the economy. This article presents evidence to suggest that countries must weigh their overall economic objectives against the minimum tax.
Minimum tax, CFC, BEPS, incentives, capital controls
Country Note: Analysis of Turkey’s Controlled Foreign Company Regime
Authors: Öner Cihat 
Published: August 2022

This study analyses Turkey’s current position against the policies it has carried out, especially regarding the controlled foreign companies (CFC) taxation regime by the Organization for Economic Cooperation and Development (OECD). As a member of the OECD and G20 during both the preparation and processing of the OECD’s Base Erosion and Profit Shifting (BEPS) Project, Turkey has undertaken various roles. Nevertheless, it is observed that existing CFC rules and current developments regarding Turkey’s CFC regime fall below the minimum standards recommended in the BEPS Action 3 Final Report, and there is a certain ‘resistance’ that continues to regulate some matters. This study seeks to critically analyse and display Turkey’s position for coping with the BEPS Action Plan concerning CFC regulations.
Controlled Foreign Company (CFC), Base Erosion and Profit Shifting (BEPS), Turkish Corporate Income Taxation, International Taxation Principles, Tax Avoidance.
Country Note: A Critical Approach on the Greek Implementation of the DAC6
Authors: Pantazopoulos Petros , Kalampaliki Katerina 
Published: August 2022

The article provides a critical description of the main points of the Mandatory Disclosure Rules (MDR) in Greece following the implementation of the DAC6, specifically, what must be reported, who is responsible for it, the applicable penalties, and the deadlines for reporting. In parallel, certain issues of legal uncertainty arising from the ambiguous terms and concepts contained in the rules mentioned previously that need to be clarified are further analysed. In addition, the compatibility of the indicated Greek provisions mirroring, to a great extent, the content of the Directive with the fundamental freedoms and rights is examined.
Greece, DAC6, Reportable Cross-Border Arrangements, Intermediaries, Penalties
Critical Review Of The Atad Implementation: The Implementation of the ATAD in Italy
Authors: Arginelli Paolo 
Published: August 2022

The objective of the present contribution is to pinpoint the specificities of the Anti-Tax Avoidance Directive (ATAD) implementation rules in Italy, with a particular regard to the exercise of the different options provided by the Directive. That implementation has mainly taken the form of amendments to existing provisions (re Controlled foreign company (CFC), exit tax, interest deduction) with only a completely new set of rules (hybrid mismatch arrangements). For the general anti-abuse rule, the choice made has been to regard that rule as substantially overlapping with the Italian general anti-abuse rule (GAAR) and, therefore, not requiring any specific implementation. The result of this approach has been that taxpayers, tax authorities, and courts have been sledging comfortably into the new regimes without any significant discontinuity with the past, except for the hybrid mismatch regulation. In addition, the way in which Italy implemented the ATAD has proved rather conservative and appears largely compliant with the Directive. That notwithstanding, the most relevant departures from the ATAD are highlighted and discussed with a view to establish their compatibility with the EU legal order. Finally, the contribution examines the possible consequences stemming from the technique adopted to implement the Directive general anti-abuse rule and scrutinises the areas where tax litigations could more easily occur in the future.
ATAD, CFC, hybrid mismatch arrangements, interest limitation rule, exit tax, CJEU, GAAR, abuse of tax law, EU law, Italy
Case Law Trends: Just a Formality!: Substance over Form in EU VAT and the Right to Deduct Input VAT
Authors: Merkx Madeleine 
Published: August 2022

When it comes to the right to deduct input tax, substance in principle takes precedence over form. The CJEU has already ruled several times that the fundamental principle of the neutrality of VAT requires that if the substantive conditions for the right of deduction are met, this right can be exercised even when certain formal conditions are not met. In this article the author addresses recent case law of the CJEU on the distinction between formal and substantive conditions for the exercise of the right of deduction and the right to refund. The following topics are addressed: (1) Incorrect or incomplete invoices, (2) mistakes and refunds under Directive 2008/9/EC, (3) including an asset in the business assets and (4) VAT deduction in the event of late filing of intra-Community acquisitions. The recent CJEU cases will be analysed in the light of previous and pending case law providing the reader with an overview of the current situation.
formality, substantive condition, deduction, refund, invoice, VAT fraud, business assets, intracommunity acquisition, neutrality principle, principle of proportionality
Debate: Is There A Need for A Directive on Pillar Two?
Authors: Dourado Ana Paula 
Published: August 2022

