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Journal articles on the topic 'Arms length principle'
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Setiawan, Benny, and Eko Sulistyono. "ANALISIS PENERAPAN KETENTUAN PERPAJAKAN TENTANG KRITERIA PINJAMAN YANG SESUAI DENGAN PRINSIP KEWAJARAN DAN KELAZIMAN USAHA DALAM TRANSAKSI HUBUNGAN ISTIMEWA." INFO ARTHA 1 (June 7, 2017): 73–96. http://dx.doi.org/10.31092/jia.v1i1.71.
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To counteract tax evasion (thin-capitalization), countries across the world including Indonesia begin to apply certain rules. One of the method is to limit the amount of debt of intra-group loan transactions based on the arms length principles. However, the application of this principle to assess the fairness of the loan transaction is not smooth. The unclear set of criteria cause disputes when it is applied. This study analyzes the implementation of the criteria and the relationship among these criteria when they are used simultaneously. The findings of the study initially found that the regulations in Indonesia only adhere to two criterias: the need of debt and debt to equity ratio comparison with its peers. However, in practice, there is another criterion commonly used that is borrowing capacity. Because the regulation concerning these criteria is considered as a guideline and not binding, it is feasible to use all three criteria. When they are applied, it turns out that only the ratio criterion is considered as the most objective and applicable. Nevertheless, the loan between related parties can only be said to fulfill the arms length principle only if all the criteria are met.
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Shen, Yong Kang, Zheng Zhong Wang, and Chun Long Zhao. "Stability Bearing Capacity of Dendritic Arms in Tainter Gate." Applied Mechanics and Materials 733 (February 2015): 464–67. http://dx.doi.org/10.4028/www.scientific.net/amm.733.464.
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The new arms form of radial gate—dendritic arms is introduced for the proper mechanical mechanism, however the stability design is very difficult. According to the stability theory of structure, the stability analysis model of step column with lateral restraints was proposed for dendritic arms, some equations was derived from the principle of minimum potential energy, the practical formulas of buckling bearing capacity and effective length coefficient were provided. According to an example, the accuracy on formulas was verified by finite analysis method.
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Dewi, Ni Luh Rian, and Nur Aisyah Kustiani. "ANALISIS FAKTOR-FAKTOR YANG MEMPENGARUHI PROFITABILITAS PERUSAHAAN MANUFAKTUR INDEPENDEN DI KAWASAN ASIA DAN APLIKASINYA DALAM MENENTUKAN PEMBANDING KEWAJARAN DAN KEWAJARAN USAHA." INFO ARTHA 3 (May 23, 2017): 154–69. http://dx.doi.org/10.31092/jia.v3i0.50.
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In the tax audit on companies which involves transfer pricing in their transaction, tax auditor must determine benchmark companies to determine the arms length principle to be met by the companies. This study aims to analyze determinant factors of the profitability of independent manufacturing companies in Asia. Determinant factors of profitability can be used to determine the appropriate comparison companies. The study used two models with Plust net cost margin and return on assets as dependent variables of each model. Whereas, the independent variables used in this study are the ratio of operating revenue / net sales; operating profit; number of employees; payroll; total assets; tangible fixed assets; net working capital, cash and cash equivalent; other assets; geography; and industry. The results show that operating profit; net working capital; cash and cash equivalent and geography influence significantly and have been tested to determine comparator companies in determining the arms length principle.
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Zeng, Ling Sheng, Zi Qiang Zhang, Run Dian Li, Yong Jie Zhao, Qing Ge Kang, and Zhang Lin Chen. "On Adaptable Design for SCARA Manipulator with Quick-Replaceable Arms." Applied Mechanics and Materials 741 (March 2015): 45–49. http://dx.doi.org/10.4028/www.scientific.net/amm.741.45.
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By surveying SCARA manipulator in the market, the question that the overall length of arms is fixed, which leads its operating range to be relatively fixed, and the manipulator has badly adaptive can be found. Aiming at the problem, a SCARA manipulator whose arms can be replaced quickly had been designed according to the concept of adaptable design, and the principle of replacement arms had been put forward basing on the analysis to the minimum operating radius of manipulator in this paper. Moreover, an adaptable interface for replacing quickly different grippers during the process of production had been designed in the paper.
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Mangset, Per. "El principi d’arm’s lenght i el sistema de finançament de les arts. Una aproximació comparativa." Debats. Revista de Cultura, Poder i Societat 130, no. 2 (November 15, 2016): 53–72. http://dx.doi.org/10.28939/iam.debats.130-2.4.
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Mu, Dan, Jian-Quan Li, Xing-Shun Cong, and Han Zhang. "Mesoscopic Detection of the Influence of a Third Component on the Self-Assembly Structure of A2B Star Copolymer in Thin Films." Polymers 11, no. 10 (October 10, 2019): 1636. http://dx.doi.org/10.3390/polym11101636.
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The most common self-assembly structure for A2B copolymer is the micellar structure with B/A segments being the core/corona, which greatly limits its application range. Following the principle of structure deciding the properties, a reformation in the molecular structure of A2B copolymer is made by appending three segments of a third component C with the same length to the three arms, resulting (AC)2CB 3-miktoarm star terpolymer. A reverse micellar structure in self-assembly is expected by regulating the C length and the pairwise repulsive strength of C to A/B, aiming to enrich its application range. Keeping both A and B lengths unchanged, when the repulsion strength of C to A is much stronger than C to B, from the results of mesoscopic simulations we found, with a progressive increase in C length, (AC)2CB terpolymer undergoes a transition in self-assembled structures, from a cylindrical structure with B component as the core, then to a deformed lamellar structure, and finally to a cylindrical structure with A component as the core. This reverse micellar structure is formed with the assistance of appended C segments, whose length is longer than half of B length, enhancing the flexibility of three arms, and further facilitating the aggregation of A component into the core. These results prove that the addition of a third component is a rational molecular design, in conjunction with some relevant parameters, enables the manufacturing of the desired self-assembly structure while avoiding excessive changes in the involved factors.
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Kelly, Veronica. "The Globalized and the Local: Theatre in Australia and Aotearoa/New Zealand Enters the New Millennium." Theatre Research International 26, no. 1 (March 2001): 1–14. http://dx.doi.org/10.1017/s0307883301000013.
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Late in 1999 the Commonwealth of Australia's Department of Communications, Information Technology and the Arts released Securing the Future, the final Report of the Major Performing Arts Enquiry chaired by Helen Nugent (commonly referred to as the Nugent Report). The operations of the committee and the findings of the Report occasioned considerable public debate in the Australian arts world in the late 1990s, as the Enquiry solicited and analysed information and opinion on the financial health and artistic practices of thirty-one national major performing arts companies producing opera, ballet, chamber and orchestral music as well as theatre. The Report saw the financial viability of Australian live performance as deeply affected by the impact of globalization, especially by what elsewhere has been called ‘Baumol's disease’ – escalating technical, administrative and wage costs but fixed revenue – which threaten the subsidized state theatre companies of Brisbane, Adelaide and Perth with their relatively small population bases. The structural implementation recommended a considerable financial commitment by Commonwealth and State Governments to undertake a defined period of stabilizing and repositioning of companies. Early in 2000 both levels of Government committed themselves to this funding – in fact increasing Nugent's requested $52 million to $70 million – and to the principle of a strengthened Australia Council dispensing arms-length subsidy. In an economically philistine political environment, these outcomes are a tribute to Nugent's astute use of economic rhetoric to gain at least a symbolic victory for the performing arts sector. In 2000 New Zealand arts gained a similar major injection of funding, while a commissioned Heart of the Nation report, advocating the dilution of the principle of arm's-length funding through the abolition of the national funding organization Creative New Zealand, was rejected by Prime Minister Helen Clark.
