Profit repatriation of a Polish subsidiary from tax planning point of view of an international corporation

The main purpose of this study was to examine and compare the possibilities of profit repatriation from the point of view of tax planning of an international corporation, in such a case that a Finnish parent company has a subsidiary in Poland. The main research problem was divided into two sub research problems: 1) to examine concepts and principles of international taxation and tax planning from the point of view of international corporations and 2) to discuss the main features of Polish Companies-, Accounting- and Tax Act from the point of view a Finnish parent company. The research method of this study is mainly decision making, comparative analysis. In this study have been discussed the possibilities of international profit repatriation for supporting the decision making of the management of a Finnish parent company. In addition different repatriation possibilities have been compared. In this study has been noticed that a Finnish parent company can repatriate profit of its Polish subsidiary either directly as dividends or by using indirect methods such as interests, royalties, management fees and transfer pricing of goods. The total tax burden of dividends is heavier than the tax burden of indirect methods. It was also concluded that during the last years the Polish legislation has been renewed in order to prevent hidden dividend distribution. This has been done by implementing new rules of transfer pricing and thin capitalization.

RNA enrichment method for quantitative transcriptional analysis of pathogens in vivo applied to the fungus Candida albicans.

UNLABELLED: In vivo transcriptional analyses of microbial pathogens are often hampered by low proportions of pathogen biomass in host organs, hindering the coverage of full pathogen transcriptome. We aimed to address the transcriptome profiles of Candida albicans, the most prevalent fungal pathogen in systemically infected immunocompromised patients, during systemic infection in different hosts. We developed a strategy for high-resolution quantitative analysis of the C. albicans transcriptome directly from early and late stages of systemic infection in two different host models, mouse and the insect Galleria mellonella. Our results show that transcriptome sequencing (RNA-seq) libraries were enriched for fungal transcripts up to 1,600-fold using biotinylated bait probes to capture C. albicans sequences. This enrichment biased the read counts of only ~3% of the genes, which can be identified and removed based on a priori criteria. This allowed an unprecedented resolution of C. albicans transcriptome in vivo, with detection of over 86% of its genes. The transcriptional response of the fungus was surprisingly similar during infection of the two hosts and at the two time points, although some host- and time point-specific genes could be identified. Genes that were highly induced during infection were involved, for instance, in stress response, adhesion, iron acquisition, and biofilm formation. Of the in vivo-regulated genes, 10% are still of unknown function, and their future study will be of great interest. The fungal RNA enrichment procedure used here will help a better characterization of the C. albicans response in infected hosts and may be applied to other microbial pathogens. IMPORTANCE: Understanding the mechanisms utilized by pathogens to infect and cause disease in their hosts is crucial for rational drug development. Transcriptomic studies may help investigations of these mechanisms by determining which genes are expressed specifically during infection. This task has been difficult so far, since the proportion of microbial biomass in infected tissues is often extremely low, thus limiting the depth of sequencing and comprehensive transcriptome analysis. Here, we adapted a technology to capture and enrich C. albicans RNA, which was next used for deep RNA sequencing directly from infected tissues from two different host organisms. The high-resolution transcriptome revealed a large number of genes that were so far unknown to participate in infection, which will likely constitute a focus of study in the future. More importantly, this method may be adapted to perform transcript profiling of any other microbes during host infection or colonization.

Rockfall detection from LIDAR point clouds: A clustering approach using R

The analysis of rockfall characteristics and spatial distribution is fundamental to understand and model the main factors that predispose to failure. In our study we analysed LiDAR point clouds aiming to: (1) detect and characterise single rockfalls; (2) investigate their spatial distribution. To this end, different cluster algorithms were applied: 1a) Nearest Neighbour Clutter Removal (NNCR) in combination with the Expectation?Maximization (EM) in order to separate feature points from clutter; 1b) a density based algorithm (DBSCAN) was applied to isolate the single clusters (i.e. the rockfall events); 2) finally we computed the Ripley's K-function to investigate the global spatial pattern of the extracted rockfalls. The method allowed proper identification and characterization of more than 600 rockfalls occurred on a cliff located in Puigcercos (Catalonia, Spain) during a time span of six months. The spatial distribution of these events proved that rockfall were clustered distributed at a welldefined distance-range. Computations were carried out using R free software for statistical computing and graphics. The understanding of the spatial distribution of precursory rockfalls may shed light on the forecasting of future failures.

