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.

Performance Evaluation of Imaging Systems

Imaging systems have developed latest years and developing is still continuing following years. Manufacturers of imaging systems give promises for the quality of the performance of imaging systems to advertise their products. Promises for the quality of the performance are often so good that they will not be tested in normal usage. The main target in this research is to evaluate the quality of the performance of two imaging systems: Scanner and CCD color camera. Optical measurement procedures were planned to evaluate the quality of imaging performances. Other target in this research is to evaluate calibration programs for the camera and the scanner. Measuring targets had to choose to evaluate the quality of imaging performances. Manufacturers have given definitions for targets. The third task in this research is to evaluate and consider how good measuring targets are.

Another Kind of Knowledge: Aristotle's Phronêsis from an Epistemological Point of View

In my thesis, I defend the idea that Aristotle's notion of phronêsis (practical wisdom) is best understood as a kind of practical knowledge. I interpret phronêsis as the knowledge we display when we make the correct decision to act. In a particular situation that demands a specific response, we have practical knowledge of what to do when we make the best decision possible. This interpretation of phronêsis involves that it is possible to evaluate our decisions epistemically, that is, to evaluate whether we really know what to do or not. Aristotle provides a tool for the evaluation of our decisions, which is a definite kind of argument and which the tradition has called the 'practical syllogism'. The practical syllogism stands as the explanation of our decisions or actions. We invoke it when we want to explain or justify why we act as we do. My claim is that the components of the practical syllogism enable one to evaluate not only the moral character of our actions, but also the epistemic strength of our decisions. Correspondingly, a decision is morally right, i.e. virtuous, if the agent considers the right moral principle to apply, and if he is aware of the relevant circumstances of the situation (moral evaluation). Moreover, a decision displays practical knowledge if the agent meets three conditions (epistemic evaluation): he must desire the moral principle for its own sake; he must have experience in spotting the relevant circumstances of the situation; and he must be able to closely connect these circumstances with the moral principle. This interpretation of phronêsis differs from other more traditional interpretations in the emphasis it puts on phronêsis as knowledge. Other interpretations focus more on the moral dimension on phronêsis, without taking its epistemic value seriously. By contrast, I raise seriously the question of what it takes to genuinely know what one should do in a particular situation. -- Dans ma thèse, je défends l'idée que la notion aristotélicienne de phronêsis (sagesse pratique) doit être interprétée comme connaissance pratique. Je comprends la phronêsis comme étant la connaissance que nous avons lorsque nous prenons une bonne décision. Dans une situation particulière qui demande une réponse précise, nous avons une connaissance pratique lorsque nous prenons la meilleure décision possible. Cette interprétation de la phronêsis implique qu'il est possible d'évaluer nos décisions de manière épistémique, c'est-à-dire, d'évaluer si nous savons vraiment ce qu'il faut faire ou non. Ma position est qu'Aristote fournit un outil pour évaluer épistémiquement nos décisions, qui consiste en un certain type d'argument et que la tradition a appelé le 'syllogisme pratique'. Le syllogisme pratique correspond à l'explication de nos décisions ou de nos actions. Nous invoquons un syllogisme pratique lorsque nous voulons expliquer ou justifier pourquoi nous agissons comme nous le faisons. Les éléments du syllogisme pratique permettent d'évaluer non seulement le caractère moral de nos actions, mais aussi la force épistémique de nos décisions. Par conséquent, une décision est moralement correcte, i.e. vertueuse, si l'agent considère le bon principe moral, et s'il est attentif aux circonstances pertinentes de la situation (évaluation morale). En outre, une décision inclut la connaissance pratique si l'agent remplit trois conditions (évaluation épistémique) : il doit désirer le principe moral pour lui-même, il doit avoir de l'expérience pour déceler les circonstances pertinentes, et il doit pouvoir lier intimement ces circonstances avec le principe moral. Cette interprétation de la phronêsis diffère d'autres interprétations plus traditionnelles par l'emphase mise sur la phronêsis en tant que connaissance. D'autres interprétations se concentrent plus sur la dimension morale de la phronêsis, sans se préoccuper sérieusement de sa valeur épistémique. Au contraire, je pose sérieusement la question des conditions nécessaires pour réellement savoir ce qu'il faut faire dans une situation donnée.

