bluuebunny/crossref_metadata_2025_split huggingface dataset:
Article: The EU’s Uncoordinated Approach to Tax Avoidance and Tax Abuse in Relation to ‘Uncooperative’ Tax Jurisdictions
Authors: Geringer Stefanie 
Published: May 2022

The European Union (EU)’s external tax policies in relation to ‘uncooperative’ tax jurisdictions are predominantly shaped by the case law of the Court of Justice of the European Union (CJEU), the Member States’ domestic tax laws and, most recently, the EU list of non-cooperative jurisdictions for tax purposes (EU blacklist). Research in academia scholarship has assessed the EU blacklist from various angles. The objective of this article is to contribute to this discussion by contextualizing the EU blacklist with the relevant CJEU case law on anti-avoidance and antiabuse provisions applied in third country situations. Beyond an assessment from a doctrinal perspective, particular emphasis is placed on related tax policy issues. This combined evaluation yields three primary conclusions: the EU blacklist’s soft law character allows the Member States to continue to take advantage of type-casted and irrebuttable anti-avoidance and anti-abuse provisions in light of the CJEU case law; the EU blacklist’s inability to meet its initial objectives can be explained by political dynamics at the EU level; and the EU blacklist might relieve some of the currently manifesting symptoms without addressing the fundamental flaws in the international tax system.
CJEU case law, developing countries, EU blacklist, EU external tax policies, free movement of capital, harmful tax competition, mutual assistance, tax abuse, tax avoidance
Article: Access to Tax Treaty Dispute Resolution Mechanisms in Cases of Abuse
Authors: Navarro Aitor 
Published: May 2022

Reaching a common understanding of the interpretation and enforcement of tax treaties is a desirable policy goal. It results in higher certainty and helps to increase their effectiveness thus enhancing all the purported objectives of these international agreements. In this regard, dispute resolution mechanisms within international tax law fulfil a relevant coordinating function through the amicable assessment of frictions and mismatches in tax treaty provisions. Notwithstanding, access to these remedies is sometimes denied when the tax authorities consider that the case involves tax abuse even though anti-tax abuse measures usually pose some of the most complex interpretation challenges within tax treaties. Even after the post-BEPS wide implementation of broad-based treaty anti-abuse rules – such as the principal purpose test – countries are reluctant to grant unrestricted access to dispute resolution remedies. This contribution aims at depicting the rather asymmetrical state of affairs on the access to dispute resolution remedies in instances of tax abuse. Additionally, it purports to demonstrate that there are compelling policy reasons to support granting access to both mutual agreement and arbitration procedures in these cases and to criticize the incoherencies that originate from the existing restrictions.
Tax treaties, dispute resolution, mutual agreement procedure, arbitration, MLI, Tax abuse, GAAR, PPT
Critical Review Of The ATAD Implementation: The Implementation of the ATAD by Austria
Authors: Geringer Stefanie 
Published: May 2022

The Anti-Tax Avoidance Directive (ATAD) and ATAD II had major implications for the Austrian corporate tax regime. Particularly, Austria was obligated to introduce an interest limitation rule, a controlled foreign company (CFC) rule, and comprehensive hybrid mismatches rules. In addition to an overview of the transposition measures, this contribution particularly aims at elucidating remarkable deviations from the ATAD’s standards and discussing selected issues arising in the specific Austrian context.
Tax abuse, tax avoidance, BEPS, ATAD, EU law, adoption of EU secondary law
Country Note: Honduran Zones for Employment and Economic Development (ZEDEs) in Light of BEPS Action 5
Authors: Obando Roberto Ramos 
Published: May 2022

Based on Nobel Laureate Paul Romer’s concept of charter cities and following the models of Hong Kong and Singapore, Honduras is the site of an experimental special regime called Zones for Employment and Economic Development (ZEDEs). The ZEDEs are autonomous regions with their own policies, regulations and courts. They are form of private microstate that seeks to create conditions for direct foreign investment and develop rural areas in Honduras. This article seeks to determine if the tax regimes established in the ZEDEs, according to their General Law and examples of specific statutes, are at risk of being categorized as harmful regimes based on Base Erosion and Profit Shifting (BEPS) Action 5 on Harmful Tax Practices.
Tax, BEPS Action 5, Honduras, ZEDEs, Harmful Tax Practices, Special Regime
Het Sumal-arrest
Authors: Korneeva O.V. , VerLoren van Themaat W. 
Published: May 2022