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Bakvis, Herman. "Commissioned Ridings: Designing Canada's Electoral Districts. By John C. Courtney. Montreal: McGill-Queen's University Press, 2001. 337p. $75.00 cloth, $27.95 paper." American Political Science Review 96, no. 3 (September 2002): 655–56. http://dx.doi.org/10.1017/s0003055402680360.
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The approach to the design and revision of electoral districts in Canada is quite different from that found in the United States, despite the two countries' sharing of the same basic first-past-the-post electoral system. As John Courtney notes in his careful study of the topic, in Canada the emphasis in defining electoral districts, or constituencies or ridings, has been underpinned by concepts such as “community of interest” and “effective representation,” which encompass a wide range of political and social considerations—many local in nature—and which permit substantial deviation from the principle of one person, one vote. At the federal level, the allowable deviation in the size of constituencies can be plus or minus 25% within any given province, with the possibility of even greater variances under special circumstances. At the level of provincial electoral systems, the variances can be even larger, in part due to the fact that in certain provinces the ratio of urban to rural seats is specified in law. At the same time, the actual process of designing and reconfiguring the boundaries of constituencies, in the hands of independent, arm's-length commissions for the past 40 years, has been remarkably free of direct partisan influence. In fact, given the rather tattered state of current Canadian parliamentary democracy, characterized by one-party dominance in the federal parliament and a precipitous decline in voter turnout over the past three elections, the institution of arms-length boundary commissions stands out as something that works well and enjoys broad respect.
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Bonnitcha, Jonathan. "Article: Investment Treaties and Transition from Authoritarian Rule." Journal of World Investment & Trade 15, no. 5-6 (November 18, 2014): 965–1011. http://dx.doi.org/10.1163/22119000-01506009.
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Following recent events in Egypt, Libya, Myanmar (Burma) and Tunisia, foreign investors have lodged international claims under investment treaties. Several of these cases follow a common fact pattern. They concern foreign investments acquired from authoritarian governments substantially below market value through transactions that were not arms’ length. Subsequently, new governments sought to renegotiate these contracts and concessions, or to change the regulatory arrangements that govern them. The investors then invoked the protections of an investment treaty. This article draws on political science scholarship on transition. It argues that investment treaties risk constraining the ability of incoming democratic regimes to consolidate their position, and questions the normative justifications for applying the principle of full market value compensation to situations in which investments were not acquired on a full market value basis. These conclusions are relevant to wider debates about the tension between legal stability and political change in international law.
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Paciolla, Mariarita, Daniel J. Arismendi-Arrieta, and Angel J. Moreno. "Coarsening Kinetics of Complex Macromolecular Architectures in Bad Solvent." Polymers 12, no. 3 (March 2, 2020): 531. http://dx.doi.org/10.3390/polym12030531.
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This study reports a general scenario for the out-of-equilibrium features of collapsing polymeric architectures. We use molecular dynamics simulations to characterize the coarsening kinetics, in bad solvent, for several macromolecular systems with an increasing degree of structural complexity. In particular, we focus on: flexible and semiflexible polymer chains, star polymers with 3 and 12 arms, and microgels with both ordered and disordered networks. Starting from a powerful analogy with critical phenomena, we construct a density field representation that removes fast fluctuations and provides a consistent characterization of the domain growth. Our results indicate that the coarsening kinetics presents a scaling behaviour that is independent of the solvent quality parameter, in analogy to the time–temperature superposition principle. Interestingly, the domain growth in time follows a power-law behaviour that is approximately independent of the architecture for all the flexible systems; while it is steeper for the semiflexible chains. Nevertheless, the fractal nature of the dense regions emerging during the collapse exhibits the same scaling behaviour for all the macromolecules. This suggests that the faster growing length scale in the semiflexible chains originates just from a faster mass diffusion along the chain contour, induced by the local stiffness. The decay of the dynamic correlations displays scaling behavior with the growing length scale of the system, which is a characteristic signature in coarsening phenomena.
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Huang, Zhixiong, and Yaohui Ying. "The application of the principle of distinction in the cyber context: A Chinese perspective." International Review of the Red Cross 102, no. 913 (April 2020): 335–65. http://dx.doi.org/10.1017/s1816383121000023.
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AbstractUp to now, the Chinese government has only made very general comments on the application of international humanitarian law to cyberspace. There are indeed Chinese academic papers concerning this issue, but the discussion of the principle of distinction is limited both in length and in academic depth. Compared with the West, research by Chinese scholars on this topic is still in a relatively preliminary stage. At present, there is no specific deconstruction or clarification of the application of the principle of distinction in cyberspace in Chinese academia. As the first paper written by Chinese scholars specifically devoted to this question, this piece provides a different perspective by injecting the positions of Chinese officials and the views of Chinese scholars. The authors aim to clarify whether the existing rules are still completely applicable in the cyber context, and if needed, to find out what kind of improvements and clarifications can be made. Weighing in on these debates, we argue that despite the potential technical challenges and uncertainties, the principle of distinction should be applied to cyberspace. It should also be carefully re-examined and clarified from the standpoint of preventing over-militarization and maximizing the protection of the interests of civilians. For human targets, the elements of combatant status identified in customary international law and relevant treaties are not well suited to the digital battlefield. Nevertheless, cyber combatants are still obligated to distinguish themselves from civilians. In applying the principle of distinction, we argue that it makes more sense to focus on substantive elements over formal elements such as carrying arms openly or having a fixed distinctive sign recognizable at a distance. In interpreting “direct participation in hostilities”, the threshold of harm requires an objective likelihood instead of mere subjective intention; the belligerent nexus should be confirmed, and the causal link should be proximate. Applying the “cyber kill chain” model by analogy helps us to grasp the whole process of direct participation in hostilities during cyber warfare. For non-human targets, all military objectives must cumulatively fulfil both the “effective contribution” and “definite military advantage” criteria, which are equally indispensable. The same requirements apply to dual-use objects. Furthermore, certain data should fall within the ambit of civilian objects.
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Morimoto, Yoshiharu. "High-Speed Measurement of Shape and Vibration: Whole-Field Systems for Motion Capture and Vibration Modal Analysis by OPPA Method." Sensors 20, no. 15 (July 30, 2020): 4263. http://dx.doi.org/10.3390/s20154263.
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In shape measurement systems using a grating projection method, the phase analysis of a projected grating provides accurate results. The most popular phase analysis method is the phase shifting method, which requires several images for one shape analysis. Therefore, the object must not move during the measurement. The authors previously proposed a new accurate and high-speed shape measurement method, i.e., the one-pitch phase analysis (OPPA) method, which can determine the phase at every point of a single image of an object with a grating projected onto it. In the OPPA optical system, regardless of the distance of the object from the camera, the one-pitch length (number of pixels) on the imaging surface of the camera sensor is always constant. Therefore, brightness data for one pitch at any point of the image can be easily analyzed to determine phase distribution, or shape. This technology will apply to the measurement of objects in motion, including automobiles, robot arms, products on a conveyor belt, and vibrating objects. This paper describes the principle of the OPPA method and example applications for real-time human motion capture and modal analysis of free vibration of a flat cantilever plate after hammering. The results show the usefulness of the OPPA method.
