bluuebunny/crossref_metadata_2025_split huggingface dataset:
Evaluation of Efficiency of the Two Commonly Used Pulp Test For Assessing Pulp Vitality And Sensitivity
Authors: Shafiq Nighat , Akram Sadia , Ahmed Junaid , Khan Muhammad Amer , Kayani Amna Ajmal , Nasir Umar , Alam Mohammad Shiraz , Khan Tahir Ali 
Published: February 2022

Hard tissue boundaries are limited to pulp tissue and cannot be inspected directly for health evaluation so most of its evaluations are based on sensitivity testing. It is believed that electric pulp test (EPT) has some limitations in determining the vitality of the pulp. Therefore the objective in the current study was to see how well the electric pulp test and the cold test agreed in evaluating pulp vitality and sensitivity. Study Design, Place and Duration: This Observational/Retrospective study was carried from 1st March, 2021 to 31st December, 2021 at the Department of Dental Materials, Sardar Begum Dental College, Gandhara University, Peshawar. Methods: Total one hundred and eighteen patients of both genders had pulpits because of dental caries were included in this study. A range of ages were represented from 18 to 50 years old. As part of the informed written consent process, each patient was asked to provide demographic information such as their age, gender, and the type of teeth they had. Patients were equally categorized into two groups, Group I received electric pulp test and group II received cold test. Teeth were classified as vital if there was tingling or pain, and non-vital if there was no tingling or discomfort. Outcomes among both groups were calculated in terms of absence or presence of tingling sensation. Visual analog scale was used to determine pain score among enrolled cases. We used SPSS 23.0 version to analyze the data. Results: Among 118 patients, 67 (56.8%) were males and majority of the cases 60 (50.8%) were aged between 26-35 years, followed by age group 18-25 in 35 (29.7%) cases and 23 (19.5%) cases were between age group 36-45 years. Mandibular incisors were the most common tooth found in 47 (39.8%) cases followed by maxillary incisors 32 (27.1%) cases. By using visual analogue scale (VAS), we found that most of the patients had severe pain 90 (76.3%). The rate of vital teeth in group I was 45 (76.3%) and in group II vital teeth found in 41 (69.5%) while remaining tooth were necrotic among both groups 14 (23.7%) and 18 (30.5%). By Kappa’s statistics we found that overall frequency of vital teeth among all cases was 86 (72.9%). Conclusion: In assessing pulp viability and sensitivity, EPT and cold testing showed great concordance, according to this study. Electric pulp testers and cold testing currently satisfy the majority of the criteria for an ideal testing procedure and are still widely utilized diagnostic tools. When EPT and Endo frost are used together, a more precise assessment of pulp vitality can be made.
SELF-DETERMINATION THEORY SEBAGAI STIMULASI PERILAKU PENGOBATAN DAN PELATIHAN SENAM DIABETES PADA LANSIA DI KECAMATAN MANGANITU
Authors: Tatangindatu Maryati Agustina , Umboh Melanthon 
Published: February 2022

Prevalensi penyakit diabetes melitus menduduki peringkat ke tujuh di Indonesia.Di Kabupaten Kepulauan Sangihe angka kejadian kasus diabetes melitus tipe 2 terutama di kampung Barangka yang merupakan wilayah Kerja Puskesmas Manganitu cukup tinggi. Dari 18 kasus diabetes melitus tipe 2 terdapat 2 kasus kaki diamputasi dan 1 kasus mengalami kebutaan. Hal ini menunjukan pentingnya perhatian dan penanganan terkait penyakit diabetes melitus tipe 2 yang membutuhkan pegelolaan penyakit melalui managemen diri yang cukup kompleks, tidak hanya berdampak pada kondisi kesehatan secara fisik namun juga kondisi psikologis. Salah satu faktor psikologis yang penting menjadi perhatian adalah motivasi berdasarkan self-determination Theory (SDT). Tujuan pengabdian kepada masyarakat untuk memberikan stimulasi perilaku pengobatan dan pelatihan senam diabetes pada lansia di Kecamatan Manganitu. Metode pelaksanaan yaitu melakukan pemeriksaan tekanan darah, gula darah, penyuluhan tentang diabetes melitus, dan pelatihan senam diabetes. Waktu pelaksanaan kegiatan pada bulan September 2020 bertempat di Balai Pertemuan Desa Kampung Barangka. Peserta yang hadir dalam kegiatan pengabdian kepada masyarakat berjumlah 30 orang yang mengikuti pemeriksaan tekanan darah, gula darah, penyuluhan tentang diabetes melitus, dan pelatihan senam diabetes. Hasil pemeriksaan didapatkan beberapa lansia mengalami hipertensi dan diabetes melitus.