Het Sumal-arrest. Doorbraak in aansprakelijkheid van de onderneming voor mededingingsinbreuken
In dit artikel analyseren de auteurs het Sumal-arrest waarin het Hof van Justitie de vraag heeft beantwoord of een dochteronderneming aansprakelijk kan worden gesteld door de benadeelde partijen voor een door haar moedermaatschappij gepleegde mededingingsinbreuk (‘neerwaartse aansprakelijkheid’) en zo ja, onder welke voorwaarden. Dit arrest is geanalyseerd vanuit de doctrine van persoonlijke aansprakelijkheid en de doctrine van economische eenheid. Tot slot wordt ingegaan op de mogelijke gevolgen van dit arrest voor de privaat- en publiekrechtelijke handhaving van mededingingsrecht.HvJ 6 oktober 2021, C-882/19, ECLI:EU:C:2021:800 (Sumal, S.L./Mercedes Benz Trucks España, S.L.).
GAMBARAN PENGETAHUAN MASYARAKAT TENTANG BAHAYA VIRUS CORONA DIDESA KALI UPA KECAMATAN LOLODA UTARA
Authors: Sri Sero Leni , Asih Blandina Olivia , Nur Fitria Pipit 
Published: May 2022

Background: The corona virus is a disease that causes the respiratory tract ranging from the common cold, difficulty breathing and even death.
Purpose: of this study was to identify a description of public knowledge about the dangers of covid-19 in Kailupa Village, North Loloda District.
Method: the study uses a quantitative method with a descriptive approach. This research will be carried out in Kailupa Village, North Loloda District in July-August 2020. The samples taken in the study are the people of Kailupa Village, North Loloda District who are 14-59 years old. The sampling technique uses Probility sampling technique with simple random sampling technique, sampling using the Slovin formula in order to get 100 respondents. The data obtained in this study were collected using a questionnaire distributed to the people of Kailupa Village, Loloda Utara District.
Results:analysis in this study used univariate data analysis. Based on the data from the questionnaire, the researcher found that the knowledge of the people of Kailupa Village was quite good and not good about the dangers of the corona virus.
Conclusion: Public knowledge about the dangers of the corona virus in Kailupa Village, North Loloda Subdistrict has sufficient and inadequate knowledge.
DESKRIPSI POTENSI DAN STRATEGI PENGEMBANGAN PARIWISATA DI KOTA BERASTAGI KABUPATEN KARO
Authors: Erianto Edy 
Published: May 2022

Karo regency has alot of tourism potential consist of marine tourism, religious tourism, culture tourism, ecotourism and others. The tourist destination have it’s own appeal for domestic or foreign tourists. The tourist visits increased every year.
This study aims to determine the potential and strategy for developing tourism in Karo District. This type of research is qualitative research with a descriptive approach. Research informants were determined purposively. The technique of collecting data was done by observation, interviews and documentation. Analysis data is was with data reduction, presentation of data, conclusion and data triangulation. The data are presented and analyzed in descriptively. The results shows that department of tourism Karo regency have strategy to develop the tourism. Development strategy used such as; Man, for maximize human resources quantity of department of tourism Karo regency, then departmen of tourism has cooperate with stakeholder such as community, agent, blogger, and establish tourism promotion agency for support the tourism marketing.
IMPOLITEESS STRATEGIES USED ON ONLINE COMMENTS IN THE LIPUTAN6.COM OF POLITICAL NEWS
Authors: Meidipa Lisa Fitri , Lubis Khairunnisah 
Published: May 2022

This study investigates the impoliteness strategies in online comments in Liputan6.com. The objectives of this study are: 1) to investigate the types of impoliteness strategies used on online comments in website Liputan6.com, 2) to find out the dominant type of impoliteness strategies used on online comments in website Liputan6.com. This study was conducted by using qualitative content analysis method. The data were taken from comments of internet users in five topics of political news in Idntimes.com. The finding showed that four of five types of impoliteness strategies are used on online comments in website Liputan6.com. They are: Bald on Record, Positive impoliteness, Negative Impoliteness, and Sarcasm or Mock politeness. The dominant types is negative impoliteness by used scorn or ridicules comments and invade the other's space with that comments and explicitly associate the other with a negative aspect.
IDEOLOGI NUBUWWAH DALAM PEMBANGUNAN WILAYAH MELALUI KEBIJAKAN DAN PERSPEKTIF POLITIK IBNU SINA
Authors: Nazri M , Mukti Abdul , Dahlan Zaini 
Published: May 2022