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Rukomojnikov, Konstantin P., and Viktoriia O. Kuptcova. "Design Improvement of the Mechanism of Delimbing by Multi-Operational Forest Machines." Lesnoy Zhurnal (Forestry Journal), no. 3 (May 20, 2021): 117–24. http://dx.doi.org/10.37482/0536-1036-2021-3-117-124.
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The principles of increasing the use of modern multifunctional forest machines (harvesters and processors) for felling and delimbing in Russia and abroad are currently becoming more widespread and deserve increased attention from esearchers. The results of the studies performed made it possible to identify a wide range of constructive solutions of technological equipment interesting in the opinion of the authors of the publication and to develop a new technical solution. The idea of creating an additional shock load by the working body of multifunctional forest machines for delimbing during the processing of a tree trunk is one of the most effective options for the development of additional cutting force, allowing to facilitate the operation of the device. The proposed method involves delimbing the trunk by pulling rollers and is a combination of the operation of standard delimbing knives together with the gripping arms and a reciprocating delimbing knife that complements the design. The use of compressed air energy provides the reciprocating motion of the knife, creating a new principle of the cutting mechanism for this design. The article describes in detail the design of the device, its operation, as well as options for the interaction of individual technological elements. The implementation of the proposed idea will make it possible to introduce harvester and processor heads into the forestry sector, facilitating the operation of individual assemblies of forest machines with large average volume of the tree-length log. For citation: Rukomojnikov K.P., Kuptcova V.O. Design Improvement of the Mechanism of Delimbing by Multi-Operational Forest Machines. Lesnoy Zhurnal [Russian Forestry Journal], 2021, no. 3, pp. 117–124. DOI: 10.37482/0536-1036-2021-3-117-124
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Svinøy, Odd-Einar, Astrid Bergland, May Arna Risberg, Are Hugo Pripp, and Gunvor Hilde. "Better before–better after: efficacy of prehabilitation for older patients with osteoarthritis awaiting total hip replacement—a study protocol for a randomised controlled trial in South-Eastern Norway." BMJ Open 9, no. 12 (December 2019): e031626. http://dx.doi.org/10.1136/bmjopen-2019-031626.
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IntroductionHealth professions need to prepare for the increase of older patients with osteoarthritis requiring health services including those requiring total joint arthroplasty (TJA). The primary objective of this study is to assess the effect of a tailored prehabilitation programme of older patients awaiting primary surgery for total hip replacement on physical function measured by walking speed within 1 week after intervention as well as 6 weeks and 3 months after TJA surgery.Methods and analysisThis is a single-blinded randomised controlled trial. The participants are 70 years or older, scheduled for primary total hip replacement due to late stage osteoarthritis. The intervention group will receive patient education and exercise for 6–12 weeks. The control group will receive care as usual. The primary outcome is gait speed. Secondary outcomes are lower body strength, mobility, aerobic capacity, activity of daily living, length of stay at the hospital, referral to an inpatient rehabilitation clinic, pain, quality of life and cost-effectiveness. Estimated sample size is 150 participants randomised into the two arms. The data will be analysed following the intention-to-treat principle with methods for repeated measurements.Ethics and disseminationThe project proposal has been approved by The Regional Committee for Medical Research Ethics in South Norway (ref no. 2018/503). The results will be published in peer-reviewed articles.Trial registration numberNCT03602105
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Jakoubek, Jiří. "Arm's Length Principle in Intangible Assets Valuation." Český finanční a účetní časopis 2013, no. 4 (December 1, 2013): 70–83. http://dx.doi.org/10.18267/j.cfuc.353.
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Choe, Chongwoo, and Noriaki Matsushima. "The arm's length principle and tacit collusion." International Journal of Industrial Organization 31, no. 1 (January 2013): 119–30. http://dx.doi.org/10.1016/j.ijindorg.2012.12.001.
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Scott, Jessica, Samantha M. Thomas, James Emmett Herndon, Jeffrey M. Peppercorn, Pamela S. Douglas, Michel Khouri, Chau T. Dang, et al. "Effects of Non-Linear or Linear Aerobic Training (AT) Dosing Regimens on Impaired Cardiovascular (CV) Function in Patients with Operable Breast Cancer: A Randomized Controlled Trial (RCT)." Journal of Clinical Oncology 37, no. 15_suppl (May 20, 2019): 541. http://dx.doi.org/10.1200/jco.2019.37.15_suppl.541.
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541 Background: Breast cancer therapy causes marked impairments in CV function predisposing to elevated risk of CV morbidity. We investigated the effects of two AT dosing regimens on CV function in post-treatment patients with operable breast cancer. Methods: In a three-arm, parallel-group RCT, 174 post-menopausal patients (2.8 years post primary adjuvant therapy) with impaired age/sex-matched peak oxygen consumption (VO2peak) were randomized to: (1) conventional linear AT (uniform dose-intensity / session), (2) nonlinear AT (variable dose-intensity / session), or (3) stretching (attention control). AT consisted of 64 supervised treadmill walking sessions delivered four times weekly at either ~70% VO2peak for 40 mins/session (linear) or 55% to 100% VO2peak for 20-45 mins/session (nonlinear) for 16 consecutive weeks. Stretching was matched to AT on the basis of location, frequency, duration, and treatment length. The primary end point was change in VO2peak. Secondary end points were other markers of CV risk profile (biochemical CV risk profile, cardiac function, body composition), patient-reported outcomes (PROs), tolerability (e.g., relative dose intensity), and safety. All analyses followed the intention-to-treat principle. Results: Rates of lost-to-follow were < 10% in all arms. Relative dose intensity of AT was 73% ± 27% and 80% ± 21% in linear and nonlinear arms, respectively. No serious adverse events were observed. In adjusted analysis, compared to control, VO2peak (ml O2.kg-1.min-1) increased 0.7 (± 0.3) ml O2.kg-1.min-1 (p = 0.06) and 0.8 (± 0.4) ml O2.kg-1.min-1 (p = 0.02) in linear and nonlinear AT, respectively. Rates of VO2peak improvement greater than the technical error of measurement (i.e., ≥1.32ml O2.kg-1.min-1) were 33% and 39% in linear and nonlinear AT (p = 0.03), respectively. Both AT regimens were associated with improvements in several secondary CV end points but only nonlinear AT improved PROs compared with control (all p’s < 0.05). There were no differences between the two AT regimens. Conclusion: AT significantly improves CV function and PROs in post-treatment breast cancer patients. The efficacy-tolerability ratio favors the non-linear regimen over the conventional linear prescription approach. Clinical trial information: NCT01186367.
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Yao, Jen-Te. "The arm's length principle, transfer pricing, and location choices." Journal of Economics and Business 65 (January 2013): 1–13. http://dx.doi.org/10.1016/j.jeconbus.2012.09.004.
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Van Thiel, Sandra, and Amanda Smullen. "Principals and Agents, or Principals and Stewards? Australian Arms Length Agencies’ Perceptions of Arm’s Length Government Instruments." Public Performance & Management Review 44, no. 4 (February 11, 2021): 758–84. http://dx.doi.org/10.1080/15309576.2021.1881803.
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CHOE, CHONGWOO, and CHARLES E. HYDE. "Multinational Transfer Pricing, Tax Arbitrage and the Arm's Length Principle*." Economic Record 83, no. 263 (January 2, 2008): 398–404. http://dx.doi.org/10.1111/j.1475-4932.2007.00429.x.
