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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.
Advanced Microsystems for Automotive Applications 2004
Microsystems applications (MST) in automobiles have become commonplace: they enable the introduction of a series of new functions and at the same time the replacement of existing technologies offering improved performance and better value for money. Microsystems are indispensable for fulfilling a complete transition from the mechanically driven automobile system to a mechanically based but ICT-driven system as part of a likewise complex environment. With the introduction of micro-systems a series of challenges arise regarding complexity, systems design, reliability, serviceability, etc. These challenges have to be addressed in order to meet high customer expectations concerning performance and price.
The Courage of Composers and the Tyranny of Taste
Bálint András Varga is perhaps the world's most respected interviewer of living composers. For The Courage of Composers and the Tyranny of Taste: Reflections on New Music, Varga has confronted thirty-three composers with quotations carefully chosen to elicit their thoughts about an issue that is crucial for any serious creative artist: How can one find courage to deal with the sometimes tyrannical expectations of the outside world? The result is an imaginary roundtable at which we encounter fresh, revealing, previously unpublished statements from such world-renowned composers as John Adams, Friedrich Cerha, George Crumb, Sofia Gubaïdulina, Georg Friedrich Haas, Giya Kancheli, György Kurt...
Formulary Apportionment for the Internal Market
Since its Company Tax Communication of 2001, the European Commission has been promoting a comprehensive harmonization of corporation taxes within the Internal Market on the basis of consolidation and formulary apportionment of the profits of cross-border enterprises, both in the form of a Home State Taxation (HST) and of the Common Consolidated Corporate Tax Base. This study assesses whether this approach represents a viable alternative to the arm's length standard currently applied in international tax law. The study comprises four parts. First, a theoretical concept of formulary apportionment is presented, followed by an evaluation of the practical experiences of four jurisdictions (United States, Canada, Switzerland and Germany) with formulary apportionment at the subnational level. Next, a proposal for harmonization on the basis of consolidation and apportionment is developed, and the book concludes with an overall analysis of the merits and drawbacks of the proposed model for harmonization.
Climate Wars
Struggles over drinking water, new outbreaks of mass violence, ethnic cleansing, civil wars in the earth's poorest countries, endless flows of refugees: these are the new conflicts and forces shaping the world of the 21st century. They no longer hinge on ideological rivalries between great powers but rather on issues of class, religion and resources. The genocides of the last century have taught us how quickly social problems can spill over into radical and deadly solutions. Rich countries are already developing strategies to garner resources and keep 'climate refugees' at bay. In this major book Harald Welzer shows how climate change and violence go hand in hand. Climate change has far-reac...
Organised Crime in Europe
Whilst the nature of organised crime may keep changing with the effects of globalisation, technological developments and European integration, its impact remains the same in terms of undermining democracy, human rights and the rule of law. The "Octopus Programme" is a technical co-operation programme against corruption and organised crime initiated by the Council of Europe in 1996. This publication reviews the organised crime situation in Europe in 2004, in order to help member states ensure that counter-measures are based on a thorough knowledge of trends and good practice. It includes a chapter on the challenge of cybercrime, with an analysis of the different forms of cybercrime, its links to organised crime and terrorism, and its socio-economic impacts.