A legally binding link for a simultaneous implementation of Pillars One and Two in the European Union (EU), as requested by one Member State, has not been accepted by the French Presidency. The author contends that a legal link between the Directive on Pillar Two and international developments is not incompatible with European sovereignty. This is so, for several reasons: (1) the competence for implementing the minimum tax foreseen by Pillar Two is not exclusive to the EU; (2) the principle of primacy would not impede the EU harmonization on Pillar Two being made dependent upon the evolution of the international agreements on the topic; (3) taking into account the developments of Pillar Two and the contents of the proposal for a Directive, it is dubious that a Directive is necessary for fulfilling the requirements of the internal market; (4) the interaction among all the instruments, exceptions, deferrals, and options foreseen in the model rules, in the original Proposal and the concessions may lead to multiple regimes. The latter can be achieved by the national transposition of the model rules.
Pillar Two Directive, principle of autonomy, principle of primacy, European sovereignty, EU legal order, international tax agreement, treaty override, EU external relations, EU competence, subsidiarity, proportionality
PENDAMPINGAN PENYUSUNAN STRUKTUR ORGANISASI DAN TUPOKSI PADA PENGELOLA WISATA KARANGPARA
Authors: Nursiva Halimah , Amal Muhammad 
Published: August 2022

Organisasi diperlukan sebagai wadah bagi sekelompok orang untuk bekerja sama secara rasional dan sistematis dan dibimbing atau dikendalikan dengan menggunakan sumber daya dalam organisasi untuk mencapai tujuan tertentu. Penyusunan struktur organisasi, tugas pokok dan fungsi Pengelola Pariwisata Kalammala adalah salah satu bentuk pengabdian kepada masyarakat yang dilakukan oleh mahasiswa Universitas Muhammadiyah Sukabumi. Sosialisasi ini bertujuan untuk membentuk struktur organisasi yang benar dan melaksanakan kegiatan yang tertib secara tertib dan teratur. Metode yang digunakan dalam kegiatan pengabdian ini terdiri dari lima bulan observasi, sosialisasi, dan pendampingan langsung. Hasil dari pengabdian masyarakat ini, peserta mampu memahami apa itu Tupoksi dan perannya dalam pengelolaan pariwisata di Karangpara, Desa Kebon Manggu Kabupaten Sukabumi.
Work Culture, Workload, and Job Satisfaction Intervening a Public Hospital Nurses’ Performance
Authors: Adhikara Arrozi , Rahmawati Wawah , Musaida Musaida 
Published: August 2022

Based on preliminary data taken by researchers, with 15 nurses at BA Tangerang Public Hospital, from the questionnaires distributed, in the aspect of job satisfaction nurses obtained results that all nurses filled in at least 1 indicator of dissatisfaction, namely 80% dissatisfied in terms of salary, 60% dissatisfied in terms of job promotion and 6% dissatisfied in terms of supervision. In terms of workload, 4 nurses did not report workload issues, and 11 nurses, or 73 percent, reported workload issues. Specifically, 81 percent of respondents reported that their working hours increased during each shift, 27 percent reported that the shifts were too long, 9 percent reported receiving duplicate tasks, 9 percent worked in confined spaces, and 9 percent worked in uncooled rooms. In the aspect of Work Culture, it was found that 87% had a good work culture and 13% had work culture problems. In the aspect of nurse performance, it was found that 20% of nurses had performance problems. To analyze the influence of work culture, workload, and job satisfaction on the performance of nurses at BA Tangerang Public Hospital. The research method uses an exploratory causality research design conducted on 130 respondents. The results of the study show that Work Culture, Workload, and Job Satisfaction have a significant influence on the performance of nurses at BA Tangerang Public Hospital.
Suberesolving codes
Authors: Jangjooye Shaldehi Somayyeh 
Published: August 2022