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Keuschnigg, Christian, and Michael P. Devereux. "The arm's length principle and distortions to multinational firm organization." Journal of International Economics 89, no. 2 (March 2013): 432–40. http://dx.doi.org/10.1016/j.jinteco.2012.08.007.
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Berry, Robert, and Joyce Wiggins. "Spotlight on the Principles/Standards: Measurement in the Middle Grades." Mathematics Teaching in the Middle School 7, no. 3 (November 2001): 154–56. http://dx.doi.org/10.5951/mtms.7.3.0154.
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People use measurement ideas everyday because the ideas arise out of the need to compare attributes of the real world and because humans are naturally inclined to make comparisons. Comparison is the basis for measurement. We make simple comparisons, such as that “the width of the desk is about an arms length,” and complex comparisons expressed in terms of precise numerical measurements. Although measurement encompasses such topics as time, temperature, length, perimeter, and volume, this article specifically focuses on how middle school students learn about angle measurement.
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Bustos, Sebastián, Dina Pomeranz, José Vila-Belda, and Gabriel Zucman. "Challenges of Monitoring Tax Compliance by Multinational Firms: Evidence from Chile." AEA Papers and Proceedings 109 (May 1, 2019): 500–505. http://dx.doi.org/10.1257/pandp.20191045.
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This paper reviews common challenges of taxing multinational firms, using Chile as a case study. We briefly describe key international tax avoidance methods: profit shifting to low-tax jurisdictions through transfer pricing and debt shifting. We discuss the prevalent policy to tax multinationals--the arm's length principle--and alternative proposals using apportionment formulas. Novel data from Chile show that multinationals make up a large share of GDP but report lower profit and effective tax rates than local firms. In 2011, Chile implemented a reform following OECD guidelines to enforce the arm's length principle. We discuss potential effects on tax collection and welfare.
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Lee, Koo-Hyoung, and Karl H. E. Kroemer. "A Finger Model with Constant Tendon Moment Arms." Proceedings of the Human Factors and Ergonomics Society Annual Meeting 37, no. 10 (October 1993): 710–14. http://dx.doi.org/10.1177/154193129303701014.
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A kinematic finger model was developed with the assumption that the tendon moment arms at the finger joints were constant, and that the finger moved in the sagittal plane. Equations of static equilibrium for the model, derived using the principle of virtual work, were indeterminate. The number of variables was reduced based on the muscular activities in finger movements. The finger strengths were computed from the equilibrium equations, and mathematically expressed as functions of finger positions, tendon moment arms, and lengths of phalanges. Experiments were performed to measure finger strengths, and the measured finger strengths were compared to the computed results.
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Nerudová, D., and V. Solilová. "Transfer pricing in agricultural enterprises." Agricultural Economics (Zemědělská ekonomika) 57, No. 7 (August 1, 2011): 311–21. http://dx.doi.org/10.17221/84/2010-agricecon.
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International tax issues already have not been problems of multinational enterprises. The effect of globalization and international business development causes that many small and medium size firms including agricultural entities are now engaged in the cross-border transactions and have to face the international tax issues. One of the important areas of international taxes is transfer pricing. The transactions between these persons should be assessed at their arm's length price according to the arm's length principle (internationally accepted standard) as the price which would have been agreed between the unrelated parties in free market conditions. The aim of the paper is to evaluate the impact of the selection of the form of the subsidiary on the total tax liability of the agricultural entity, including the determination of the transfer price, the application of the arm's length principle and decisions about the most suitable legal form of the subsidiary.
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Li, Yongjun, Lin Lin, Qianzhi Dai, and Linda Zhang. "Allocating common costs of multinational companies based on arm's length principle and Nash non-cooperative game." European Journal of Operational Research 283, no. 3 (June 2020): 1002–10. http://dx.doi.org/10.1016/j.ejor.2019.11.049.
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Quinn, Ruth‐Blandina M. "Distance or intimacy?—The arm's length principle, the British government and the arts council of Great Britain1." International Journal of Cultural Policy 4, no. 1 (October 1997): 127–59. http://dx.doi.org/10.1080/10286639709358066.
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Chen, Zhe, and Simon Haykin. "On Different Facets of Regularization Theory." Neural Computation 14, no. 12 (December 1, 2002): 2791–846. http://dx.doi.org/10.1162/089976602760805296.
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This review provides a comprehensive understanding of regularization theory from different perspectives, emphasizing smoothness and simplicity principles. Using the tools of operator theory and Fourier analysis, it is shown that the solution of the classical Tikhonov regularization problem can be derived from the regularized functional defined by a linear differential (integral) operator in the spatial (Fourier) domain. State-ofthe-art research relevant to the regularization theory is reviewed, covering Occam's razor, minimum length description, Bayesian theory, pruning algorithms, informational (entropy) theory, statistical learning theory, and equivalent regularization. The universal principle of regularization in terms of Kolmogorov complexity is discussed. Finally, some prospective studies on regularization theory and beyond are suggested.
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DUDLEY, GEOFFREY. "THE NEXT STEPS AGENCIES, POLITICAL SALIENCE AND THE ARM'S-LENGTH PRINCIPLE: BARBARA CASTLE AT THE MINISTRY OF TRANSPORT 1965-68." Public Administration 72, no. 2 (June 1994): 219–40. http://dx.doi.org/10.1111/j.1467-9299.1994.tb01009.x.
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Sari, Nuraini, and Ririn Susanti Hunar. "Analysis Method of Transfer Pricing Used by Multinational Companies Related to Tax Avoidance and its Consistencies to the Arm's Length Principle." Binus Business Review 6, no. 3 (December 1, 2015): 341. http://dx.doi.org/10.21512/bbr.v6i3.944.
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The purpose of this study is to evaluate about how Starbucks Corporation uses transfer pricing to minimize the tax bill. In addition, the study also will evaluate how Indonesia’s domestic rules can overcome the case if Starbucks UK case happens in Indonesia. There are three steps conducted in this study. First, using information provided by UK Her Majesty's Revenue and Customs (HMRC) and other related articles, find methods used by Starbucks UK to minimize the tax bill. Second, find Organisation for Economic Co-Operation and Development (OECD) viewpoint regarding Starbucks Corporation cases. Third, analyze how Indonesia’s transfer pricing rules will work if Starbucks UK’s cases happened in Indonesia. The results showed that there were three inter-company transactions that helped Starbucks UK to minimize the tax bill, such as coffee costs, royalty on intangible property, and interest on inter-company loans. Through a study of OECD’s BEPS action plans, it is recommended to improve the OECD Model Tax Convention including Indonesia’s domestic tax rules in order to produce a fair and transparent judgment on transfer pricing. This study concluded that by using current tax rules, although UK HMRC has been disadvantaged because transfer pricing practices done by most of multinational companies, UK HMRC still cannot prove the transfer pricing practices are not consistent with arm’s length principle. Therefore, current international tax rules need to be improved.
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Zemel, Richard S., and Geoffrey E. Hinton. "Learning Population Codes by Minimizing Description Length." Neural Computation 7, no. 3 (May 1995): 549–64. http://dx.doi.org/10.1162/neco.1995.7.3.549.
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The minimum description length (MDL) principle can be used to train the hidden units of a neural network to extract a representation that is cheap to describe but nonetheless allows the input to be reconstructed accurately. We show how MDL can be used to develop highly redundant population codes. Each hidden unit has a location in a low-dimensional implicit space. If the hidden unit activities form a bump of a standard shape in this space, they can be cheaply encoded by the center of this bump. So the weights from the input units to the hidden units in an autoencoder are trained to make the activities form a standard bump. The coordinates of the hidden units in the implicit space are also learned, thus allowing flexibility, as the network develops a discontinuous topography when presented with different input classes.
