Hacia la aplicación de las guías de la Organización para la Cooperación y el Desarrollo Económicos (OCDE) sobre precios de transferencia para empresas multinacionales y administraciones tributarias en Colombia

Los precios de transferencia ocupan el interés de los Estados en el mundo actual al constituir uno de los retos fundamentales del Derecho Internacional Tributario. En el seno de la Organización para la Cooperación y el Desarrollo Económicos (OCDE), creada en 1961, se discutieron y desarrollaron diversas propuestas para regular el fenómeno. Estas, se materializaron en Modelos de Convenios Tributarios e instrumentos de soft law, que hoy en día constituyen los principios internacionalmente aceptados en la materia. Las Guías de la OCDE sobre precios de transferencia para empresas multinacionales y administraciones tributarias son el cuerpo normativo de soft law que se erigen, en el Ordenamiento Internacional, como el norte de las legislaciones a nivel interno para efectos de regulación de dicha temática. Su adopción por parte de los países miembros y no miembros de la OCDE se enfrenta a problemas teóricos derivados del quebrantamiento del decantado principio de reserva de ley tributaria y el respeto por la seguridad jurídica, razón por la cual su incorporación ha variado de Estado a Estado. El presente trabajo recoge la experiencia en varios países europeos y latinoamericanos y pretende proponer una fórmula de adopción en Colombia, coherente con los principios constitucionales tributarios y con virtualidad de superar las críticas realizadas por la doctrina a la aplicación directa de las Guías.

Estimating and Forecasting the Term Structure of Interest Rates:US and Colombia Analysis

In this paper we use the most representative models that exist in the literature on term structure of interest rates. In particular, we explore affine one factor models and polynomial-type approximations such as Nelson and Siegel. Our empirical application considers monthly data of USA and Colombia for estimation and forecasting. We find that affine models do not provide adequate performance either in-sample or out-of-sample. On the contrary, parsimonious models such as Nelson and Siegel have adequate results in-sample, however out-of-sample they are not able to systematically improve upon random walk base forecast.

Human exposure modelling for chemical risk assessment: a review of current approaches and research and policy implications

A wide variety of exposure models are currently employed for health risk assessments. Individual models have been developed to meet the chemical exposure assessment needs of Government, industry and academia. These existing exposure models can be broadly categorised according to the following types of exposure source: environmental, dietary, consumer product, occupational, and aggregate and cumulative. Aggregate exposure models consider multiple exposure pathways, while cumulative models consider multiple chemicals. In this paper each of these basic types of exposure model are briefly described, along with any inherent strengths or weaknesses, with the UK as a case study. Examples are given of specific exposure models that are currently used, or that have the potential for future use, and key differences in modelling approaches adopted are discussed. The use of exposure models is currently fragmentary in nature. Specific organisations with exposure assessment responsibilities tend to use a limited range of models. The modelling techniques adopted in current exposure models have evolved along distinct lines for the various types of source. In fact different organisations may be using different models for very similar exposure assessment situations. This lack of consistency between exposure modelling practices can make understanding the exposure assessment process more complex, can lead to inconsistency between organisations in how critical modelling issues are addressed (e.g. variability and uncertainty), and has the potential to communicate mixed messages to the general public. Further work should be conducted to integrate the various approaches and models, where possible and regulatory remits allow, to get a coherent and consistent exposure modelling process. We recommend the development of an overall framework for exposure and risk assessment with common approaches and methodology, a screening tool for exposure assessment, collection of better input data, probabilistic modelling, validation of model input and output and a closer working relationship between scientists and policy makers and staff from different Government departments. A much increased effort is required is required in the UK to address these issues. The result will be a more robust, transparent, valid and more comparable exposure and risk assessment process. (C) 2006 Elsevier Ltd. All rights reserved.

Governmentality, subject-building, and the discourses and practices of devolution in the UK

This paper uses a Foucauldian governmentality framework to analyse and interrogate the discourses and strategies adopted by the state and sections of the business community in their attempts to shape and influence emerging agendas of governance in post-devolution Scotland. Much of the work on governmentality has examined the ways in which governments have developed particular techniques, rationales and mechanisms to enable the functioning of governance programmes. This paper expands upon such analyses by also looking at the ways in which particular interests may use similar procedures, discourses and practices to promote their own agendas and develop new forms of resistance, contestation and challenge to emerging policy frameworks. Using the example of business interest mobilization in post-devolution Scotland, it is argued that governments may seek to mobilize defined forms of expertise and knowledge, linking them to wider political debates. This, however, creates new opportunities for interests to shape and contest the discourses and practices of government. The governmentalization of politics can, therefore, be seen as more of a dialectical process of definition and contestation than is often apparent in existing Foucault-inspired writing.