MRI/TRUS fusion software-based targeted biopsy: the new standard of care?

The advent of multiparametric MRI has made it possible to change the way in which prostate biopsy is done, allowing to direct biopsies to suspicious lesions rather than randomly. The subject of this review relates to a computer-assisted strategy, the MRI/US fusion software-based targeted biopsy, and to its performance compared to the other sampling methods. Different devices with different methods to register MR images to live TRUS are currently in use to allow software-based targeted biopsy. Main clinical indications of MRI/US fusion software-based targeted biopsy are re-biopsy in men with persistent suspicious of prostate cancer after first negative standard biopsy and the follow-up of patients under active surveillance. Some studies have compared MRI/US fusion software-based targeted versus standard biopsy. In men at risk with MRI-suspicious lesion, targeted biopsy consistently detects more men with clinically significant disease as compared to standard biopsy; some studies have also shown decreased detection of insignificant disease. Only two studies directly compared MRI/US fusion software-based targeted biopsy with MRI/US fusion visual targeted biopsy, and the diagnostic ability seems to be in favor of the software approach. To date, no study comparing software-based targeted biopsy against in-bore MRI biopsy is available. The new software-based targeted approach seems to have the characteristics to be added in the standard pathway for achieving accurate risk stratification. Once reproducibility and cost-effectiveness will be verified, the actual issue will be to determine whether MRI/TRUS fusion software-based targeted biopsy represents anadd-on test or a replacement to standard TRUS biopsy.

Patterns of care in recurrent glioblastoma in Switzerland: a multicentre national approach based on diagnostic nodes.

Despite moderate improvements in outcome of glioblastoma after first-line treatment with chemoradiation recent clinical trials failed to improve the prognosis of recurrent glioblastoma. In the absence of a standard of care we aimed to investigate institutional treatment strategies to identify similarities and differences in the pattern of care for recurrent glioblastoma. We investigated re-treatment criteria and therapeutic pathways for recurrent glioblastoma of eight neuro-oncology centres in Switzerland having an established multidisciplinary tumour-board conference. Decision algorithms, differences and consensus were analysed using the objective consensus methodology. A total of 16 different treatment recommendations were identified based on combinations of eight different decision criteria. The set of criteria implemented as well as the set of treatments offered was different in each centre. For specific situations, up to 6 different treatment recommendations were provided by the eight centres. The only wide-range consensus identified was to offer best supportive care to unfit patients. A majority recommendation was identified for non-operable large early recurrence with unmethylated MGMT promoter status in the fit patients: here bevacizumab was offered. In fit patients with late recurrent non-operable MGMT promoter methylated glioblastoma temozolomide was recommended by most. No other majority recommendations were present. In the absence of strong evidence we identified few consensus recommendations in the treatment of recurrent glioblastoma. This contrasts the limited availability of single drugs and treatment modalities. Clinical situations of greatest heterogeneity may be suitable to be addressed in clinical trials and second opinion referrals are likely to yield diverging recommendations.

L'année 2014 mise en perspective par les internistes hospitaliers [What is new in 2014 for the specialist in hospital internal medicine? The point of view of university hospital chief residents].

The year 2014 was rich in significant advances in all areas of internal medicine. Many of them have an impact on our daily practice and on the way we manage one problem or another. From the use of the ultrasound for the diagnosis of pneumonia to the choice of the site of venous access and the type of line, and the increasing complexity of choosing an oral anticoagulant agent, this selection offers to the readers a brief overview of the major advances. The chief residents in the Service of internal medicine of the Lausanne University hospital are pleased to share their readings.