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O'Sullivan, Janet. "LOST ON PENALTIES." Cambridge Law Journal 73, no. 3 (November 2014): 480–83. http://dx.doi.org/10.1017/s0008197314000920.
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FREEDOM of contract is a fundamental principle of English law, but it is of course qualified by numerous protective regimes, some common law, most statutory nowadays, which protect vulnerable parties from untrammelled, unequal free bargaining. It is, quite rightly, exceptional for an experienced commercial party, negotiating at arm's length and with the benefit of specialist professional advice, to succeed in invoking such a regime to escape being bound by what he freely agreed. Yet, in Cavendish Square Holdings BV v Makdessi [2013] EWCA Civ 1539, this was precisely the controversial result.
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Li, Jinyan, Nathan Jin Bao, and Huaning Christina Li. "Value Creation: A Constant Principle in a Changing World of International Taxation." Canadian Tax Journal/Revue fiscale canadienne 67, no. 4 (December 27, 2019): 1107–34. http://dx.doi.org/10.32721/ctj.2019.67.4.sym.li.
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The authors consider the new nomenclature of value creation in terms of its meaning, theoretical basis, and importance in the context of the international taxation of business profits. The authors' central claim is that the principle of value creation is a profound elaboration of the doctrine of economic allegiance, which is the theoretical basis for the current international tax system; and that international tax norms, such as the arm's-length principle, are meant to give effect to the doctrine of economic allegiance (and now to the principle of value creation). As demonstrated by the Organisation for Economic Co-operation and Development/Group of Twenty base erosion and profit shifting project, there is apparently global consensus that the value-creation principle should guide the development of new rules—not only the rules to protect countries' existing tax bases (for example, anti-avoidance rules) but also the rules to allocate new taxation rights in respect of income derived in a digital and intangible economy. The authors evaluate the most recent tax-reform proposals in the light of the value-creation principle, and they recommend a global profit-split rule as a way of accurately reflecting value creation.
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Hukamawati, Dinartika, and Arifah Fibri Andriani. "ANALISIS PENERAPAN ARM’S LENGTH PRINCIPLE PADA TRANSAKSI PEMBAYARAN ROYALTI ATAS PEMANFAATAN MEREK DAGANG (TRADEMARK) KEPADA PERUSAHAAN AFILIASI." INFO ARTHA 4 (May 24, 2017): 1–18. http://dx.doi.org/10.31092/jia.v4i4.34.
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Trademark is a unique marketing intangible. It does not only involve the expenses of marketing, advertising, and promoting, but the reputation of the trademark's owners also takes part in the development of trademark. Many parties involve in the development of trademark. In the context of transfer pricing, these parties entitle to some compensation. And arm's length principle must be applied to determine the reasonable compensation for the use of trademark. Transaction payment of royalties on trademarks is subject to taxes.The taxation of transactions payment of royalties on the use of the trademark among affiliated companies also created disputes between the taxpayer and Tax collector. Cases disputed are related to the fairness of the transaction relating to the determination of royalty payments on trademarks which cover: definition, identification, allocation and valuation between affiliated companies (Caroline Silberztein, 2010). The dispute raises the burden of the cost of compliance for taxpayers and cost of collection to the tax authorities.This study aims to determine how to identify ownership and economic benefits, as well as the best method which can be applied to determine the reasonable price of royalty payment transaction for the trademark use.The results shows that in order to determine the parties entitled to compensation/ remuneration are: Party who can be legally declared to have legal ownership (legal owner) which are parties that have control over decisions related to the exploitation of the intangible as well as the right to restrict others to use intangible; Parties that contribute to the value of the trademark by identifying the parties who bear the cost and risk of the development of the trademark.
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Sulik-Górecka, Aleksandra. "Dilemmas of Transfer Pricing Comparability Analysis in Manufacturing Entities. Polish-Czech Case Study." Management Systems in Production Engineering 26, no. 2 (June 1, 2018): 76–82. http://dx.doi.org/10.2478/mspe-2018-0012.
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Abstract Modern manufacturing entities often operate in capital groups, and their role is sometimes limited to the function of cost centers. From the legal point of view, however, they are separate entities obliged to apply transfer pricing regulations. Meeting the requirements of the arm's length principle can be very difficult at this time, given the relationships and conflicts of interest in the capital group. Complexity increases in capital groups operating in different countries, due to differences in tax regulations. The main purpose of the paper is to demonstrate that the need to valuate the sale of finished goods to a manufacturing entity, which is a subject to a different tax jurisdiction, may lead to a problem of compliance with the arm's length principle. In addition, the paper proposes a methodology for comparability analysis that may be used by manufacturing entities to defend conditions of setting transfer pricing. The paper presents the different functional profiles of manufacturing entities and points out the difficulties that they may encounter when preparing the comparability analysis. It has also been noted that there are differences in transfer pricing regulations in different countries, for example by analyzing Polish and Czech regulations. The lack of uniform benchmarking legislation can cause inconsistencies in the selection of comparable data, resulting in differences in transfer pricing. The paper uses the method of legal regulation review and analysis of results of published studies concerning the scope of transfer pricing and comparability analysis. The paper also adopts a case study analysis.
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Khorasani, Manouchehr Moshtagh. "El arma sagrada: el combate con arco y flecha en Irán." Revista de Artes Marciales Asiáticas 5, no. 1 (July 13, 2012): 53. http://dx.doi.org/10.18002/rama.v5i1.124.
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<p class="AMresumen">The following article presents the development of the bow and arrow, and its important role in the history of Iran. The bow always played an important role not only on the battlefield, but also in hunting. It was also considered as a sacred weapon and additionally a royal symbol. Bow and arrow were considered as a superior weapon in comparison with other types of weapons because one could fight with them at a safer distance as one offered by swords, maces and axes. The first part of the article presents a short history of the bow in Iran. Based on historical Persian manuscripts, the next part explains the structure of the composite bow and the materials used for making it. The third part describes some types of bows based on the material, place of production, the usage, and bow type based on the length of the bow and the arrows. The following part talks about different types of arrows based on morphology of arrowheads, the type of plume/feather, the material of the shaft, the material of the arrowhead, the length of arrows, the target of arrows, the place of production of arrowheads and terms for describing its different features of an arrowhead. Then, the article talks about different types of thumb rings, bowstrings, quivers and bow cases and arrow guides for shooting short arrows. The next part discusses different principles of archery as explained in Persian manuscripts. Finally the article describes different archery targets.</p>
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Squires, Steven, Adam Prügel-Bennett, and Mahesan Niranjan. "Rank Selection in Nonnegative Matrix Factorization using Minimum Description Length." Neural Computation 29, no. 8 (August 2017): 2164–76. http://dx.doi.org/10.1162/neco_a_00980.
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Nonnegative matrix factorization (NMF) is primarily a linear dimensionality reduction technique that factorizes a nonnegative data matrix into two smaller nonnegative matrices: one that represents the basis of the new subspace and the second that holds the coefficients of all the data points in that new space. In principle, the nonnegativity constraint forces the representation to be sparse and parts based. Instead of extracting holistic features from the data, real parts are extracted that should be significantly easier to interpret and analyze. The size of the new subspace selects how many features will be extracted from the data. An effective choice should minimize the noise while extracting the key features. We propose a mechanism for selecting the subspace size by using a minimum description length technique. We demonstrate that our technique provides plausible estimates for real data as well as accurately predicting the known size of synthetic data. We provide an implementation of our code in a Matlab format.