The prevalence of diabetes mellitus is ranked seventh in Indonesia. In Sangihe Island District, the incidence of type 2 diabetes mellitus, especially in Barangka village, which is the working area of ​​the Manganitu Health Center, is quite high. From the 18 cases of type 2 diabetes mellitus, those were 2 cases of leg amputation and 1 case of blindness. This shows the importance of attention and treatment related to type 2 of diabetes mellitus which requires management of the disease through complex self-management, not only affecting physical health conditions but also psychological conditions.One of the important psychological factors to be considered is motivation based on self-determination theory (SDT). The purpose of community service is to stimulate treatment behavior and diabetes exercise training for the elderly in Manganitu District. The method of implementation was check the blood pressure, blood sugar, counseling about diabetes mellitus, and diabetes exercise training. The time for the implementation in September 2020 and take place at the Village Meeting Hall of the Village of Barangka. The participants who attended were 30 people who attended and check blood pressure, blood sugar tests, counseling about diabetes mellitus, and diabetes gymnastics training. The results showed some elderly people had hypertension and diabetes mellitus.
PENGOLAHAN SAMPAH ORGANIK RUMAH TANGGA MENJADI PUPUK ORGANIK CAIR
Authors: Pramardika Dhitodwi , Melanthon Junaedi  Umboh  , Gracia Christy Tooy  
Published: February 2022

Permasalahan sampah merupakan masalah global, termasuk yang dialami Kampung Petta Selatan saat ini. Pengolahan sampah yang dilakukan yaitu dengan cara dibakar, ditimbun dan ada yang dibuang ke dalam saluran pembuangan air limbah (SPAL). Sampah-sampah tersebut berdasarkan sifatnya yaitu 60% merupakan sampah organik. Oleh karena itu, masyarakat perlu diberikan pelatihan dalam pengolahan sampah organik rumah tangga menjadi Pupuk Organik Cair (POC). Artikel ini bertujuan untuk meningkatkan pengetahuan dan kemandirian masyarakat dalam pengolahan sampah. Tahapan yang dilakukan berupa penyuluhan mengenai sifat sampah dan pupuk organik, pelatihan pembuatan Mikro Organisme Lokal (MOL), pelatihan pembuatan tong komposter semi anaerob yang dilaksanakan hari Sabtu, 12 September 2020 di kantor Kapitalaung Kampung Petta Selatan yang dihadiri 9 orang dengan penerapan protokol pencegahan Covid-19. Dari hasil evaluasi pelatihan nilai rata-rata pre post adalah 42,22, dan ketika dilakukan pelatihan maka nilai rata-rata post test adalah 82,22. dari hasil tersebut diketahui bahwa terjadi peningkatan pengetahuan rata-rata 40 sebelum pelatihan dan sesudah pelatihan.

The household waste problem is a global problem, including those was experienced in Petta Selatan village. Waste processing was carried out by burning, dumping and discharge it into the waste water disposal channel (SPAL). Based on those characteristics, 60% of those waste was organic waste. Therefore, the community needs to trained in processing household organic waste into Liquid Organic Fertilizer (POC). Those article aim increasing knowledge and community independence in waste processing. A gradual process of counseling on the nature of waste and organic fertilizers, train on making Local Micro Organisms (MOL), train on making semi anaerobic composter vats was held in Saturday, September 12, 2020, at the Kapitalaung office of Petta Selatan village which was attended by 9 (nine) people with the implementation of the Covid-19 prevention protocol. The results of the training evaluation the pre-post average score was 42.22, and when the training was carried out, the post-test average score was 82.22. From this result it is known there is an increasing in knowledge about 40 before training and after training.
PENERAPAN ADAPTASI PSIKOSOSIAL PADA MASYARAKAT PASCA TRAUMA BENCANA ALAM DI KAMPUNG LEBO KECAMATAN MANGANITU
Authors: Surudani Conny Juliana , Makahaghi Yenny Budiman , Pangandaheng Nansy Delia 
Published: February 2022