‎We show that any right continuing factor code with retract 0 into an irreducible shift of finite type is right eresolving‎, ‎and we give some sufficient conditions for a right eresolving almost everywhere code being right eresolving everywhere‎. ‎Suberesolving codes as a generalization of ersolving codes have been introduced and we determine some shift spaces which preserved by suberesolving codes‎. ‎Also‎, ‎we show that any bi-eresolving (resp‎. ‎bi-suberesolving) code on an irreducible shift of finite type (resp‎. ‎a synchronized system) is open (resp‎. ‎semi-open) and any right suberesolving code on a synchronized system is right continuing almost everywhere‎.
Perbandingan Metode Clustering Menggunakan Metode Single Linkage dan K - Means pada Pengelompokan Dokumen
Authors: Handoyo Rendy , Mangkudjaja Rumani , Nasution Surya Michrandi 
Published: August 2022

Penyebaran berita saat ini semakin tersebar??? luas semenjak perkembangan dunia internet yang semakin pesat. Perkembangan dunia internet membuat berita yang??? tersebar semakin beragam dan berjumlah??? sangat besar. Pembaca berita akan kesulitan untuk memperoleh berita yang diinginkan??? jika berita tersebut tidak terkelompok dengan baik. Dan jika harus dikelompokkan secara manual membutuhkan waktu yang sangat lama. Oleh sebab itu, Clustering menjadi solusi untuk mengatasi masalah tersebut. Clustering akan??? mengelompokkan dokumen berita berdasarkan??? tingkat kemiripan dari dokumen tersebut. Metode Single Linkage merupakan metode pengelompokan hierarchical clustering. Metode Single Linkage mengelompokkan dokumen didasarkan pada jarak terdekat antar dokumen. Komputasi Single Linkage merupakan komputasi yang mahal dan kompleks.??? Sedangkan metode K-means merupakan metode pengelompokan partitioned clustering. Metode K-means mengelompokkan dokumen didasarkan pada jarak terdekat dengan centroid-nya. K-Means merupakan??? metode pengelompokan yang sederhana dan dapat digunakan dengan mudah. Tetapi pada jenis data tertentu, K-means tidak dapat memberikan segementasi data dengan baik, sehingga kelompok yang terbentuk tidak murni data yang sama. Metode pengujian yang digunakan untuk mengukur kualitas cluster adalah Silhouette Coefficient dan Purity. Berdasarkan hasil pengujian yang dilakukan, dapat disimpulkan, bahwa metode Single Linkage memiliki performansi yang lebih baik dibandingkan dengan metode K-means. Nilai silhouette coefficient Single Linkage selalu lebih unggul dibandingkan dengan??? K-Means. Pertambahan jumlah dokumen membuat nilai silhouette coefficient single linkage semakin kecil sedangkan K-means terkadang menghasilkan nilai yang negatif. Untuk nilai purity, Single Linkage selalu bernilai 1 sedangkan K-Means tidak pernah bernilai 1. Hasil pertambahan jumlah cluster dan jumlah dokumen memberikan pengaruh terhadap nilai silhouette coefficient dan purity. Hal ini berarti single linkage selalu menghasilkan dokumen yang sama, sedangkan K-means masih bercampur dengan dokumen yang lain.
Effects of the chemical treatment on coal-fired bottom ash for the utilization in fiber-reinforced cement composites
Authors: Sonprasarn Passakorn , Chakartnarodo Parinya , Ineure Pitcharat , Prakaypan Wichit 
Published: August 2022

