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The Taxation of Permanent Establishments
This book provides a comprehensive analysis of the rules governing the taxation of permanent establishments as implemented in the OECD Model Tax Convention and German national tax law. Deviations between the OECD approach and the German approach are identified and modifications to the rules as a result of the Base Erosion and Profit Shifting (BEPS) project are examined. Moreover, challenges imposed to the PE concept as a result of the digitalisation of the economy are identified and discussed. Against this background, the Pillar One Blueprint proposing a long-term solution to overcome the tax challenges arising from the digitalisation of the economy is presented and assessed against widely accepted overarching principles of tax policy.
Life Sciences and Radiation
Scope and ideas of the workshop The workshop which took place at the University of Giessen from Oct. 3 to Oct. 7, 2002 and whose proceedings are collected in this volume started from the idea to convene a number of scientists with the aim to outline their ”visions” for the future of radiation research on the basis of their expertise. As radiation research is a very wide field restrictions were unavoidable. It was decided to concentrate this time mainly on molecular and cellular biology because it was felt that here action is par-ticularly needed. This did not exclude contributions from neighbouring fields as may be seen from the table of contents. It was clearly not planned to have a c- ...
Radiotherapy and Brachytherapy
This book reports the majority of lectures given during the NATO Advanced Study Institute ASI-982996, which was held at the European Scientific Institute of Archamps (ESI, Archamps – France) from November 15 to November 27, 2007. The ASI course was structured in two parts: the first was dedicated to what is often called “teletherapy”, i. e. radiotherapy with external beams, while the second focused on internal radiotherapy, also called “brachytherapy” or “curietherapy” in honour of Madame Curie who initiated the technique about a century ago. This ASI took place after the European School of Medical Physics, which devoted a 3 week period to medical imaging, a subject complementa...
Microdosimetric Response of Physical and Biological Systems to Low- and High-LET Radiations
One of the aims of this book was to focus the attention of specialists to the diversity of the effects of the ionising radiation on biological and physical systems. Special emphasis has been placed on the exquisite complexities/differences introduced by high ionisation density versus low ionisation density irradiation in both biological and physical systems (Scholz – Chapter 1, Horowitz – Chapter 2, Olko – Chapter 3). As well we wanted to point out the need for novel experimental and theoretical approaches required to advance the important fields of micro and nanodosimetry. Important first steps have already been taken, for example, the accelerated application of semiconductor detector...
Between Solidarity and Economic Constraints
Until the end of the Cold War in 1990, building projects and architectural icons played an important role in the self-portrayal of the competing systems. However, as the current research shows, we also find a large variety of forms of cooperation between the East, the South, and the West, not to forget the manifold cross-border entanglements within the South or the East. This book explores the intersection of two strands of research. On the one hand, interaction in the field of architecture and construction between actors from socialist countries and from countries of the Global South have increasingly won interest amongst historians of architecture and planning. On the other hand, in the context of the strongly emerging Cold War Studies, scholars have explored cooperation and circulation across the Iron Curtain with a focus on economic and research planning. This book connects perspectives of planning, construction and architectural design with those on economic interests and conflicts in projects and networks. Furthermore, it opens the view to the hubs of communication and exchange, and on patterns of longterm transformation and appropriation of architecture.
The Constitutional Framework for Enhanced Cooperation in EU Law
Enhanced Cooperation allows a group of Member States to use the EU’s competences and institutions to pursue a project within the Union’s framework that is binding only on the participating States while remaining an EU act. Introduced by the Amsterdam Treaty, this tool of flexible integration was not used until 2010. In The Constitutional Framework for Enhanced Cooperation in EU Law, Robert Böttner analyses the primary-law framework of this flexibility tool. On the basis of profound literature review and against the background of recent Member State practice, the author redefines the constitutional rules of Enhanced Cooperation. He draws conclusions on this tool’s legal limits, but also its potential for European integration.
National Action Plans in the Global Governance of Business and Human Rights
Diese Arbeit analysiert Nationale Aktionspläne für Wirtschaft und Menschenrechte als bedeutsamen Schritt in der Entwicklung unternehmerischer Menschenrechtsverantwortung. Angeleitet vom diskursiven Institutionalismus und gerahmt von einer Interpretation des Politikfeldes als Wettbewerb konkurrierender Ideen wird am Beispiel von Schweden und Deutschland detailliert der Einfluss staatlicher und nichtstaatlicher Akteure im Politikprozess beleuchtet und aufgezeigt, unter welchen Bedingungen unternehmerische Menschenrechtsverantwortung größere Verbindlichkeit gewinnt. Die Studie leistet theoretisch und empirisch einen innovativen Beitrag zur politikwissenschaftlichen Menschenrechtsforschung.
The Oxford Handbook of International Tax Law
International Tax Law is at a turning point. Increased tax transparency, the tackling of Base Erosion and Profit Shifting (BEPS), the reconstruction of the network of bilateral tax treaties, the renewed discussion about a fair and efficient allocation of taxing rights between States in a global, digitalized economy, and the bold push for minimum corporate taxation are some expressions of this shift. This new era also demonstrates the increased influence of international standard setters such as the OECD, the UN, and the EU. Each of these developments alone has the potential of being disruptive to the traditional world of international tax law, but together they have the potential to reshape ...
Cancer
Introducing the first volume of a new series, Cancer: Principles & Practice of Oncology—Annual Advances in Oncology. This series of annual volumes will focus on the most significant changes in oncologic research and practice that have taken place during the preceding year. Each volume identifies scientific and clinical areas in oncology that are rapidly changing and show a high potential for affecting the management of cancer patients in the future. These areas may reflect current controversies in oncology and every effort is made to provide clear direction for the practicing oncologist.
Towards Consistency in International Investment Jurisprudence
Investor-State arbitration is currently a much-debated topic, both within the legal community and in the public at large. In Towards Consistency in International Investment Jurisprudence, Katharina Diel-Gligor addresses the alleged proliferation of inconsistent decision-making in this field – one of the main points of concern raised in the ongoing discussions. After exploring whether such criticism is appropriate at all, she goes on to examine the different causes, forms, and manifestations of the inconsistencies that exist through a detailed analysis of ICSID arbitration. The author then canvasses possible approaches to reform and concludes that an ICSID preliminary ruling system – the practicalities of which are set out in the study – is a suitable means for enhancing consistency in investment arbitration and moving towards a jurisprudence constante.
