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Attribution of Profits to Permanent Establishments
Attribution of Profits to Permanent Establishments: Issues and Developments The profit attribution to permanent establishments is one of the most controversial topics in international tax law. In recent years it was subject to various changes based on the introduction of the “Authorized OECD Approach” in 2008 and 2010, the outcomes of Final Report on OECD BEPS Action 7 and the Final Report on “Additional Guidance on the Attribution of Profits to a Permanent Establishment under BEPS Action 7” from 2018 (with the previous Discussion-Drafts). This publication discusses the most important issues and recent developments related to the attribution of profits to permanent establishments. St...
Life in the Megalopolis
The modern metropolis has been called 'the symbol of our times', and life in it epitomizes, for many, modernity itself. But what to make of inherited ideas of modernity when faced with life in Mexico City and São Paulo, two of the largest metropolises in the world? Is their fractured reality, their brutal social contrasts, and the ever-escalating violence faced by their citizens just an intensification of what Engels described in the first in-depth analysis of an industrial metropolis, nineteenth century Manchester? Or have post-industrial and neo-globalized economies given rise to new forms of urban existence in the so-called developing world? Life in the Megalopolis: Mexico City and São ...
South American Cinema
Originally issued in hardcover in 1996 by Garland Publishing, this important reference work is now available in paperback for a wider audience. A distinguished team of contributors has compiled entries on 140 significant South American feature films from the silent era until 1994. The entries discuss each film's subject matter, critical reception, and social and political contexts, as well as its production, distribution, and exhibition history, including technical credits. The entries are grouped by country and arranged chronologically. Both fiction and documentary films (some no longer in existence) are included, as well as extensive title, name, and subject indexes and glossaries of film and foreign terms.
FLEEING PERSECUTION
In a world that still persecutes, marginalises and discriminates LGBTQI+ individuals, and where asylum seekers and refugees are denied rights and have their basic humanity violated, this publication intends to understand the asylum policies the German government develops specifically tailored to the needs of LGBTQI+ asylum seekers and refugees and whether the literature has addressed the implementation of such policies across the European continent. LGBTQI+ asylum is a rather new field of research. Among the European states, Germany has been more open to asylum than other states in the continent and has received the world's highest number of asylum seekers between 2010 and 2019, which justif...
Tpm
Revista Tpm. Entrevistas e reportagens sobre comportamento, moda, beleza, viagem e decoração para mulheres que querem ir além dos manuais, desafiando os padrões. Imagem não é tudo.
African Chronicle
A fortnightly record on governance, economy, development, human rights, and environment.
Eu Amo Inverno
I Love Winter - Portuguese Brazilian edition Winter is a fun and beautiful season to play in the snow, but Jimmy the little bunny was not prepared for the cold weather. Once he learns how to keep himself warm, he can finally enjoy spending time outside with his family.
Bons sonhos, meu amor!
Sweet Dreams, My Love - Portuguese Brazilian children's book It's time for bed, but Alice doesn't want to go to sleep just yet. By going through her bedtime routine, Mom calms her daughter down by reminding her of all the wonderful things they did together that evening. Written in a soft and soothing manner, this book shows the warm and loving relationship between Alice and her mom, while preparing young readers for a good night's sleep.