Kejadian gangguan psikososial biasanya mulai muncul segera setelah bencana terjadi (60%). Angka kejadian akan turun seiring dengan berjalannya waktu. Akan tetapi, hal ini tidak menutup kemungkinan gangguan psikososial akan muncul pada rentang waktu lama setelah terjadinnya bencana. Selain itu, resiko terjadinya gangguan psikososial juga semakin menurun jika tiak terjadi cedera fisik yang berarti dan kehilangan orang terdekat. Tujuan PKMS ini yaitu mengurangi dampak psikologi pasca trauma bencana alam akibat kehilangan berduka terhadap keluarga dan harta benda. Kegiatan penyuluhan dilakukan dari rumah ke rumah hal ini dilakukan karena pandemi Covid-19, dimana tim pengabdian mengunjungi rumah-rumah keluarga yang terdampak dengan bencana alam kampung Lebo Kecamatan Manganitu, kemudian melakukan Intervensi Adaptasi Psikologis pada keluarga, kecemasan yang dirasakan oleh keluarga yang mengalami trauma pasca bencana dapat berkurang dengan selalu melakukan tindakan yang sudah diberikan jika rasa takut/cemas datang kembali. Setelah diberikan penyuluhan dan pemberian intervensi adapatsi psikologis pada masyarakat terdampak bencana alam dikampung Lebo Kecamatan Manganitu dapat mengurangi resiko terjadinya depresi akibat kecemasan yang berlebihan karena kehilangan harta benda dan anggota keluarga lainnya.

The incidence of psychosocial disorders usually start immediately after the disaster (60%). The incidence rate will decrease over time. However, this does not rule out the possibility that psychosocial disorders will appear for a long time after the disaster. In addition, the risk of developing psychosocial disorders also decreases if there is no significant physical injury and loss of loved ones. The goal of PKMS was reduce the psychological impact of post-traumatic natural disasters due to loss of grief to family and property. Outreach activities were carried out by door to door, those was done because of the Covid-19 pandemic, where the community service team visite the home of families who impact by natural disasters in Lebo village, Manganitu District, then carried out Psychological Adaptation Interventions on families, anxiety felt by traumatized families Post-disaster can be reduced by always take the action that have been given if fear / anxiety returns. After being given counseling and psychological adaptation interventions to peole in Lebo affected by natural disaster, Manganitu District, it can reduce the risk of depression due to excessive anxiety due to loss of property and other family members.
Current Developments of Contributions to US Pension Plans under German Tax Law
Authors: Lühn Tim 
Published: February 2022

This article analyses the current tax developments of contributions to US pension plans (e.g., 401(k) – plan) under German tax law from a domestic tax law and from a double tax treaty perspective, whereas the main emphasis is put on the employer contributions. There have been two fundamental incidents that have had major impact for the current German domestic tax law and double tax treaty treatment of employer contributions to US pension plans: firstly, in a decision dating 5 July 2007, the German Federal Court of Finance has ruled for the first time that employer contributions to US pension plans should be qualified as employment income under German domestic tax law. Secondly on 28 December 2007, a new Article 18A Double Tax Treaty Germany/ USA (in the following: ‘DTT Germany/USA’) concerning the treatment of pension plans for tax treaty purposes was introduced (partly) retroactively as of 1 January 2007 within the adoption of a new protocol amending the DTT Germany/USA.
This article analyses and evaluates the impacts and changes under German domestic tax law according to the aforementioned incidents, starting with a short overview of the US domestic taxation of US pension plans which is important for understanding the issues regarding the German domestic tax law and double tax treaty treatment.
Double Taxation Treaties: The Autonomous Interpretation Method in German and English Law; as Demonstrated by the Case of the Silent Partnership
Authors: Knebel Andreas 
Published: February 2022