A politics does not have some rich people who have the power to achieve authority. Understanding Politics will be narrow if it is interpreted as a power conflict to gain position and authority. Politics is the style of humans interacting to form social relations in order to give birth to an equitable and prosperous country, therefore politics belongs together. The state will not be realized as a respectable country if there is no good interaction from the leader and his people. Both of them practice what has been agreed upon together. This article focuses on Ibn Sina's political thought as a social and political analysis found today, especially in Indonesia. Ibn Sina's political ideas lead to nubuwwah as well as foreign political thoughts. Thus, the State Leaders actually practice the values ​​of the Prophetic heritage in their souls. Similarly, what is carried out by the community is to comply with the existing regulations in their territory, so that the realization of a country with noble character is realized.
Biotic potential of an exotic date palm pest specie: Oryctes agamemnon (Coleoptera: Scarabaeidae)
Authors: Ehsine M’hammed , Belkadhi Mohamed Sadok , Chaieb Mohamed 
Published: May 2022

In Tunisia, particularly in southern regions, the culture of date palms plays an important role, both at socioeconomic and ecological levels. In spite of its importance, this agro-system is still threatened by many species of insects and diseases. Among these phytosanitary problems figure the exotic pest Oryctes agamemnon. This insect causes severe damage on palm tree mainly on the collar and the root system. The aim of this work is to study some parameters of the biotic potential of the insect. A number of ten couples were used in this survey. Follow-up of the experiment under the following conditions (Relative humidity = 40 +/- 6%, Temperature = 28 ° C +/- 2 ° C and a photoperiod: 16/8) allowed to study the reproductive potential, the larval survival rate and the adult lifetime. The follow-up of the experiment shows that the average pre-oviposition period and the average post-oviposition period are 25.3 ± 9.85 and 7.3 ± 5.39 days, respectively. The developmental cycle comprises, the egg, 3 larval stages L1, L2 and L3, prenymph and nymph respectively lasted 13,742 ± 2,011 days, 26,591 ± 3,142 days, 43,361 ± 3,237 days, 137,047 ± 6,132 days, 7,487 ± 0,909 days and 21,390 ± 2,655 days. Survival rates for the various stages ranged from 83.631 to 93.886%. Adults lived on average 55.18 days for males and 60 days for females. The average number of eggs laid per female was 28.7 ± 17.13 with an average fertility rate of 81.184%.
The World Set Free
Authors: Wells H. G. 
Published: May 2022

In a novel written on the eve of World War I, H. G. Wells imagines a war “to end all wars” that begins in atomic apocalypse but ends in an enlightened utopia.
Writing in 1913, on the eve of World War I's mass slaughter and long before World War II's mushroom cloud finale, H. G. Wells imagined a war that begins in atomic apocalypse but ends in a utopia of enlightened world government. Set in the 1950s, Wells's neglected novel The World Set Free describes a conflict so horrific that it actually is the war that ends war.
Wells—the first to imagine a “uranium-based bomb”—offers a prescient description of atomic warfare that renders cities unlivable for years: “Whole blocks of buildings were alight and burning fiercely, the trembling, ragged flames looking pale and ghastly and attenuated in comparison with the full-bodied crimson glare beyond.” Drawing on discoveries by physicists and chemists of the time, Wells foresees both a world powered by clean, plentiful atomic energy—and the destructive force of the neutron chain reaction.
With a cast of characters including Marcus Karenin, the moral center of the narrative; Firmin, a proto-Brexiteer; and Egbert, the visionary young British monarch, Wells dramatizes a world struggling for sanity. Wells's supposedly happy ending—a planetary government presided over by European men—may not appeal to contemporary readers, but his anguish at the world's self-destructive tendencies will strike a chord.
Sarah Cole is the author of Inventing Tomorrow: H.G. Wells and The Twentieth Century (2019). The Parr Professor of English and Comparative Literature and Dean of Humanities at Columbia University, she is the cofounder of the NYNJ Modernism Seminar and founder of the Humanities War and Peace Initiative at Columbia. She is also the author of Modernism, Male Friendship, and the First World War (2003) and At the Violet Hour: Modernism and Violence in England and Ireland (2012).
Joshua Glenn, who was the first to describe the years 1900–1935 as science fiction's “Radium Age,” has helped popularize stories from the era for over a decade now. A former Boston Globe staffer and publisher of the indie intellectual journal Hermenaut, he is coauthor of The Idler's Glossary (2008), Significant Objects (2012), and the family activities guide UNBORED (2012). He is also cofounder of the brand consultancy Semiovox; and he publishes the blog HiLobrow.
The Secrets of Words
Authors: Chomsky Noam , Moro Andrea 
Published: May 2022