Continuum of care for persons with common mental health disorders in Nunavik: a descriptive study.

BACKGROUND: Changing Directions, Changing Lives, the Mental Health Strategy for Canada, prioritizes the development of coordinated continuums of care in mental health that will bridge the gap in services for Inuit populations. OBJECTIVE: In order to target ways of improving the services provided in these contexts to individuals in Nunavik with depression or anxiety disorders, this research examines delays and disruptions in the continuum of care and clinical, individual and organizational characteristics possibly associated with their occurrences. DESIGN: A total of 155 episodes of care involving a common mental disorder (CMD), incident or recurring, were documented using the clinical records of 79 frontline health and social services (FHSSs) users, aged 14 years and older, living in a community in Nunavik. Each episode of care was divided into 7 stages: (a) detection; (b) assessment; (c) intervention; (d) planning the first follow-up visit; (e) implementation of the first follow-up visit; (f) planning a second follow-up visit; (g) implementation of the second follow-up visit. Sequential analysis of these stages established delays for each one and helped identify when breaks occurred in the continuum of care. Logistic and linear regression analysis determined whether clinical, individual or organizational characteristics influenced the breaks and delays. RESULTS: More than half (62%) the episodes of care were interrupted before the second follow-up. These breaks mostly occurred when planning and completing the first follow-up visit. Episodes of care were more likely to end early when they involved anxiety disorders or symptoms, limited FHSS teams and individuals over 21 years of age. The median delay for the first follow-up visit (30 days) exceeded guideline recommendations significantly (1-2 weeks). CONCLUSION: Clinical primary care approaches for CMDs in Nunavik are currently more reactive than preventive. This suggests that recovery services for those affected are suboptimal.

Two-photon excitation fluorometry in detection of infectious diseases

Because of the heavily overlapping symptoms, pathogen-specific diagnosis and treatment of infectious diseases is difficult based on clinical symptoms alone. Therefore, patients are often treated empirically. More efficient treatment and management of infectious diseases would require rapid point-of-care compatible in vitro diagnostic methods. However, current point-of-care methods are unsatisfactory in performance and in cost structure. The lack of pointof- care methods results in unnecessary use of antibiotics, suboptimal use of virus-specific drugs, and compromised patient care. In this thesis, the applicability of a two-photon excitation fluorometry is evaluated as a tool for rapid detection of infectious diseases. New separation-free immunoassay methodologies were developed and validated for the following application areas: general inflammation markers, pathogen-specific antibodies, pathogen-specific antigens, and antimicrobial susceptibility testing. In addition, dry-reagent methodology and nanoparticulate tracers are introduced in context to the technique. The results show that the new assay technique is a versatile tool for rapid detection of infectious diseases in many different application areas. One particularly attractive area is rapid multianalyte testing of respiratory infections, where the technique was shown to allow simple assay protocols and comparable performance to the state-of-the-art laboratory methods. If implemented in clinical diagnostic use, the new methods could improve diagnostic testing routines, especially in rapid testing of respiratory tract infections.

Non-Linear Journal Bearing Model for Analysis of Superharmonic Vibrations of Rotor Systems