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Lehtokangas, Mikko, Jukka Saarinen, Pentti Huuhtanen, and Kimmo Kaski. "Predictive Minimum Description Length Criterion for Time Series Modeling with Neural Networks." Neural Computation 8, no. 3 (April 1996): 583–93. http://dx.doi.org/10.1162/neco.1996.8.3.583.
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Nonlinear time series modeling with a multilayer perceptron network is presented. An important aspect of this modeling is the model selection, i.e., the problem of determining the size as well as the complexity of the model. To overcome this problem we apply the predictive minimum description length (PMDL) principle as a minimization criterion. In the neural network scheme it means minimizing the number of input and hidden units. Three time series modeling experiments are used to examine the usefulness of the PMDL model selection scheme. A comparison with the widely used cross-validation technique is also presented. In our experiments the PMDL scheme and the cross-validation scheme yield similar results in terms of model complexity. However, the PMDL method was found to be two times faster to compute. This is significant improvement since model selection in general is very time consuming.
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Ravn-Højgaard, Signe. "Media policy in Greenland." Nordicom Review 42, s2 (March 1, 2021): 36–52. http://dx.doi.org/10.2478/nor-2021-0016.
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Abstract This article describes the historical development of media policy in Greenland, and the shifts in the underlying normative and causal ideas that legitimise media policy. I argue that media policy reflects changes in Greenland's political system. Specifically, under colonial rule, Greenlandic media was state run and media was seen as an instrument to educate the population. Gradually, with the introduction of home rule, a paradigm shift took place, whereby media was seen as a vital instrument to strengthen Greenlandic language and identity. At the same time, normative ideas of media independence appeared which called for institutionalisation of the arm's length principle. Due to the influence and institutional spill-over from Denmark, I argue, Greenlandic media policy fit rather well into the “Nordic media model” although media policy in Greenland is mostly formulated without long-term or broad political agreements.
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Seex, Kevin A. "An anterior cervical retractor utilizing a novel principle." Journal of Neurosurgery: Spine 12, no. 5 (May 2010): 547–51. http://dx.doi.org/10.3171/2009.9.spine0955.
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The alarmingly high soft-tissue complication rates after anterior cervical surgery suggests that the design of current retractors is inadequate. A review of retractor design and consideration of new designs is worthwhile. The author reviewed the literature and the 7 described devices (Cloward, Caspar, Thompson-Farley, Tresserras, Ozer, Takayasu, and Oh devices). With the exception of Cloward/Caspar and Thomson-Farley systems, the author's search of the literature failed to disclose any independent review or investigations of the other retractors, suggesting that the use of these devices is limited. The Cloward/Caspar-style retractors depend for stability on small teeth at the ends of the blades that impale and stretch the longus colli muscle. For stability this self-retaining design requires equal tissue counterpressure. These devices are thus ill suited for a wound with substantially greater pressure from the medial structures and are prone to migration. The Thomson-Farley type of systems use arms with mechanical joints fixed to a table-mounted frame. The releasable joints allow adjustability and independent relaxation. Their limitations include bulk causing obstruction to the surgeons and radiographs, increased setup time, and ease with which excessive force can be applied. The author describes a new anterior cervical retractor that is based on a novel principle. The principle is that bone fixation can be used to provide the retractor blade an axis of rotation inside the wound. This gives improved retractor blade stability with the mechanical advantage of a lever. The stable rotation produced allows adjustable retraction and tissue relaxation without compromise in stability. To the author's knowledge, there are no previously described retractors with this ability. The system consists of a small 2-piece sliding frame fixed to the spine with the distraction screws. Bone fixation is preferable to sharp teeth and longus colli dissection because it works better and heals without scarring. Surgery is carried out through the frame, which slides during distraction. Independent retractor blades are attached to the sides of the frame, which provides a stable craniocaudal axis inside the wound. The blades rotate to provide retraction or relaxation as required. Intermittent relaxation of tissues under retractors has been shown to be beneficial. Another advantage, compared with systems that maintain wounds with vertical sides, is the ease with which an oblique approach can be used. The mechanical advantage has 3 benefits. First, bulky external mechanisms for retraction are avoided, which improves access. Second, numerous blade lengths are unnecessary, reducing inventory. Third, radiolucent polymers can be used with “snap-fit” properties. The improved stability over conventional systems reduces the need for skilled assistance and avoids surgeon frustration after retraction migration. Over a 3-year period, 100 anterior cervical operations have been performed. Anecdotally, operations are quicker mainly because the retractors do not slip. Prospective clinical studies with independent evaluation are underway.
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Will, B., and M. Gerding. "Determination of the permittivity of soils by use of double transmission measurements." Advances in Radio Science 7 (May 18, 2009): 1–4. http://dx.doi.org/10.5194/ars-7-1-2009.
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Abstract. Delay time measurements, e.g. time domain reflectometry (TDR), are a well-established method for the measurement of permittivity of various materials, especially soils. However, common measurement systems only provide one average value of the dielectric constant along the length of the TDR probe. This contribution deals with an advanced application of the TDR principle, the so-called double transmission method, for the determination of the water content of soil along a probe. To apply the advanced TDR technique, a probe, realized by a combination of a transmission line and a dielectric obstacle, which can mechanically be moved along the probe, is used. The probe is inserted into the soil to measure the effective soil permittivity. Thus, the water content along the probe can be estimated by means of the effective permittivity. Based on the known mechanical position of the reflection at the end of the probe and the position of the obstacle, the measured delay time can be used as a measure for the effective dielectric constant of the environment surrounding the obstacle. Thus, it is possible to determine the effective dielectric constant with a spatial resolution given by the step size of the obstacle displacement.
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Brem, Markus, and Thomas Tucha. "Transfer Pricing: Conceptual Thoughts on the Nature of the Multinational Firm." Vikalpa: The Journal for Decision Makers 31, no. 2 (April 2006): 29–44. http://dx.doi.org/10.1177/0256090920060202.
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This paper deploys Transaction Cost Economics (TCE) to elaborate on the shortcomings of ‘mainstream‘ transfer pricing in multinational firms. Departing from the notion that multinationals increasingly (re-)organize their business along multinational value chains irrespective of jurisdictional borders, this paper discusses the nature of the multinational firm and the problem of choosing the right intra-group (transfer) price. The mainstream transfer pricing approach derived from the Arm�s Length Principle (ALP) is deemed inappropriate for globally operating multinational enterprises (MNEs). Referring to the value chain model, the paper suggests that ‘entrepreneurial coordination’ is the key performance feature to be used for valuing business activity and for allocating — for tax transfer pricing purposes — standard mark-ups and residual profits along the value chain. The main findings of this paper are: Neo-classical concepts on marginal pricing may not suffice to establish arm's lengh transfer pricing; the inadequacy between tax-world transfer pricing (getting income allocation right) and business-world transfer pricing (getting management incentives right) might find its explanation in such concepts. MNEs need to be understood as large organizations different from domestic large organizations by the fact that they operate in different jurisdictions and/or institutional environments. Operative business is coordinated along business lines in which value chain processes can e identified. De facto, business-world transfer pricing takes place along such value chains in which tangible and intangible assets are transferred and hence require appropriate pricing from both the tax-world and the business-world perspective. TCE is a worthy candidate for illustrating governance structures and transactional attributes of business between related parties of a multinational group; such features support arguments to establish arm's length transfer pricing. Regularly, a clear cut-off of functional allocation into tax jurisdictions is difficult to achieve because of the high degree of integration into the value chains of the multinational. TCE appears to better distinguish between so-called �routine� and ‘non-routine’ functions. Transactions of the MNE are rarely of an ‘either-or’ feature (either ‘market’ or ‘hierarchy’). Depending upon transactional attributes, the price of such transaction can be assessed by variables describing the institutional and economic context, the transaction-specific contract, the stage of the business process involved, the strategy chosen, and the function pattern (function, risk, assets) Comparable information is rarely found in databases which provide company information. The more non-routine functions and intangibles are involved, the less is the tested function (or business unit) comparable with companies from external databases. Under these data constraints on comparables, the arm�s length tests on transfer pricing will have to resort to internal information if the ALP is intended to remain viable. A next-generation transfer pricing approach may have to make use of patterns of governance to characterize and to value the functional contributions to the overall value chain.