A new alternative method for testing skin irritation using a fresh human skin model

La dermatite irritative est décrite comme une réaction réversible, non immunologique caractérisée par des lésions d'aspect très variable, allant de la simple rougeur jusqu'à la formation de bulles voire d'une nécrose, accompagnée de prurit ou d'une sensation de brûlure suite à I' application d'une substance chimique. Le teste de prédiction d'irritation cutanée est traditionnellement depuis les années 1940 le Test de Draize. Ce test consiste en l'application d'une substance chimique sur une peau rasée de lapin pendant 4h et de regarder à 24h si des signes cliniques d'irritations sont présents. Cette méthode critiquable autant d'un point de vue éthique que qualitative reste actuellement le teste le plus utilisé. Depuis le début des années 2000 de nouvelles méthodes in vitro se sont développées tel que le model d'épiderme humain recombiné (RHE). Il s agit d'une multicouche de kératinocyte bien différencié obtenu depuis une culture de don d'ovocyte. Cependant cette méthode en plus d'être très couteuse n'obtient au mieux que 76% de résultat similaire comparé au test in vivo humain. Il existe donc la nécessité de développer une nouvelle méthode in vitro qui simulerait encore mieux la réalité anatomique et physiologique retrouvée in vivo. Notre objectif a été de développer cette nouvelle méthode in vitro. Pour cela nous avons travaillé avec de la peau humaine directement prélevée après une abdominoplastie. Celle ci après préparation avec un dermatome, un couteau dont la lame est réglable pour découper l'épaisseur souhaitée de peau, est montée dans un système de diffusion cellulaire. La couche cornée est alors exposée de manière optimale à 1 ml de la substance chimique testée pendant 4h. L'échantillon de peau est alors fixé dans du formaldéhyde pour permettre la préparation de lames standards d'hématoxyline et éosine. L'irritation est alors investiguée selon des critères histopathologiques de spongioses, de nécroses et de vacuolisations cellulaires. Les résultats de ce.tte première batterie de testes sont plus que prometteurs. En effet, comparé au résultat in vivo, nous obtenons 100% de concordance pour les 4 même substances testes irritantes ou non irritantes, ce qui est supérieur au model d épiderme humain recombiné (76%). De plus le coefficient de variation entre les 3 différentes séries est inférieur à 0.1 ce qui montre une bonne reproductibilité dans un même laboratoire. Dans le futur cette méthode va devoir être testée avec un plus grand nombre de substances chimiques et sa reproductibilité évaluée dans différents laboratoires. Mais cette première evaluation, très encourageante, ouvre des pistes précieuses pour l'avenir des tests irritatifs.

3D Surface Modeling From Point Clouds

The goal of this thesis is to implement software for creating 3D models from point clouds. Point clouds are acquired with stereo cameras, monocular systems or laser scanners. The created 3D models are triangular models or NURBS (Non-Uniform Rational B-Splines) models. Triangular models are constructed from selected areas from the point clouds and resulted triangular models are translated into a set of quads. The quads are further translated into an estimated grid structure and used for NURBS surface approximation. Finally, we have a set of NURBS surfaces which represent the whole model. The problem wasn’t so easy to solve. The selected triangular surface reconstruction algorithm did not deal well with noise in point clouds. To handle this problem, a clustering method is introduced for simplificating the model and removing noise. As we had better results with the smaller point clouds produced by clustering, we used points in clusters to better estimate the grids for NURBS models. The overall results were good when the point cloud did not have much noise. The point clouds with small amount of error had good results as the triangular model was solid. NURBS surface reconstruction performed well on solid models.