Around 3 million tons of municipal solid wastes called bottom ash (BA) are produced annually from the coal-fired power plants and it is still much underutilized in Thailand.Â Hence, the increasing usage of BA in industrial scale is necessary to limit the environmental impacts from landfilling of those by-product. Using of BA in fiber cement (FC) manufacturing seems to be a promising one.Â However, several negative effects regarding the extremely high water content from the fiber-cement forming process (Hatschek process) and the BA characteristic (the creation of bubble network) need to be eliminated.Â Both mentioned inferiors significantly reduce the cement hydration mechanism leading to remarkable reductions of set and hardened performances of fiber cement.Â Therefore, chemical treatment (CT) was introduced to boost up the hydration kinetic and characterized via the relevance of higher heat of hydration.Â Additionally, scanning electron microscope (SEM) was used to reveal the beneficial effects of treated BA through the microstructures. The results showed the chemically treated BA improve kinetic of hydration reaction was from the modification of BA surface.
The Effect of E-wallet and Sales Promotion on Purchasing Decisions
Authors: Subagiyo  , Gustia Adriani , Oktavian Syah Donny 
Published: August 2022

E-wallet is an electronic device, online service, or software program that allows one party to make electronic transactions with another party bartering digital currency units for goods and services. This can include purchasing items on-line with a computer or using a smartphone to purchase something at a store. Currently in Indonesia there are many kinds of E-Wallets including; DOKU, BBM money bank Permata, cash XL, Telkomsel T-Cash, CIMB Niaga Mobile Account, and so on. One example of an E-wallet is Gopay, inaugurated in April 2016 that can be used in all payment transactions in the Gojek application. This study aims to investigate the effects of E-wallet and Sales Promotion of Hop Hop Purchasing Decisions among high school students in the city of North Jakarta. This is explanatory research using probability sampling method and using a questionnaire on Google Form for collecting data. The sample used is 100 respondents from high school students who use the GOPAY electronic wallet to buy Hop Hop in the city of North Jakarta. This research uses quantitative analysis: validity, reliability, classic assumptions, correlation coefficient, determination coefficient, simple and multiple linear regression, hypothesis significance of t test and F test. The results of multiple linear regression analysis show that there was an effect of E-wallet and Sales Promotion on purchasing decisions. The variable correlation coefficient of the use of E-wallet and Sales Promotion on the GOPAY E-wallet has a strong relationship. The coefficient of determination of the variable using E-wallet on the Purchasing Decision variable is 59.4%, and the coefficient of determination of the Sales Promotion variable on the Purchasing Decision variable is 43.1%.
THE EFFECT OF COVID 19 ON MORINGA FARMERS UNDER THE VILLAGE SAVINGS AND LOANS ASSOCIATIONS IN NORTH-WESTERN GHANA
Authors: PIENAAH CORNELIUS K. A. , SEIDU ABDUL-AZIZ JERIKU , ISSAHAKU ABDUL-RAHAMAN 
Published: August 2022

This paper explored the current structure and dynamics of the village savings and loans associations operations by women and its socio-economic impact during the peak of Covid-19 on sanitation. The study adopted a mixed method design of qualitative and quantitative approach. Women groups who have operated, managed, and sustained for over the period of five (5) years were selected for the study. In all, 48 women between the ages of 18-60 years participated in the study. The study revealed that absenteeism, irregular share-buying, and nonpayment of loans behaviors are factors that were found to negatively affect the structure, dynamics, and sustainability of village savings and loans in 2021 due to Covid 19. The study also identified inadequate medical care, reduction in household incomes and nutrition gaps as key adverse effects of covid-19 on the women farmers. Some trades like Pito brewing, ‘‘Kosee’,’ Shea butter and food vending businesses are either collapsed or almost folding up due to covid-19. Communities relapsed into open defecation due to collapse of household toilets because of Covid-19 related poverty. The study concludes that rural women had challenges in contributing to the village savings and loans schemes or pay back their loans thereby threatening the solvency of the groups due to the COVID crisis. The study recommends that women farmers must be given training in financial literacy and bookkeeping. Both local and international organizations must collaborate to overcome the effects of post Covid-19 on poverty and sanitation.
Perspectiva dos trabalhadores da Estratégia de Saúde da Família na promoção da saúde ao idoso rural
Authors: Pinto Andressa Hoffmann , Lange Celmira , Santos Fernanda dos , Heidmann Ivonete Teresinha Schülter Buss , Lemões Marcos Aurélio Matos , Zillmer Juliana Graciela Vestena 
Published: August 2022