A rotating machine usually consists of a rotor and bearings that supports it. The nonidealities in these components may excite vibration of the rotating system. The uncontrolled vibrations may lead to excessive wearing of the components of the rotating machine or reduce the process quality. Vibrations may be harmful even when amplitudes are seemingly low, as is usually the case in superharmonic vibration that takes place below the first critical speed of the rotating machine. Superharmonic vibration is excited when the rotational velocity of the machine is a fraction of the natural frequency of the system. In such a situation, a part of the machine’s rotational energy is transformed into vibration energy. The amount of vibration energy should be minimised in the design of rotating machines. The superharmonic vibration phenomena can be studied by analysing the coupled rotor-bearing system employing a multibody simulation approach. This research is focused on the modelling of hydrodynamic journal bearings and rotorbearing systems supported by journal bearings. In particular, the non-idealities affecting the rotor-bearing system and their effect on the superharmonic vibration of the rotating system are analysed. A comparison of computationally efficient journal bearing models is carried out in order to validate one model for further development. The selected bearing model is improved in order to take the waviness of the shaft journal into account. The improved model is implemented and analyzed in a multibody simulation code. A rotor-bearing system that consists of a flexible tube roll, two journal bearings and a supporting structure is analysed employing the multibody simulation technique. The modelled non-idealities are the shell thickness variation in the tube roll and the waviness of the shaft journal in the bearing assembly. Both modelled non-idealities may cause subharmonic resonance in the system. In multibody simulation, the coupled effect of the non-idealities can be captured in the analysis. Additionally one non-ideality is presented that does not excite the vibrations itself but affects the response of the rotorbearing system, namely the waviness of the bearing bushing which is the non-rotating part of the bearing system. The modelled system is verified with measurements performed on a test rig. In the measurements the waviness of bearing bushing was not measured and therefore it’s affect on the response was not verified. In conclusion, the selected modelling approach is an appropriate method when analysing the response of the rotor-bearing system. When comparing the simulated results to the measured ones, the overall agreement between the results is concluded to be good.

Deformation of Gabor systems

We introduce a new notion for the deformation of Gabor systems. Such deformations are in general nonlinear and, in particular, include the standard jitter error and linear deformations of phase space. With this new notion we prove a strong deformation result for Gabor frames and Gabor Riesz sequences that covers the known perturbation and deformation results. Our proof of the deformation theorem requires a new characterization of Gabor frames and Gabor Riesz sequences. It is in the style of Beurling's characterization of sets of sampling for bandlimited functions and extends significantly the known characterization of Gabor frames 'without inequalities' from lattices to non-uniform sets.

Small scale energy production in Helsinki Metropolitan area in emission trading point of view

Emission trading with greenhouse gases and green certificates are part if the climate policy the main target of which is reduce greenhouse gas emissions. The carbon dioxide and fine particle emissions of energy production in Helsinki Metropolitan area are calculated in this study. The analysis is made mainly by district heating point of view and the changes of the district heating network are assessed. Carbon dioxide emissions would be a bit higher, if the district heating network is expanded, but then the fine particle emissions would be much lower. Carbon dioxide emissions are roughly 10 % higher, if the district heating network is expanded at same rate as it has in past five years in the year 2030. The expansion of district heating network would decrease the fine particle emissions about 40 %. The cost of the expansion is allocated to be reduction cost of the fine particle emissions, which is considerably higher than the traditional reduction methods costs. The possible new nuclear plant would reduce the emissions considerably and the costs of the nuclear plant would be relatively low comparing the other energy production methods.

PREDICTING THE BOILING POINT OF PCDD/Fs BY THE QSPR METHOD BASED ON THE MOLECULAR DISTANCE-EDGE VECTOR INDEX

The quantitative structure property relationship (QSPR) for the boiling point (Tb) of polychlorinated dibenzo-p-dioxins and polychlorinated dibenzofurans (PCDD/Fs) was investigated. The molecular distance-edge vector (MDEV) index was used as the structural descriptor. The quantitative relationship between the MDEV index and Tb was modeled by using multivariate linear regression (MLR) and artificial neural network (ANN), respectively. Leave-one-out cross validation and external validation were carried out to assess the prediction performance of the models developed. For the MLR method, the prediction root mean square relative error (RMSRE) of leave-one-out cross validation and external validation was 1.77 and 1.23, respectively. For the ANN method, the prediction RMSRE of leave-one-out cross validation and external validation was 1.65 and 1.16, respectively. A quantitative relationship between the MDEV index and Tb of PCDD/Fs was demonstrated. Both MLR and ANN are practicable for modeling this relationship. The MLR model and ANN model developed can be used to predict the Tb of PCDD/Fs. Thus, the Tb of each PCDD/F was predicted by the developed models.