Two distinguished linguists on language, the history of science, misplaced euphoria, surprising facts, and potentially permanent mysteries.
In The Secrets of Words, influential linguist Noam Chomsky and his longtime colleague Andrea Moro have a wide-ranging conversation, touching on such topics as language and linguistics, the history of science, and the relation between language and the brain. Moro draws Chomsky out on today's misplaced euphoria about artificial intelligence (Chomsky sees “lots of hype and propaganda” coming from Silicon Valley), the study of the brain (Chomsky points out that findings from brain studies in the 1950s never made it into that era's psychology), and language acquisition by children. Chomsky in turn invites Moro to describe his own experiments, which proved that there exist impossible languages for the brain, languages that show surprising properties and reveal unexpected secrets of the human mind.

Chomsky once said, “It is important to learn to be surprised by simple facts”—“an expression of yours that has represented a fundamental turning point in my own personal life,” says Moro—and this is something of a theme in their conversation. Another theme is that not everything can be known; there may be permanent mysteries, about language and other matters. Not all words will give up their secrets.
Genetic Divergence in Micronutrient Rich wheat– A Tool to Identify Diverse Parents
Authors: Sheera Ashish , Dey Tuhina , Pandey Mukesh Kumar , Singh Tushadri , Bhagat Taruna , K Shruthi 
Published: May 2022

Aim: To Study genetic divergence in the micronutrient rich lines to identify diverse parents for hybridization.
Study Design: Randomized Complete Block Design
Place and Duration of Study: Division of Plant Breeding and Genetics, She-e-Kashmir University of Agricultural Sciences and Technology of Jammu during rabi 2019-20.
Methodology: Nature and magnitude of variability in forty-nine zinc/iron rich genotypes along with three commercial varieties with stripe rust resistance could be grouped into five clusters using D2–Statistics.
Results: Fifty-two lines were placed in five cluster with most of the micronutrient rich lines lying in cluster I except for HP-44 , HP 49 , HP 14 and HP 13 placed in cluster II, III, IV and V respectively indicating them to be divergent than the rest. Further HD 3086, RSP 561 and JAUW-683 were in the cluster I indicating them to be less diverse with respect to traits under study. The traits that contributed mast towards divergence were grain yield per plant(25) percent followed by number of tillers per plant (20.7) percent and 1000 grain weight (14) percent zinc and iron add little contribution of 8 and 7 percent respectively to the total divergence hence could not classified the genotypes into different cluster based on inter cluster distance Cluster III and Cluster V had the greatest inter-cluster distance, followed by Cluster III and Cluster IV, Cluster II and Cluster V, and Cluster II and Cluster IV.
Conclusion: Developing wheat varieties with enhanced content of iron and zinc is one of the most sought objectives in a present world to alleviate micronutrient malnutrition. Modern wheat varieties exhibit little diversity in zinc and iron levels in the grain, but large-scale screening has found significant amounts of zinc and iron in wild relatives and progenitors of cultivated wheat.
Design of a Heating Chamber for Air Turbines: A Method of Optimizing Its Efficiency
Authors: Adeniji Excel E. , Asonja Taiwo O. , Alare Taiwo 
Published: May 2022

Increasing comfort, conveniences and reducing carbon-emission into the atmosphere have been the research focus of many researchers in various field of science. SDGs have one of her goals to be zero carbon emission. In order to achieve this goal, carbon combustion must be eliminated in heat engines. This can be done by developing thermodynamics processes that would not use organic fuel as their working fluid. Following this knowledge, researchers found the use of abundant natural resources such as solar, water, wind, and air known as renewable energies also hydrogen and synergy gases as replacement to carbon combustion. However, due to high first cost of these renewable energies and their low mechanical and overall efficiencies, they failed in some applications.
In order to increase the mechanical efficiency of air turbines, the internal energy of air must be increase. Therefore, this research paper developed a heating chamber for air turbines working on an isobaric expansion process in order to raise the temperature of air to the required temperature for it to roll turbine rotor blades efficiently. The heating compartment is intended to follow the adiabatic compression process of an air compressor section of the air turbine layout. The heating compartment has it heat source to be an electric heater and the compressed air as it heat sink. The thermal and economic efficiency of the heating chamber as a section of air turbine was determine using Levelized Cost Method of Moran.
The heating compartment raised the compressed air temperature to the required hot temperature at a constant pressure.
Water‐Triggered Stiffening of Shape‐Memory Polyurethanes Composed of Hard Backbone Dangling PEG Soft Segments
Authors: Liu Wenkai , Wang Ao , Yang Ruibo , Wu Hecheng , Shao Shuren , Chen Jinlin , Ma Yan , Li Zhen , Wang Yanchao , He Xueling , Li Jiehua , Tan Hong , Fu Qiang 
Published: May 2022