The authors explore the current state of the case law in Germany and England regarding the silent partnership in international taxation. The main concern is the interpretation and application of the double taxation treaty as a bilateral convention: how will German courts and fiscal authorities react to the Memec case series in view of existing case law on double taxation convention (DTCs) with other countries? Will they respect the English view on the qualification proceeds from a German ‘atypical’ silent partnership under the DTC or will they continue to apply an outdated and arguably ill-founded reasoning?
The discussion wants to contribute to the evolution of a truly and much needed international legal doctrine within an ever-expanding European Union.
Shareholders’ Subordination Agreements in Light of German Commercial Law, Insolvency Law and Tax Law
Authors: Graf Kerssenbrock Otto-Ferdinand 
Published: February 2022

Subordination declarations play a major role for crisis-threatened enterprises in the prevention of duty to apply for insolvency procedures. The German legal environment for Shareholder’s Subordination Agreements has recently changed drastically, since Germany has significantly changed and adapted the concept of Corporate Equity Protection – which was formally laid down in section 30 and the following of the Limited Liability Company Act (GmbHG) – for all kinds of enterprises and moved it into the legal framework of Insolvency Law (InsO).
This article covers the legal situation before and after the reform of the concept of Corporate Equity Protection and gives a coherent, practical presentation of the commercial, insolvency, and tax law aspects of this still important financing instrument.
Lesson Learned by the New Italian Law on Limited Tax Shield on Debt: Much Ado about Nothing
Authors: Tagliavini Giulio , Lanzavecchia Alberto 
Published: February 2022

Corporate finance management rules are written under the assumption that financing costs are fully deductible from taxable income. If this assumption is relaxed, such rules need to be revised. We review traditional management tools and propose a new set of guidelines for financial management. The tax reform introduced in Italy, which creates a partial tax deduction for financing costs, offers a case study to measure the impact of such rules on a firm's profitability. The general wisdom among academics and practitioners was of a further pressure on economic performance of firms due to a higher tax burden. Is this concern effective? Do Italian firms pay more taxes in the following years? We checked the effect of the new rules on a sample of 2,025 large Italian firms. We did not find a deep impact. Effects are limited to one sector, characterized by operating profitability on sample mean and financial leverage below sample mean. Policy makers are now advised to fine-tune this regulation or to abandon it.
Brazil: CFC Rules Update
Authors: Rosenblatt Paulo 
Published: February 2022

In August 2011, the Supreme Court of Brazil continued the judgment on the constitutionality of the Brazilian Controlled Foreign Corporation (CFC) legislation. The final decision is dependent on a sole justice's opinion, but some conclusions can be drawn from the case so far. In April 2011, the Superior Court of Justice of Brazil also decided one leading case on the CFC rules, which restricted its scope. The case law under review is a signpost that the Brazilian CFC legislation needs to be reformed in order to match reasonable and internationally accepted parameters. In this article, the author provides an overview of the Brazilian CFC regime. It was originally written as a paper presented at the 2nd London Alumni International Tax Conference, Institute of Advanced Legal Studies, University of London.
The European Arbitration Convention on Transfer Pricing: Legal Fossil or
Authors: de Carolis Daniele 
Published: February 2022

This article provides an analysis of the European Arbitration Convention on Transfer Pricing focused on the ever-increasing role soft law is playing in the drafting and diffusion of international and European rules. The main argument of this survey is that, rather than an instrument at the border of Community law, the Arbitration Convention lies at the centre of a complex and innovative system of new European governance, in which a hard law instrument (the Convention) is supported by a soft law instrument (the Code of Conduct) and by monitoring and mutual learning mechanisms carried out by the Joint Transfer Pricing Forum (JTPF). These features help better understand the Convention's increasing application in practice as well as the remarkable impact of the Code of Conduct at national level, e.g., in Italian law. Analyses of the European Arbitration Convention are mostly focused on a traditional legal approach and consequently tend to consider this instrument either as a mere international treaty outside the European legal framework or as a no man's land between Community law and ordinary international law or even as a sort of 'legal fossil', i.e., a legally obsolete instrument at the border of European law. These approaches have generally emphasized the Convention's drawbacks, especially with respect to the potential advantages related to its adoption in the form of a European directive according to the Commission's original design. In other words, according to these approaches the Convention is but a sort of second-best, a watered-down compromise which the Commission had to accept in the wake of the Member States' reluctance to waive their fiscal sovereignty in the transfer pricing field. In contrast to these approaches, this work puts forward an analysis of the Convention which stems from soft law's ever-increasing role in international law and in the European integration process. As will be shown in the remainder of this essay, this alternative vision allows to account for the remarkable impact the Convention is starting to have in practice, both at international and national level.
What Is Wrong with (The Rules of) the Game?
Authors: Snel Freek PJ 
Published: February 2022

