bluuebunny/crossref_metadata_2025_split huggingface dataset:
The Benefits of Differentiated Transparency. Proposal for Graduated Confidentiality Regimes within International Tax Disputes
Authors: Castagna Stefano 
Published: February 2022

To date, legislators and policymakers have not yet used any explicit policy criterion to balance transparency matters when dealing with EU and OECD tax dispute resolution reforms. This article wants to fill this void by providing a unique tool for implementing changes in international tax dispute resolution mechanisms, balancing different expectations and needs of stakeholders. Providing an example of its application, it proposes the use of differentiated levels of transparency according to stakeholders’ interests to ensure efficiency and fairness of outcome. The article employs principles of data protection regulations as a means to propose changes, drawing inspiration from comparable dispute resolution regimes that deal with taxation matters (Investor-State Dispute Settlement, International Commercial Arbitration and World Trade Organization dispute resolution mechanism). It concludes by providing proposals to render more efficient the current EU and OECD tax dispute resolution mechanisms.
Transparency, dispute resolution, international arbitration, legitimate interests, reform, WTO, ICSID, commercial arbitration, EU tax, OECD.
Country Note: Implementation of BEPS Recommendations in Indonesia’s New APA and Transfer Pricing Rules
Authors: Dewi Astuti Melani 
Published: February 2022

Indonesia has recently updated its Advance Pricing Agreement and transfer pricing regulations in order to capture the development in the business and transfer pricing. It is also aimed to align with the Base Erosion and Profit Shifting (BEPS) recommendations. The new regulation has made substantial changes to the old advance pricing agreements (APAs) and transfer pricing regulations. With regards to transfer pricing, the new regulation has made some changes pursuant to the related parties’ definition, transfer pricing methods, comparability analysis procedures, special transactions, and intangibles. The transfer pricing guidance also provides guidance on the financial transactions and introduces the value creation concept.
The new definition of related party is broader by providing more example on the ownership based on control. The regulation also allows the use of other transfer pricing methods other than the five OECD methods. Moreover, the intangible provisions have been modified to reflect the changes in the OECD Transfer Pricing Guideline 2017, to cover development, enhancement, maintenance, protection, and exploitation (DEMPE) activities and the economic owner. The guidance on financial transaction could also be useful for taxpayers and tax administration.
Meanwhile, in terms of APA, the new regulation has provided a longer period of APA implementation, included a roll-back provision and modified the requirements regarding the submission of APA. Based on the new APA regulation, to submit an APA, a taxpayer cannot propose a lower profit than profit reported in the tax return.
In general, the new regulation is in line with the BEPS 8-10 recommendations, albeit some differences are found, those are considered minor. The new regulations are expected to provide more certainty and simplicity for the taxpayers.
Transfer pricing, APAs, Indonesia, advance pricing agreement, transfer pricing guidance, roll-back, related party, affiliated, transfer pricing methods, comparables
Policy Note: Taxing the Digital Economy: A Case Study on the Unified Approach
Authors: Greil Stefan , Eisgruber Thomas 
Published: February 2022

In October 2020, the OECD Secretariat published the ‘Report on Pillar One Blueprint’ approved by the Inclusive Framework on BEPS as a result of the work on the tax challenges arising from digitization. This contribution attempts to explain the application of the Unified Approach, especially Amount A using a case study. The case study reveals a considerable complexity of the proposed new system. Therefore a simplification potential is to be pointed out at the same time, in order to make Amount A practicable. The possibility is not precluded that certain aspects could be interpreted or regarded differently. Therefore, this case study intends to contribute to the development of a common understanding, too. It is important that all participants in a multilateral system have a common understanding. Otherwise, this results in double taxation and enormous administrative challenges for taxpayers and tax administrations. There is still the opportunity to make changes. This should be used now, since multilateral systems are difficult to change once they have been implemented. Finally, the application of the proposed draft of the new Article 12B of the UN Tax Treaty Model is also considered.
Digital economy, digitalization, arm’s length principle, pillar one blueprint, unified approach, reallocation of taxing rights, Amount A, tax certainty, Article 12B UN model.
Policy Note: Taxation of Workers in the Gig Economy: A European Perspective
Authors: Poras Geoffrey , Maurer Ludmilla , Murdoch Gillian , Smale Anne-Carien , Mirabella Andrea , D’Anthonay Eleonore , Rogel Davinia 
Published: February 2022