Point sampling with uniformly distributed lines

In this paper we address the problem of extracting representative point samples from polygonal models. The goal of such a sampling algorithm is to find points that are evenly distributed. We propose star-discrepancy as a measure for sampling quality and propose new sampling methods based on global line distributions. We investigate several line generation algorithms including an efficient hardware-based sampling method. Our method contributes to the area of point-based graphics by extracting points that are more evenly distributed than by sampling with current algorithms

Splat-based surface reconstruction from defect-laden point sets

We introduce a method for surface reconstruction from point sets that is able to cope with noise and outliers. First, a splat-based representation is computed from the point set. A robust local 3D RANSAC-based procedure is used to filter the point set for outliers, then a local jet surface - a low-degree surface approximation - is fitted to the inliers. Second, we extract the reconstructed surface in the form of a surface triangle mesh through Delaunay refinement. The Delaunay refinement meshing approach requires computing intersections between line segment queries and the surface to be meshed. In the present case, intersection queries are solved from the set of splats through a 1D RANSAC procedure

Melodic Analysis of Speech Method applied to Spanish and Catalan

In this paper, we present the Melodic Analysis of Speech method (MAS) that enables us to carry out complete and objective descriptions of a language's intonation, from a phonetic (melodic) point of view as well as from a phonological point of view. It is based on the acoustic-perceptive method by Cantero (2002), which has already been used in research on prosody in different languages. In this case, we present the results of its application in Spanish and Catalan.

Application of cloud point preconcentration and flame atomic absorption spectrometry for the determination of cadmium and zinc ions in urine, blood serum and water samples

A simple, sensitive and selective cloud point extraction procedure is described for the preconcentration and atomic absorption spectrometric determination of Zn2+ and Cd2+ ions in water and biological samples, after complexation with 3,3',3",3'"-tetraindolyl (terephthaloyl) dimethane (TTDM) in basic medium, using Triton X-114 as nonionic surfactant. Detection limits of 3.0 and 2.0 µg L-1 and quantification limits 10.0 and 7.0 µg L-1were obtained for Zn2+ and Cd2+ ions, respectively. Relative standard deviation was 2.9 and 3.3, and enrichment factors 23.9 and 25.6, for Zn2+ and Cd2+ ions, respectively. The method enabled determination of low levels of Zn2+ and Cd2+ ions in urine, blood serum and water samples.

Determination of triamterene in human plasma and urine after its cloud point extraction

A new analytical approach was developed involving cloud point extraction (CPE) and spectrofluorimetric determination of triamterene (TM) in biological fluids. A urine or plasma sample was prepared and adjusted to pH 7, then TM was quickly extracted using CPE, using 0.05% (w/v) of Triton X-114 as the extractant. The main factors that affected the extraction efficiency (the pH of the sample, the Triton X-114 concentration, the addition of salt, the extraction time and temperature, and the centrifugation time and speed) were studied and optimized. The method gave calibration curves for TM with good linearities and correlation coefficients (r) higher than 0.99. The method showed good precision and accuracy, with intra- and inter-assay precisions of less than 8.50% at all concentrations. Standard addition recovery tests were carried out, and the recoveries ranged from 94.7% to 114%. The limits of detection and quantification were 3.90 and 11.7 µg L-1, respectively, for urine and 5.80 and 18.0 µg L-1, respectively, for plasma. The newly developed, environmentally friendly method was successfully used to extract and determine TM in human urine samples.

Ligandless cloud point extraction of trace amounts of palladium and rhodium in road dust samples using Span 80 prior to their determination by flame atomic absorption spectrometry

In this study, a procedure is developed for cloud point extraction of Pd(II) and Rh(III) ions in aqueous solution using Span 80 (non-ionic surfactant) prior to their determination by flame atomic absorption spectroscopy. This method is based on the extraction of Pd(II) and Rh(III) ions at a pH of 10 using Span 80 with no chelating agent. We investigated the effect of various parameters on the recovery of the analyte ions, including pH, equilibration temperature and time, concentration of Span 80, and ionic strength. Under the best experimental conditions, the limits of detection based on 3Sb for Pd(II) and Rh(III) ions were 1.3 and 1.2 ng mL-1, respectively. Seven replicate determinations of a mixture of 0.5 µg mL-1 palladium and rhodium ions gave a mean absorbance of 0.058 and 0.053 with relative standard deviations of 1.8 and 1.6%, respectively. The developed method was successfully applied to the extraction and determination of the palladium and rhodium ions in road dust and standard samples and satisfactory results were obtained.