Public outrage is growing about 'immoral tax evasion by multinationals'. This calls for a thorough and polemical response from the tax advisory profession. This article investigates the following questions: 'can we define the boundaries to "ethical tax planning"; "is the Netherlands a tax haven"; "what are the fundamental reasons multinationals can pay little tax without acting illegally"; and "how can we really improve the rules of the game"?' The growing criticism with respect to tax evasion by multinational companies is understandable. But, if one takes a closer look, this criticism is largely unjustified. The author concludes that we cannot ask more from multinationals than paying tax in accordance with the law and in a balanced relation to the value of the benefits they derive from government services. The rules of the game can be improved with respect to the relation to the benefits from government services. In the author's view, this requires replacing the arm's-length principle for the allocation of profits to countries by a more robust approach. It requires the recognition by governments that there is a clear limit to what they can ask from multinational companies and what not.
Legal Aspects of Statistical Sampling in Tax Compliance Auditing
Authors: Van Brederode Robert F. 
Published: February 2022

Sampling is in essence an estimation of tax compliance. Taxpayers may be either in a position of underpayment, overpayment or zero payment. There is a direct correlation between the level of accuracy of the sample and the accuracy level of the underlying documents. After providing a short explanation of a statistical sample, this article examines whether sampling should be allowed and, if so, under what conditions, as sampling is an estimation method and does not provide exact information on the tax position of the taxpayer. Discussed are the role of the allocation of the burden of proof, the type of tax, the principle of fair play, the influence of the confidence interval, and the risk of inaccuracy. Separate discussions are offered on the use of sampling for the determination of interest and penalty payments, and on the issue of extrapolation of sampling results. The author supports the use of sampling agreements between taxpayers and tax authorities, because it clarifies the terms under which the sampling will take place and will likely increase understanding of the process by the taxpayer and, thus, his acceptance of the outcome.
Aggressive Tax Planning in EU Law and in the Light of BEPS: The EC Recommendation on Aggressive Tax Planning and BEPS Actions 2 and 6
Authors: Dourado Ana Paula 
Published: February 2022

The purpose of this article is to critically assess the meaning of aggressive tax planning and its scope in the current international move to fight against base erosion and profit shifting (BEPS). In the context of the BEPS initiative, aggressive tax planning has been broadly used in several Organization for Economic Cooperation and Development (OECD) and EU soft law instruments. However, it is not clear what new features aggressive tax planning does bring to the settled legal concepts of tax avoidance and tax evasion, and whether it is a legal or merely a tax policy concept. In order to find the meaning of aggressive tax planning in the BEPS context, some of the recommendations put forward in BEPS actions 2 and 6 and in the EC Recommendation on Aggressive Tax planning are analysed and compared in this article. The article also aims to illustrate some of the reciprocal influences and interaction between EU law and OECD recommendations and tax treaties. For example, the EC Recommendation on ATP, proposing the introduction of a General Anti-Abuse Rules (GAAR) in the Member States' legislation, and the BEPS Action 6 proposal to introduce a GAAR (a Principal Purposes Test Rule or PPT Rule) in tax treaties illustrate the same spirit and a holistic approach. Moreover, a PPT Rule in tax treaties concluded by EU Member States will have to be compatible with the EU fundamental freedoms and the principle of abuse in EU law. The GAAR amending the EU Parent-Subsidiary Directive and approved by the Economic and Financial Affairs Council (ECOFIN) on 9 December 2014 illustrates how EU Member States could introduce a GAAR in their treaties compatible with EU law. These reciprocal influences among domestic, international and EU law and practices lead to an acquis communautaire and to international standards which may be justified as products of global identity and related to a global sense of fairness and unfairness and ultimately of a global tax morale calling for global solutions and global tax standards.