Progressive digitalization accelerated by the outbreak of the coronavirus disease 2019 (COVID-19) pandemic is leading to the emergence of new employment models across Europe and beyond, including the so-called gig economy, sharing economy or crowd work. When applying existing laws to modern employment forms, it is often unclear as to how they fit into the existing legal framework and which regulations are applicable. Countries are trying to keep pace with how workers in the gig economy should be treated. Some countries are seeking to introduce new rules to deal with these new practices, whilst others are relying on court or regulators’ decisions to increase certainty. Not surprisingly, there is no standard approach, although there are some common themes. This article aims to raise awareness of existing risks from an employment, social security and tax law perspective relating to gig workers and online platform providers in the six largest economies in Europe - the UK, Germany, the Netherlands, Italy, France and Spain. It also provides some guidance about how to manage such risks and ensure compliance. The analysis concludes with a short comparison of the current status of legal developments in the six countries and a request to policy makers to take action.
Gig economy, sharing economy, crowd work, online platform, gig worker, employment status, personal service company (PSC), misclassification, deemed employment relationship, independent contractor.
Distributive Profit Allocation Rules: A New Approach for an Old Problem
Authors: Martínez Pablo Mahu 
Published: February 2022

The Organisation for Economic Co-operation and Development (OECD) has recently announced its renewed commitment to the Unified Approach (UA) contained in Pillar I for the taxation of MNEs’ business profits. The historical development of this approach demonstrates how the OECD has not taken inter-nation equity issues seriously in its drafting and, thus, the approach produces outcome issues that do not address the underlying problems that actuated the BEPS Program in the first place. The author believes that the OECD has not been asking the correct questions and, therefore, the problem of how to reform international tax law must be restated. In a world of increasing political instability, stagnating inequality rates, and a continuous struggle to improve the quality of life of its world citizens, tax policy requires addressing these fundamental issues. Internation equity demands an agreement on fundamental justice principles underlying international tax law, principles that would best be reflected in new nexus and profit allocation rules based on factors of distributive justice. Only in that way can the OECD reach a stable, lasting, and consensual solution to address the issues in our current international tax architecture that will benefit all parties involved.
International tax law, inter-nation equity, distributive justice, profit allocation rules, nexus rules, Unified Approach.
Policy Note: Value Added Tax as a Legal Transplant
Authors: Kristoffersson Eleonor 
Published: February 2022

In this article, Value Added Tax (VAT) is examined as a legal transplant. The legal transplants theory relies on the assumption that legal transplants are the primary driver behind legal change. In order to establish whether this is the case for VAT, the distribution of VAT across the world is examined. This spread, however, should be evaluated against the different legal VAT families that may be identified around the world in order to determine if the identity of the transplanted system remains. That said, VAT families vary over time, and there is no specified definition of different VAT families. The establishment of the relevance of studying VAT as a legal transplant may feasibly lead to a discussion on whether a legal transplant approach is appropriate for comparative research in VAT since such an approach entails a risk for too much emphasis on similarities. The fact that statutes appear to be similar does not necessarily mean that the law is the same due to various factors such as legal culture. However, with an awareness of the inadequacies of the legal transplants approach as a method for comparative studies, the approach may provide valuable insight into explaining the similarities and differences in VAT.
Legal transplants, value added tax, VAT, tax history, comparative methodology, comparative tax law
Blockchain and Smart Contracts: A Look at the Future of Transfer Pricing Control
Authors: Cipollini Claudio 
Published: February 2022

This article aims to outline the path towards the future of transfer pricing (TP) control by exploring the new possibilities of blockchain and smart contracts and their potential impact on the international and European policy debate. After the introduction of some preliminary concepts, the first outcome is the identification of a uniform methodology for coding advance pricing agreements (APAs) into smart contracts in which conventional elements properly match with computer language components. Despite the challenges of the coding process and the issue of legal prose, the research also approaches the dynamics and the different stages of a new smart system for TP control. Furthermore, the analysis covers the policy perspective and explores how the new technology could improve the outcomes of the recent OECD and European Commission initiatives in the area of TP. Ultimately, the study suggests the adoption of uniform rules for coding APAs into smart contracts and the establishment of an international consortium blockchain. However, other factors will also be crucial for the implementation of the new system including the collection of sufficient supply chain data and the adoption of an interdisciplinary approach that is open to software engineering and data science.
Transfer pricing, advance pricing agreements, blockchain, smart contracts, real-time monitoring, artificial intelligence, data analytics, digital economy, OECD Transfer Pricing Guidelines, convention on mutual administrative assistance in tax matters.
Mandatory Binding Arbitration: Avoiding Stalemates Over the Tax Chessboard
Authors: Nikolaou Polyvios 
Published: February 2022

The resolution of tax treaty disputes under the Mutual Agreement Procedure (MAP) mechanism is inherently problematic. This article examines how the introduction of final-offer arbitration (FOA) can improve dispute resolution using a game-theoretical approach. It will be argued that arbitration introduces an element of finality that was demonstrably absent in the MAP while also contributing to the speedier resolution of disputes which is beneficial to all international stakeholders. After demonstrating the advantages of arbitration, the paper considers how its institutional design can be optimized in the tax context. It makes proposals regarding the publication of arbitral decisions to address concerns of countries that are still skeptical about whether or not to endorse it.
Tax dispute resolution, game theory, mandatory binding arbitration, double tax treaties, mutual agreement procedure, baseball arbitration, international taxation.
ام المؤمنين ام سلمة ودورها في رواية الحديث النبوي
Authors: مجيد نهاد نعمه 
Published: February 2022

