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The Taxation of Fees for Technical Services on the Basis of Article 12A UN Model Convention
Although rules on the allocation of taxing rights for fees for technical services have been provided for in bilateral tax treaties by African, Asian, and South American countries for decades, it was only in the 2017 update that the UN Model Tax Treaty included Article 12A on the matter, thus suggesting its inclusion in the tax treaty network of its Member States. Consequently, from a cross-border perspective, the interpretation of Article 12A is of great importance for both taxpayers and tax authorities. This book presents the first comprehensive analysis of the scope of technical services in comparison to ordinary (non-technical) services and the differentiation between Article 12A and othe...
O whistleblowing como instrumento de combate aos ilícitos e abusos tributários
As ferramentas de fiscalização atualmente à disposição do Estado, dada a evolução dos esquemas ilícitos e abusivos, cada vez mais elaborados e complexos, ao avanço tecnológico e à globalização, não têm conseguido combater de forma eficaz tais práticas, o que resulta em um rombo cada vez maior dos cofres e numa precarização dos serviços públicos com graves reflexos para a justiça tributária e a concorrência. Com base em tal cenário e na análise de práticas internacionais de reconhecido sucesso, o autor faz uma incursão no instituto do whistleblowing, expondo como a adoção desse instituto, ainda incipiente no Brasil, pode contribuir para que haja uma maior participação popular no combate aos crimes e abusos contra a ordem tributária. Esta obra, resultado de um grande empenho de pesquisa e observações práticas do Autor, não apenas preenche uma lacuna doutrinária, mas também oferece uma trilha para um sistema tributário mais justo e transparente, servindo como um guia essencial para juristas, acadêmicos e profissionais comprometidos com a defesa do patrimônio público e a construção de um sistema tributário eficaz e equitativo.
Handbook of Research on Collaborative Learning Using Concept Mapping
This new encyclopedia discusses the extraordinary importance of internet technologies, with a particular focus on the Web.
Studies on Variation in Portuguese
Studies on Variation in Portuguese offers a collection of studies on a range of variable phenomena attested within and across varieties of Portuguese. The volume starts out with an overview of current issues in the study of intralinguistic variation and is divided in two parts. Part 1 is dedicated to research on variation within national varieties (Brazilian and European). Here, a multidimensional analysis that combines both the geographic and the social dimensions of variation emerges as a way to identify possible regional specificities and the directionality of some of the variants. Part 2 collects studies that compare the behavior of a particular linguistic variable across different varieties. The variable phenomena discussed concern several levels of grammar and are framed within different conceptions of variation, thus promoting confrontation of theoretical and methodological alternatives. Overall, the volume constitutes a significant contribution to the essential question of how to model variation at different levels.
NOVO PANORAMA MUNDIAL
A organização do mundo atual, com os "novos atores sociais", se estabelece pelo poder. Portanto, uma nova configuração mundial começa a se desenrolar, situando nova forma de entendê-lo. Nesse sentido, os países começam a se organizar no século atual implicando nos diferentes fluxos no mundo e novas áreas do poder. Assim, estabelecendo uma nova forma de visualizar e compreender a sua organização e espaço.
Research Anthology on Business Continuity and Navigating Times of Crisis
When the COVID-19 pandemic caused a halt in global society, many business leaders found themselves unprepared for the unprecedented change that swept across industry. Whether the need to shift to remote work or the inability to safely conduct business during a global pandemic, many businesses struggled in the transition to the “new normal.” In the wake of the pandemic, these struggles have created opportunities to study how businesses navigate these times of crisis. The Research Anthology on Business Continuity and Navigating Times of Crisis discusses the strategies, cases, and research surrounding business continuity throughout crises such as pandemics. This book analyzes business operations and the state of the economy during times of crisis and the leadership involved in recovery. Covering topics such as crisis management, entrepreneurship, and business sustainability, this four-volume comprehensive major reference work is a valuable resource for managers, CEOs, business leaders, entrepreneurs, professors and students of higher education, researchers, and academicians.
Animal lives worth living
The main theme of this year’s congress is 'Animal lives worth living'. This theme focuses on our responsibility for all animals kept or influenced by humans, to ensure that we can provide a life for them that takes into account all relevant aspects of animal welfare, aided by applied ethology as the key scientific discipline. This not only means avoiding and alleviating suffering but also promoting resilience and positive experiences. By monitoring and interpreting animal behaviour, we gain important insights into each of these aspects of quality of life.
Computer Supported Qualitative Research
This book includes selecting the articles accepted for presentation and discussion at WCQR2021, held on January 20th to 22nd, 2021 (Virtual Conference). The World Conference on Qualitative Research (WCQR) is an annual event that aims to bring together researchers, academics and professionals, promoting the sharing and discussion of knowledge, new perspectives, experiences and innovations on Qualitative Research. WCQR2021 featured four main application fields (Education, Health, Social Sciences, and Engineering/Technology) and seven main subjects: Rationale and Paradigms of Qualitative Research; Systematization of Approaches with Qualitative Studies; Qualitative and Mixed Methods Research; Data Analysis Types; Innovative Processes of Qualitative Data Analysis; Qualitative Research in Web Context; Qualitative Analysis with Software Support. The book is a valuable resource for everyone interested in qualitative research, emphasizing Computer-Assisted Qualitative Data Analysis Software (CAQDAS).
Journal of the House of Representatives of the United States
Some vols. include supplemental journals of "such proceedings of the sessions, as, during the time they were depending, were ordered to be kept secret, and respecting which the injunction of secrecy was afterwards taken off by the order of the House."
Comparative Perspectives on the Rise of the Brazilian Novel
Comparative Perspectives on the Rise of the Brazilian Novel presents a framework of comparative literature based on a systemic and empirical approach to the study of the novel and applies that framework to the analysis of key nineteenth-century Brazilian novels. The works under examination were published during the period in which the forms and procedures of the novel were acclimatized as the genre established and consolidated itself in Brazil.