AbstractShape‐memory polymers (SMPs) induced by heat or water are commonly used candidates for biomedical applications. Shape recovery inevitably leads to a dramatic decrease of Young's modulus due to the enhanced flexibility of polymer chains at the transition temperature. Herein, the principle of phase‐transition‐induced stiffening of shape‐memory metallic alloys (SMAs) is introduced to the design of molecular structures for shape‐memory polyurethane (SMPUs), featuring all‐hard segments composed of main chains that are attached with poly(ethylene glycol) (PEG) dangling side chains. Different from conventional SMPs, they achieve a soft‐to‐stiff transition when shape recovers. The stiffening process is driven by water‐triggered segmental rearrangement due to the incompatibility between the hard segments and the soft PEG segments. Upon hydration, the extent of microphase separation is enhanced and the hard domains are transformed to a more continuous morphology to realize more effective stress transfer. Meanwhile, such segmental rearrangement facilitates the shape‐recovery process in the hydrated state despite the final increased glass transition temperature (Tg). This work represents a novel paradigm of simultaneously integrating balanced mechanics, shape‐memory property, and biocompatibility for SMPUs as materials for minimally invasive surgery such as endoluminal stents.
A Study of Second‐Order Susceptibility in Digital Alloy‐Grown InAs/AlSb Multiple Quantum Wells
Authors: Foster Natalie D. , Rockwell Ann Kathryn , McArthur Joshua Andrew , Mendoza Bernardo S. , Bank Seth R. , Downer Michael C. 
Published: May 2022

AbstractA preliminary measurement of the second‐order nonlinear optical susceptibility of symmetric, coupled, InAs/AlSb multiple quantum well (MQW) structures is acquired through optical second‐harmonic generation (SHG) at fundamental wavelength 1.55 µm. High quality crystalline MQW structures of variable thickness and corresponding bulk AlSb control samples are achieved using a digital alloy epitaxial growth technique that avoids cluster formation and phase segregation. All samples are grown in between a GaSb cap and substrate layer. To isolate SHG from the MQW (or control) layers of interest from cap and substrate contributions, a multilayer optical response matrix model is built and independently tested by accurately reproducing linear reflectivity spectra. While a simplified response matrix analysis of SHG based solely on bulk χ(2)s does not reproduce the distinct SHG responses of the two sets of samples, the inclusion of an additional interface SHG contribution leads to a successful fit of the data and implies . The results demonstrate a proof‐of‐concept quantification of χ(2) in symmetric MQWs and suggest the possibility of engineering χ(2) in these structures, particularly with the introduction of well asymmetries.
An Optimized KBe2BO3F2‐Like Structure: The Unity of Deep‐Ultraviolet Transparency, Nonlinear Optical Property, and Ferroelectricity
Authors: Sha Hongyuan , Xu Junxin , Xiong Zheyao , Wang Zujian , Su Rongbing , He Chao , Yang Xiaoming , Long Xifa , Liu Ying 
Published: May 2022

AbstractAt present, only KBe2BO3F2 (KBBF) can effectively realize a deep‐ultraviolet (DUV) coherent output, while the layered growth habit seriously hinders its application. Here, a new design strategy with an optimized KBBF‐like structure based on the quasi‐phase matching principle is proposed. Thus, the first KBBF‐like ferroelectric, Li2KRb(SO4)2, is designed. It exhibits a short DUV absorption cutoff edge of 163 nm, a large nonlinear optical (NLO) effect of 1.7 × KH2PO4 under a 1064 nm laser, and typical ferroelectricity. More importantly, it completely eliminates the layered structure by replacing K‐F bonds with strong ‐Li‐O‐S‐ ones as the interlayer force. Therefore, this work finds a new promising DUV NLO candidate, a unity of the DUV transparency, NLO response, and ferroelectricity, which is advantageous to explore new DUV NLO materials.