كان للمرأة المسلمة اثر كبير في التاريخ على مر العصور وقد ذكرت كتب التاريخ والتراجم ، والطبقات ، والسنن والصحاح جوانب عدة من حياتها الدينية والسياسية والاجتماعية والعلمية لتجسد سيرتها مثالا في الثبات على الايمان وقوة العقيدة يجعلها مثالا يحتذى به على مر العصور
Case Fatality Rate and Review of Literature on Gnaecological Cancers Mortality at a Specialiazed Oncology Unit in Port Harcourt
Authors: Bassey G. , Nyengidiki T. K. , Kpurunee B. S. 
Published: February 2022

Background: Gynecological cancer is a major public health problem and an important cause of morbidity and mortality in women worldwide. There are only few researches on the overall mortality attributed to gynecological cancers in Nigeria.
Objectives: To determine the case fatality rate, prevalence and reason for mortality amongst gynecological oncology patients at the oncology unit of the University of Port Harcourt Teaching Hospital (UPTH).
Study Design: This was a retrospective study of mortality from gynecological cancers in UPTH between 1st January, 2014 and 31st December, 2018. Case files of patients with mortality from genital tract malignancies were reviewed and relevant information extracted
Results: A total of 2070 gynecological admissions were recorded out of which 399 were gynecological cancer patients, giving a 19.3% prevalence of gynecological cancer. Fifty-six gynecological cancer related deaths were reported within the study period with an overall cancer mortality rate of 14.0%. Ovarian cancer was responsible for the highest number of deaths 48.2% with a case-fatality rate of 18.6% while cervical cancer had a case fatality rate of 13.1%. Majority of the patients 96.6% presented at advanced stage of the disease. Those with financial constraints totaled 62.5% while 89.3% had challenges accessing specialized health care.
Conclusion: The study shows that the case-fatality rate of mortalities from gynaecological cancers at UPTH is very high with ovarian malignancy accounting for most deaths. Late presentation, low socioeconomic status and delay in accessing specialized health care were the main factors responsible for these mortalities. Proper screening, early diagnosis. prompt treatment and improvement in the socioeconomic status of gynaecological cancer patients will improve the case fatality rate in UPTH.
Examination of Compatibility of Autochthonous Pear Cultivars from the Region of Northeastern Bosnia with Vegetative Rootstock of the Genus Cydonia sp
Authors: Salkić Besim , Salkić Ahmed , Imširović Emir , Salkić Ensar , Salihović Emina 
Published: February 2022

Rootstocks of the genus Pyrus are easily adapted to climatic conditions and such trees are more resistant to Erwinia amylovora, but they also have disadvantages because these trees are more lush and difficult to grow in dense composition. The production of pears in a dense composition is a tendency of intensive pear production, and quince rootstocks are used for this purpose, because it is easier to control the height of the stem.
The increase in the density of the composition in pear orchards is directly related to the use of vegetative rootstocks of less lushness, such as rootstocks of the genus Cydonia sp.The research included five autochthonous pear varieties: Takiša, Jeribasma, Šećerka, Karamut i Huseinbegovača.
The tests were performed at the location Voćni rasadnik, Špionica, City Srebrenik, Tuzla Canton, Bosnia and Herzegovina, during the vegetation of 2021.
Morphometric analyzes were performed on a sample of 30 seedlings for each pear variety. Average results are presented using MS Excel software packages.
Seedlings of grafted varieties on the basis of diameter did not meet the conditions of marketing, while on the basis of vegetative growth, three varieties met the conditions of marketing of planting material. The research was conducted within the project number 02 / 9-712-1-5-4 / 21.
Grafted autochthonous varieties in the year of grafting showed extremely good adhesion with the vegetative rootstock BA-29, but did not have a good diameter. Due to the possibility of remanence, it is necessary to continue research after planting seedlings in plantations.
Gunshot Injuries in Port Harcourt, Nigeria: The University Teaching Hospitals’ Experience
Authors: Aaron Friday E. , Ogoronte A. Ijah Rex Friday , Harcourt Somiari L. , Alabi Ajibola 
Published: February 2022