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Ayvaz, Ednan. "Outsourcing as a solution of problems of transfer price in multiple companies: A case studyÇokuluslu şirketlerde transfer fiyatlandırması sorunlarının çözümü olarak dış kaynak kullanımı (outsourcing): Bir vaka çalışması." Journal of Human Sciences 14, no. 4 (December 16, 2017): 4251. http://dx.doi.org/10.14687/jhs.v14i4.4963.
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The scope and complexity of international tax regulations on transfer pricing is largely focused on adhering to taxation rather than market competition. Outsourcing has been extensively described in order to comprehend it better for comparability functions and analysis, transfer pricing methods accepted by the OECD and the arm's length principle to identify similar transactions between independent parties. The aim of this study is to demonstrate the necessity of minimizing of the conflict between the tax auditors and multinational corporations and of the inefficiencies of tax rules and the arbitration mechanisms in transfer pricing. As a result of the work, it was explained in the case study that enterprises exposed to tax and tax penalties in large quantities because the tax authorities independently considered the comparable function analysis of the OECD guideline as outsourcing in determining the cost of the proposal in the framework of transfer pricing.Extended English abstract is in the end of Full Text PDF (TURKISH) file. ÖzetTransfer fiyatlandırması konusunda uluslararası vergi düzenlemelerinin kapsamı ve karmaşıklığı genel olarak piyasa rekabetinden ziyade vergiye riayet etmeye odaklıdır. Bu durum, uluslararası transfer fiyatlandırmasının yanı sıra muhasebe bağlamında transfer fiyatlandırmasının tartışılması gereğini ortaya çıkarmaktadır. Bağımsız taraflar arasındaki benzer işlemleri belirlemek için emsallerine uygunluk ilkesi (the arm’s length principle), OECD tarafından kabul edilen transfer fiyatlandırma yöntemleri ve karşılaştırılabilirlik fonksiyonları ve analizinin daha iyi anlaşılabilmesi için dış kaynak kullanımı (outsourcing) geniş şekilde açıklanmıştır. Bu çalışmanın amacı transfer fiyatlandırmasında çokuluslu şirketlerle vergi denetçilerinin arasındaki çatışmayı ve vergi kurallarında ve tahkim mekanizmalarındaki verimsizlikleri en aza indirme gerekliliğini ortaya koymaktır. Çalışmanın sonucunda, transfer fiyatlandırması çerçevesinde emsale uygun bedelin tespitinde vergi idaresinin, OECD rehberindeki karşılaştırılabilir fonksiyon analizini dış kaynak kullanımı olgusundan bağımsız olarak ele alması nedeniyle işletmenin yüklü miktarda vergi ve vergi ziyaı cezasına maruz kalması vaka çalışması çerçevesinde açıklanmıştır.
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Hardiyanto, Ivan. "PERMASALAHAN TRANSFER PRICING DALAM UNDANG-UNDANG PAJAK DI INDONESIA." Jurnal Magister Hukum ARGUMENTUM 6, no. 1 (May 6, 2019): 1082–103. http://dx.doi.org/10.24123/argu.v6i1.1859.
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Transfer pricing is a company policy in determining transfer prices to other companies, but in practice transfer pricing is done in order to avoid taxes. At present Indonesia has not been able to overcome the issue of transfer pricing because the regulations and sanctions are still unclear. Businessmen as taxpayers need legal certainty in the context of tax planning and business competition, while the government also requires legal certainty to secure revenues from the tax sector. The legal vacuum created legal uncertainty for both parties so that it was not in harmony with the principle of justice. Regulation regarding transfer pricing in Indonesia has actually been regulated in legislation found in Article 18 paragraph (3), (3a), and (4) Income Tax Law. However, the regulation has not been clearly regulating transfer pricing. The unclear regulation regarding transfer pricing lead Indonesian Government to refine the Anti-Avoidance Rule (AAR) which is integrated in the Income Tax Law. The AAR must provide clear definitions and differences regarding acceptable tax avoidance, unacceptable tax avoidance, and tax evasion, so that transfer pricing that breaks arm's length principle will be categorized as illegal. In addition, the AAR must be clearly and explicitly regulated regarding sanctions for transfer pricing doer. Improvement of AAR which is integrated in the Income Tax Law will provides legal certainty and guarantees justice for both businessmen as taxpayers and the government.
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Gubaidullin, Renat R., Aleksandr P. Kuzin, and Vladimir V. Kulakov. "Surfactant therapy in combination treatment of COVID-19 related acute respiratory distress syndrome." Remedium. Journal about the Russian market of medicines and medical equipment, no. 1 (2021): 50–56. http://dx.doi.org/10.21518/1561-5936-2021-1-50-56.
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ntroduction. The COVID-19 pandemic caused an outbreak of viral lung infections with severe acute respiratory syndrome complicated with acute respiratory failure. Despite the fact that the pandemic has a lengthened run, none of the therapeutic approaches have proved to be sufficiently effective according to the evidence-based criteria. We consider the use of surfactant therapy in patients with severe viral pneumonia and acute respiratory distress syndrome (ARDS) as one of the possible methods for treating COVID-19 related pneumonia. Objective. To prove the clinical efficacy and safety of orally inhaled Surfactant-BL, an authorized drug, in the combination therapy of COVID-19 related ARDS. Materials and methods. A total of 38 patients with COVID-19 related severe pneumonia and ARDS were enrolled in the study. Of these, 20 patients received the standard therapy in accordance with the temporary guidelines for the prevention, diagnosis and treatment of the novel coronavirus infection (COVID-19) of the Ministry of Health of the Russian Federation, version 9. And 18 patients received the surfactant therapy in addition to the standard therapy. Surfactant-BL was used in accordance with the instructions on how to administer the drug for the indication – prevention of the development of acute respiratory distress syndrome. A step-by-step approach to the build-up of the respiratory therapy aggressiveness was used to manage hypoxia. We used oxygen inhalation via a face mask with an oxygen inflow of 5–15 l/min, highflow oxygen therapy via nasal cannulas using Airvo 2 devices, non-invasive lung ventilation, invasive lung ventilation in accordance with the principles of protective mechanical ventilation. Results and discussion. Significant differences in the frequency of transfers to mechanical ventilation, mortality, Intensive Care Unit (ICU) and hospitalization length of stay (p <0.05) were found between the groups. Patients receiving surfactant therapy who required a transfer to mechanical ventilation accounted for 22% of cases, and the mortality rate was 16%. In the group of patients receiving standard therapy without surfactant inhalation 45% were transferred to mechanical ventilation, and 35% died. For patients receiving surfactant therapy, the hospital stay was reduced by 20% on average, and ICU stay by 30%. Conclusion. The inclusion of surfactant therapy in the treatment of COVID-19 related severe pneumonia and ARDS can reduce the progression of respiratory failure, avoid the use of mechanical ventilation, shorten the ICU and hospitalization length of stay, and improve the survival rate of this patient cohort.
