The mutual agreement procedure and arbitration of double taxation disputes

It is in the interest of most states to eliminate double taxation (i.e. the payment of the same tax in two jurisdictions) of transnational commercial enterprises. Because such disputes involve, on the one hand, the state imposition of taxes, a right universally asserted by all states, and private entities on the other, taxation disputes between such parties are not, on their face, easily susceptible to arbitration. This article analyzes two dispute settlement procedures-the OECD First Model Tax Convention and a similar EU Convention-with the exclusive focus on disputes relating to the imposition of double taxation. It will look at the ways in which state roles may vary under these procedures from assisting in the negotiation process to taking a part similar to, but with important differences from, diplomatic protection on behalf of an affected enterprise. The article will examine the situations under which the settlement procedure is required and/or available, how the procedures are triggered, the obligations and parts played by the parties, the means by which the disputes are resolved (from negotiations to tribunals) and the limitations of the procedures. Are they “taxpayer friendly”? As a result the reader may draw comparisons between the two procedures. Finally, the article will look at the proposed OECD Arbitration Clause which is intended to be incorporated into Article 25 of the OECD Model Tax Convention as well as how these mechanisms relate and/or conflict with bilateral tax treaties and the GATS.

Contingency management effects on delay discounting among patients receiving smoking cessation treatment

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Shape complexity based on mutual information

Shape complexity has recently received attention from different fields, such as computer vision and psychology. In this paper, integral geometry and information theory tools are applied to quantify the shape complexity from two different perspectives: from the inside of the object, we evaluate its degree of structure or correlation between its surfaces (inner complexity), and from the outside, we compute its degree of interaction with the circumscribing sphere (outer complexity). Our shape complexity measures are based on the following two facts: uniformly distributed global lines crossing an object define a continuous information channel and the continuous mutual information of this channel is independent of the object discretisation and invariant to translations, rotations, and changes of scale. The measures introduced in this paper can be potentially used as shape descriptors for object recognition, image retrieval, object localisation, tumour analysis, and protein docking, among others

Test-retest reliability with the Madsen ZO70 electroacoustic impedance bridge

This paper is a review of a study to measure acoustic impedance of the ear using a Madsen ZO70 bridge model.

The UK-Canada Agreement on mutual support of missions abroad: loyalty compromised? CEPS Commentary, 18 October 2012

The UK and Canada recently signed a Memorandum of Understanding aimed at allowing the two countries to optimise their respective diplomatic resources by sharing embassy and consulate sites, the joint acquisition, supply and use of services, as well as collaboration on crisis response, consular services, security, diplomatic mail, information management and IT. This CEPS Commentary argues that the MoU on Mutual Support of Missions Abroad runs counter to the spirit of loyal cooperation, in particular in the realm of EU foreign policy. It also raises challenges to coherence, consistency and effectiveness of EU action in policy areas concerning visas, trade and consular protection. Moreover, the agreement may throw a spanner in the works of EU solidarity and the creation of a stronger EU identity, both internally and externally

Language experience shapes the development of the mutual exclusivity bias

Halberda (2003) demonstrated that 17-month-old infants, but not 14- or 16-month-olds, use a strategy known as mutual exclusivity (ME) to identify the meanings of new words. When 17-month-olds were presented with a novel word in an intermodal preferential looking task, they preferentially fixated a novel object over an object for which they already had a name. We explored whether the development of this word-learning strategy is driven by children's experience of hearing only one name for each referent in their environment by comparing the behavior of infants from monolingual and bilingual homes. Monolingual infants aged 17–22 months showed clear evidence of using an ME strategy, in that they preferentially fixated the novel object when they were asked to "look at the dax." Bilingual infants of the same age and vocabulary size failed to show a similar pattern of behavior. We suggest that children who are raised with more than one language fail to develop an ME strategy in parallel with monolingual infants because development of the bias is a consequence of the monolingual child's everyday experiences with words.

Study of the variation of the input impedance of induction machines with frequency

The results of a study of the variation of three-phase induction machines' input impedance with frequency are proposed. A range of motors were analysed, both two-pole and four-pole, and the magnitude and phase of the input impedance were obtained over a wide frequency range of 20 Hz-1 MHz. For test results that would be useful in the prediction of the performance of induction machines during typical use, a test procedure was developed to represent closely typical three-phase stator coil connections when the induction machine is driven by a three-phase inverter. In addition, tests were performed with the motor's cases both grounded and not grounded. The results of the study show that all induction machines of the type considered exhibit a multiresonant impedance profile, where the input impedance reaches at least one maximum as the input frequency is increased. Furthermore, the test results show that the grounding of the motor's case has a significant effect on the impedance profile. Methods to exploit the input impedance profile of an induction machine to optimise machine and inverter systems are also discussed.