Background: Gunshot injuries constitute significant contributor to morbidity and mortality of the healthcare in most societies. The global burden of gunshot injuries seems to be on the rise with the increase in violent crimes and unrest across the world.
Aim: The aim of this study was to determine the pattern of gunshot injuries seen in the surgery departments of the two Teaching Hospitals in Port Harcourt from January 2010 to January 2019.
Materials and Methods: A descriptive retrospective study was carried out using data obtained from registers for patients who had gunshot injuries from January 2010 to January 2019 in two government-owned tertiary healthcare facilities in Port Harcourt.
Results: A total of 1138 cases of gunshot injuries was recorded within the ten-year study period, with relatively higher number of cases seen during the 2011/2012 (122/116), 2015 (134), and 2019 (138). The age range 20 - 44 years are more involved in these injuries, and abdominal injuries (205 cases) top the record followed by lower limb injuries (132 cases).
Conclusion: Gunshot injury is a significant contributor to morbidity and mortality among patients in Port Harcourt, with a total of 1138 cases seen within the ten-year study period. Males were six times affected than females. There is need to equip these reference hospitals for trauma care, and reduce election-related violence in Port Harcourt as this appears to be taking a toll on the citizens.
Integrating In-silico with In-vitro Studies of Rutin as an Anti Hypertensive
Authors: Raju M. Ganga , Suvarchala Reddy N. V. L , Srivani M. , Pratyusha B. 
Published: February 2022

Rutin was evaluated for its antihypertensive effect by In vitro ACE inhibitory activity using Captopril as standard. For molecular docking the proteins namely PDB ID: 1UZE, 1O86, 2XY9 and 3L3N are selected and modelled. The abilities of the 3D model were assessed via the PROCHECK database and considered with the Ramachandran plot. The G-score of rutin was found to be more than the glide score of standard drug captopril affirming that the compound had similar affinity to impasse to the proteins. Proteins with PDB ID 1UZE, 1O86, 2XY9, and 3L3N showed more than 90% favoured area which evidently specifies that the designated protein in the current research is of noble eminence. ADME (Absorption, Distribution, Metabolism and Excretion outcome shown the three violations of rutin out of the five and the Captopril has got zero violations which noticeably shown the possibility for its greater oral bioavailability. The results of bioactive score revealed that rutin and captopril showed moderately active against GPCR ligand, ion channel modulator, kinase inhibitor and nuclear receptor but both rutin and the standard captopril were found to be highly dynamic counter to protease inhibitor and enzyme inhibitor. The PASS results clearly stated that rutin and captopril as cardio protectant, vasoprotector, vasodilator, antihypertensive. Rutin was predicted with hepatoxicity and nephrotoxicity while captopril was predicted with myocardial infarction, hepatotoxicity and nephrotoxicity. The direct targets of rutin have interventions with Cytochrome P4503A, Carbonic anhydrase II, Sodium /glucose cotransporter/2 and TNF-alpha for direct targets. The possible targets were with vascular endothelial growth factor receptor 1, and Sodium /glucose cotransporter/2. In vitro ACE inhibition assay demonstrated that rutin has shown antihypertensive activity by inhibiting angiotensin converting enzyme. From the above results the mechanism of action of rutin was validated through in silico interactions with the suitable PDB’s from MCULE software.
Effect of Virgin Coconut Oil in Plaque Related Gingivitis
Authors: Rakshitha V. S. , Priya A. Jothi , Devi R. Gayatri 
Published: February 2022

Introduction: In all individuals oral health is important. Irrespective of nationality, oral hygiene habits are taught in childhood itself. Tooth cleaning by the mechanical method is the most accepted method in the maintenance of oral hygiene worldwide. Presently to reduce plaque formation chemotherapeutic agents are used. Oil pulling is used for many years for strengthening gums, teeth and to prevent oral malodor and bleeding gums. Coconut oil is consumed as a staple diet. Coconut oil contains 50% of Lauric acid and 92% of saturated acid. The lauric acid contains anti-inflammatory properties.
Aim: This study aimed to find out the efficacy of virgin coconut oil in plaque-related gingivitis.
Materials and Methods: The sample size used for the study is 108, A self-structured questionnaire has been prepared and uploaded in Google forms. This standard questionnaire in Google forms is being circulated among the sample study population and at the end of the survey, all the data were collected and the data is been analyzed by using Chi-square analysis. The Chi-square analysis was done using the software IBM SPSS Software Version 23.
Results: The Chi-square analysis was done and the association between gender and improvement in gingival health after oil pulling in the South Indian population was found to be statistically significant. Chi-square value:11.77 and p-value:0.038, (p<0.05) hence a statistically significant decrease in gingival and plaque was noticed during the study period.
Conclusion: In summary, using Virgin coconut oil pulling could be an effective procedure in decreasing plaque-related gingivitis. This preliminary study shows that coconut oil is easily usable, cost-effective, and safe with minimal side effects which are used as an adjuvant in oral hygiene maintenance. Further studies on the antimicrobial potency of coconut oil are required for the use of coconut oil as an effective oral antimicrobial agent.