Objetivo: desvelar a perspectiva de promoção da saúde dos trabalhadores de Estratégia de Saúde da Família em relação aos idosos rurais. Método: qualitativo, tipo ação participante, com 25 profissionais da saúde, elencados por conveniência em um município da região sul do Brasil. O período de coleta ocorreu de agosto a dezembro de 2019. Análise dos dados por meio dos Círculos de Cultura de Paulo Freire. Foram realizados cinco círculos de cultura, com duração média de uma hora, todos gravados e fotografados. Resultados: a partir dos dados obtidos após a realização da dinâmica com os participantes, emergiram cinco temas: Adoção de hábitos saudáveis; A família como promotora de saúde; Prevenção de doenças; Atividade Coletiva; e O trabalhador como promotor de saúde. Conclusão: a promoção da saúde na perspectiva dos trabalhadores da estratégia tem suas bases no pilar de mudança comportamental de estilo e qualidade de vida individual.
Cellulose-Based Hydrogels: Patent Analysis
Authors: Fatimi Ahmed 
Published: August 2022

Background: Among biopolymers, cellulose and its derivatives are the most commonly used for hydrogel formulations. The innovation and improvement of cellulose-based hydrogels concerned the raw materials, synthesis and methods of preparation, formulations and fabrication processes, as well as applications.
Objectives: This study, in the form of patent analysis, presents the state by introducing what has been innovated and patented concerning cellulose-based hydrogels.
Methods: Three databases have been used in this study: the Patentscope, the Espacenet, and the Lens patent data set. A detailed analysis has been provided regarding publication dates, patent families, jurisdictions, inventors, applicants, owners, and patent classifications.
Results: A total of 8053 patent documents related to cellulose-based hydrogels have been published between 1965 and 2021. The United States leads the patent race in this sector, and the Massachusetts Institute of Technology is one of the top academic applicants.
Conclusion: Based on patent classifications, most patent documents are related to medicinal preparations characterized by special physical forms. More specifically, the classification concerns materials for prostheses or coating prostheses, including cellulose derivatives characterized by their function or physical properties, such as macromolecular gels, hydrogels, or hydrocolloids.
Male partners’ experiences of early pregnancy ultrasound scans in Soweto, South Africa: The Healthy Pregnancy, Healthy Baby randomised trial
Authors: Drysdale R E , Slemming W , Makusha T , Richter L M 
Published: August 2022

Background. Despite international evidence highlighting the benefits of male partners attending antenatal visits, including pregnancy ultrasound scans, it is unusual for South African (SA) men to attend such visits, and little is known about their experiences if they do.
Objectives. To explore the experiences and antenatal attachment among male partners who attend early pregnancy ultrasound examinations in Soweto, SA.
Methods. Pregnant women attending ultrasound examinations were invited to bring their partners with them. Both completed individual questionnaires, including the antenatal attachment scale. The results are based on a descriptive analysis of 102 mother-partner pairs.
Results. The mean age of partners was 35 years. Only 32% of men were living with their pregnant partner. Before the ultrasound scan, 64% of men reported feeling very anxious, while 54% also felt anxious after the procedure. The ultrasound examination had a positive effect on men and their thoughts regarding their developing baby, with 30% stating that they were ready or excited to be a father. Twenty-eight percent believed their relationship with the mother was stronger as a result of participating in antenatal care.
Conclusions. We found that prenatal ultrasound scans had a positive effect on male partners and their thoughts about the pregnancy, their forthcoming child and their relationship with and support for their partner. Health services in SA should accommodate partners/ fathers and encourage them to attend antenatal care, including pregnancy ultrasound scans. Interventions are needed to encourage more men to be involved – from conception – potentially addressing individual, familial, societal and structural barriers to involvement of the father in long-term maternal and child care.