Mobile system for pump working point estimation

In the current economy situation companies try to reduce their expenses. One of the solutions is to improve the energy efficiency of the processes. It is known that the energy consumption of pumping applications range from 20 up to 50% of the energy usage in the certain industrial plants operations. Some studies have shown that 30% to 50% of energy consumed by pump systems could be saved by changing the pump or the flow control method. The aim of this thesis is to create a mobile measurement system that can calculate a working point position of a pump drive. This information can be used to determine the efficiency of the pump drive operation and to develop a solution to bring pump’s efficiency to a maximum possible value. This can allow a great reduction in the pump drive’s life cycle cost. In the first part of the thesis, a brief introduction in the details of pump drive operation is given. Methods that can be used in the project are presented. Later, the review of available platforms for the project implementation is given. In the second part of the thesis, components of the project are presented. Detailed description for each created component is given. Finally, results of laboratory tests are presented. Acquired results are compared and analyzed. In addition, the operation of created system is analyzed and suggestions for the future development are given.

A generalized 1D particle transport method for convection diffusion reaction model

This work is devoted to the development of numerical method to deal with convection diffusion dominated problem with reaction term, non - stiff chemical reaction and stiff chemical reaction. The technique is based on the unifying Eulerian - Lagrangian schemes (particle transport method) under the framework of operator splitting method. In the computational domain, the particle set is assigned to solve the convection reaction subproblem along the characteristic curves created by convective velocity. At each time step, convection, diffusion and reaction terms are solved separately by assuming that, each phenomenon occurs separately in a sequential fashion. Moreover, adaptivities and projection techniques are used to add particles in the regions of high gradients (steep fronts) and discontinuities and transfer a solution from particle set onto grid point respectively. The numerical results show that, the particle transport method has improved the solutions of CDR problems. Nevertheless, the method is time consumer when compared with other classical technique e.g., method of lines. Apart from this advantage, the particle transport method can be used to simulate problems that involve movingsteep/smooth fronts such as separation of two or more elements in the system.

DEVELOPING A CROWDSOURCED VIDEOGRAPHIC RESEARCH METHOD FOR CONSUMER CULTURE RESEARCH

The purpose of this study is to develop a crowdsourced videographic research method for consumer culture research. Videography provides opportunities for expressing contextual and culturally embedded relations. Thus, developing new ways to conduct videographic research is meaningful. This study develops the crowdsourced videographic method based on a literature review and evaluation of a focal study. The literature review follows a qualitative systematic review process. Through the literature review, based on different methodological, crowdsourcing and consumer research related literature, this study defines the method, its application process and evaluation criteria. Furthermore, the evaluation of the focal study, where the method was applied, completes the study. This study applies professional review with self-evaluation as a form of evaluation, drawing from secondary data including research task description, screenshots of the mobile application used in the focal study, videos collected from the participants, and self-evaluation by the author. The focal study is analyzed according to its suitability to consumer culture research, research process and quality. Definitions and descriptions of the research method, its process and quality criteria form the theoretical contribution of this study. Evaluating the focal study using these definitions underlines some best practices of this type of research, generating the practical contribution of this study. Finally, this study provides ideas for future research. First, defining the boundaries of the use of crowdsourcing in various parts of conducting research. Second, improving the method by applying it to new research contexts. Third, testing how changes in one dimension of the crowdsourcing models interact with other dimension. Fourth, comparing the quality criteria applied in this study to various other quality criteria to improve the method’s usefulness. Overall, this study represents a starting point for further development of the crowdsourced videographic research method.

Algorithm to determine the intersection curves between bezier surfaces by the solution of multivariable polynomial system and the differential marching method

The determination of the intersection curve between Bézier Surfaces may be seen as the composition of two separated problems: determining initial points and tracing the intersection curve from these points. The Bézier Surface is represented by a parametric function (polynomial with two variables) that maps a point in the tridimensional space from the bidimensional parametric space. In this article, it is proposed an algorithm to determine the initial points of the intersection curve of Bézier Surfaces, based on the solution of polynomial systems with the Projected Polyhedral Method, followed by a method for tracing the intersection curves (Marching Method with differential equations). In order to allow the use of the Projected Polyhedral Method, the equations of the system must be represented in terms of the Bernstein basis, and towards this goal it is proposed a robust and reliable algorithm to exactly transform a multivariable polynomial in terms of power basis to a polynomial written in terms of Bernstein basis .