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Dumiter, Florin Cornel, and Ștefania Amalia Jimon. "Theoretical and Practical Assessments of Transfer Prices. Legal Evidence from Romanian Case Law." Journal of Legal Studies 26, no. 40 (December 1, 2020): 1–18. http://dx.doi.org/10.2478/jles-2020-0008.
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AbstractTransfer pricing represents the mainstream agenda in the light of tax law, lato sensu, and international taxation, stricto sensu. At the international level, there can be an emphasis on several problems related to taxation: double taxation, double non – taxation, permanent establishment, business profits, residence criteria, arm's length principle, mutual agreement procedure, dispute resolution of tax conflicts. However, the problem of transfer pricing has more profound judicial and economic implications. The main objective of this paper is to evaluate and assess the underlying features and characteristics of transfer prices in the economical and judicial actual context. The operational objectives are related to a quid pro quo analysis regarding the fine-tuning aspects of transfer pricing in the digital taxation era. The case law presented in this article tackles the main problems of applying transfer pricing international regulation upon Romanian tax jurisprudence. The conclusion of this article highlights the need, mutadis mutandis, for a tax policy agenda revealing a strengthened fiscal and financial environment towards the creation of a new proper fiscal space.
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Kennel, Matthew B., Jonathon Shlens, Henry D. I. Abarbanel, and E. J. Chichilnisky. "Estimating Entropy Rates with Bayesian Confidence Intervals." Neural Computation 17, no. 7 (July 1, 2005): 1531–76. http://dx.doi.org/10.1162/0899766053723050.
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The entropy rate quantifies the amount of uncertainty or disorder produced by any dynamical system. In a spiking neuron, this uncertainty translates into the amount of information potentially encoded and thus the subject of intense theoretical and experimental investigation. Estimating this quantity in observed, experimental data is difficult and requires a judicious selection of probabilistic models, balancing between two opposing biases. We use a model weighting principle originally developed for lossless data compression, following the minimum description length principle. This weighting yields a direct estimator of the entropy rate, which, compared to existing methods, exhibits significantly less bias and converges faster in simulation. With Monte Carlo techinques, we estimate a Bayesian confidence interval for the entropy rate. In related work, weap-ply these ideas to estimate the information rates between sensory stimuli and neural responses in experimental data (Shlens, Kennel, Abarbanel, & Chichilnisky, in preparation).
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Kobetsky, Michael. "The Transfer-Pricing Profit-Split Method After BEPS: Back to the Future." Canadian Tax Journal/Revue fiscale canadienne 67, no. 4 (December 27, 2019): 1077–105. http://dx.doi.org/10.32721/ctj.2019.67.4.sym.kobetsky.
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In 2018, the Organisation for Economic Co-operation and Development/Group of Twenty (OECD/G20) Inclusive Framework on base erosion and profit shifting (BEPS): action 10 issued revised guidance on the transactional profit-split method. Regrettably, the revised guidance failed to provide the opportunity for the profit-split method to be more often the most appropriate transfer-pricing method. The revised guidance expressly states that the lack of comparable uncontrolled transactions, by itself, is not a basis for the use of the profit-split method. Under the former guidance, the profit-split method was used infrequently. In the revised guidance, the threshold requirements for the use of the profit-split method are still restrictive. Consequently, it is likely that the profit-split method will rarely be the most appropriate transfer-pricing method. Nevertheless, the residual profit-split method is being considered for BEPS action 1, on the taxation of the digital economy. Two of the proposals under pillar 1 of the Inclusive Framework's 2019 short policy note involve the use of the residual profit-split method to allocate profits. These proposals involve new profit allocation rules that go beyond the arm's-length principle.
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Peluso, Heather, John D. Cull, and Marwan S. Abougergi. "Race Impacts Outcomes of Patients With Firearm Injuries." American Surgeon 86, no. 9 (August 22, 2020): 1113–18. http://dx.doi.org/10.1177/0003134820943558.
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Background To study the relationship between race and outcomes of patients with firearm injuries hospitalized in the United States. Methods The 2016 National Inpatient Sample was used. Patients were included if they had a principal diagnosis of firearm injury. Exclusion criteria were age <16 years and elective admissions. The primary outcome was in-hospital mortality. Secondary outcomes were morbidity (traumatic shock, prolonged mechanical ventilation, acute respiratory distress syndrome [ADRS], and ventilator-associated pneumonia [VAP]), and resource utilization (length of stay and total hospitalization charges and costs). Results The sample included 31 335 patients; 52% were Black and 29% were Caucasian. The mean age was 32 years and 88% were male. Black patients had lower odds of mortality (adjusted odds ratio (aOR): 0.41 (95% CI: 0.32-0.53), P < .01). However, compared with Caucasians, Blacks had higher mean total hospitalization charges (adjusted mean difference (aMD) : $14 052 (CI: $1469-$26 635), P = .03) and costs (aMD: $3248 (CI: $654-$5842), P = .01) despite similar mean length of stay (aMD: 0.70 (CI: −0.05-1.45), P = .07). Both racial groups had similar rates of traumatic shock (aOR: 0.91 (0.72-1.15), P = .44), prolonged mechanical ventilation (aOR: 0.82 (0.63-1.09), P = .17), ARDS (aOR: 1.18 (0.45-3.07), P = .74) and VAP (aOR: 1.27 (0.47-3.41), P = .63). Discussion Black patients with firearm injuries had a lower adjusted odds of in-hospital mortality compared with other races. However, despite having a similar hospital length of stay and in-hospital morbidity, -Black patients had higher total hospitalization costs and charges.
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Connolly, Luke. "Beckett's Broken Circle: A Literary Fractal." Journal of Beckett Studies 29, no. 2 (September 2020): 196–215. http://dx.doi.org/10.3366/jobs.2020.0311.
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This essay proposes that the picture of a broken circle encountered by Watt during the second part of his tale marks a crucial collision point between Beckett's literary and mathematical interests and triggers a process of fractal scaling self-similarity. Building on recent interest concerning the role of the mathematics and mathematical forms found in Beckett's work, I argue that the broken circle depicted in the picture from Watt is a geometric form which (re)appears within at least three interlocking scales throughout Beckett's novel-length prose: (i) its moment of arrival in the picture from Watt, (ii) a macroscopic reinscription in the names of the protagonists populating the five novels spanning Watt through to The Unnamable and (iii) buried within the narratological depths of How It Is. As a structural principle, the interminable irregularity of fractals offered Beckett a viable solution for what he considered the defining task of the modern artist: ‘to find a form to accommodate the mess’. Moreover, the specific shape selected for his fractal is shown to contain within its geometry one of Beckett's most universal and pressing concerns: the inevitable insufficiency of language. Therefore, although this essay restricts itself to examining Beckett's novel-length prose, the idea of a broken circle fractal promises to provide a valuable heuristic through which to reassess the author's other generic avenues. Fractals thus offer a means through which one can bind together the length and breadth of Beckett's oeuvre without ever reducing dynamic chaos to stable order.