Opportunities and challenges in high pressure processing of foods

Consumers increasingly demand convenience foods of the highest quality in terms of natural flavor and taste, and which are freedom additives and preservatives. This demand has triggered the need for the development of a number of nonthermal approaches to food processing, of which high-pressure technology has proven to be very valuable. A number of recent publications have demonstrated novel and diverse uses of this technology. Its novel features, which include destruction of microorganisms at room temperature or lower, have made the technology commerically attractive. Enzymes forming bacteria can be by the application of pressure-thermal combinations. This review aims to identify the opportunities and challenges associated with this technology. In addition to discussing the effects of high pressure on food components, this review covers the combined effects of high pressure processing with: gamma irradiation, alternating current, ultrasound, and carbon dioxide or anti-microbial treatment. Further, the applications of this technology in various sectors-fruits and vegetables, dairy and meat processing-have been dealt with extensively. The integration of high-pressure with other matured processing operations such as blanching, dehydration, osmotic dehydration, rehyrdration, frying, freezing/thawing and solid-liquid extraction has been shown to open up new processing options. The key challenges identified include: heat transfer problems and resulting non-uniformity in processing, obtaining reliable and reproducible data, for process validation, lack of detailed knowledge about the interaction between high pressure, and a number of food constituents, packaging and statutory issues.

Saving the planet but losing the landscape: the impact of renewable energy policies on rural Britain

The main instrument of the Government's renewable energy policy is to promote wind power through regulation and subsidy. This gives rise to anomalies in rural planning when turbines are erected in sensitve areas in which other forms of development are strictly controlled. The situation is reviewed in the context of economic viability and considered also against the alternative of growing fuel crops. The latter are currently hampered by lack of Government support but could fulfil a useful secondary role of sustaining the agricultural sector and with it the management of lowland landscapes.

The HadGEM2 family of Met Office Unified Model climate configurations

We describe the HadGEM2 family of climate configurations of the Met Office Unified Model, MetUM. The concept of a model "family" comprises a range of specific model configurations incorporating different levels of complexity but with a common physical framework. The HadGEM2 family of configurations includes atmosphere and ocean components, with and without a vertical extension to include a well-resolved stratosphere, and an Earth-System (ES) component which includes dynamic vegetation, ocean biology and atmospheric chemistry. The HadGEM2 physical model includes improvements designed to address specific systematic errors encountered in the previous climate configuration, HadGEM1, namely Northern Hemisphere continental temperature biases and tropical sea surface temperature biases and poor variability. Targeting these biases was crucial in order that the ES configuration could represent important biogeochemical climate feedbacks. Detailed descriptions and evaluations of particular HadGEM2 family members are included in a number of other publications, and the discussion here is limited to a summary of the overall performance using a set of model metrics which compare the way in which the various configurations simulate present-day climate and its variability.

Getting pupils to 'see the point' of school subjects: history, a case study

This paper examines the factors that influence pupil take up of a subject, in this case history, at GCSE. The research indicates that pupils enjoy history but significant factors prevent many from choosing it for further study; these include factors that are beyond the control of teachers, such as government policy and the way this is interpreted by senior managers in school, and factors that are within the control of teachers. The paper suggests that there are lessons that departments can learn from more successful departments but there are also important side effects of government policy that are having unintended consequences.

Building a left coast: the legacy of the California Popular Front and the challenge to Cold War liberalism in the post-world war two era

The Cold War in the late 1940s blunted attempts by the Truman administration to extend the scope of government in areas such as health care and civil rights. In California, the combined weakness of the Democratic Party in electoral politics and the importance of fellow travelers and communists in state liberal politics made the problem of how to advance the left at a time of heightened Cold War tensions particularly acute. Yet by the early 1960s a new generation of liberal politicians had gained political power in the Golden State and was constructing a greatly expanded welfare system as a way of cementing their hold on power. In this article I argue that the New Politics of the 1970s, shaped nationally by Vietnam and by the social upheavals of the 1960s over questions of race, gender, sexuality, and economic rights, possessed particular power in California because many activists drew on the longer-term experiences of a liberal politics receptive to earlier anti-Cold War struggles. A desire to use political involvement as a form of social networking had given California a strong Popular Front, and in some respects the power of new liberalism was an offspring of those earlier battles.

Policies to promote healthy eating in Europe: a structured review of policies and their effectiveness

This review provides a classification of public policies to promote healthier eating as well as a structured mapping of existing measures in Europe. Complete coverage of alternative policy types was ensured by complementing the review with a selection of major interventions from outside Europe. Under the auspices of the Seventh Framework Programme's Eatwell Project, funded by the European Commission, researchers from five countries reviewed a representative selection of policy actions based on scientific papers, policy documents, grey literature, government websites, other policy reviews, and interviews with policy-makers. This work resulted in a list of 129 policy interventions, 121 of which were in Europe. For each type of policy, a critical review of its effectiveness was conducted, based on the evidence currently available. The results of this review indicate a need exists for a more systematic and accurate evaluation of government-level interventions as well as for a stronger focus on actual behavioral change rather than changes in attitude or intentions alone. The currently available evidence is very heterogeneous across policy types and is often incomplete.

Ideological dominance in recreation provision: towards a theory of Local Authority response to Compulsory Competitive Tendering in Britain

This paper considers how the delivery of public leisure services in Britain has been affected by the imposition of Compulsory Competitive Tendering (CCT) on the management of facilities. In particular, it focuses on the changing relationship between the central and local levels of government, theorising a tripartite local response to CCT, incorporating local statism, post-Fordist rejection of CCT and post- Fordist compliance with the aims of the central administration. The paper then discusses the actual implementation of CCT, relating the theorised responses to those witnessed in practice. This results in the delineation of a continuum of stances, ranging from pragmatic forms of local statism, such as the protection of the former direct labour force, to centrist attempts to combine the ethics of socialism with the mechanics of the market, to an outright rejection of state organisation and control. The paper concludes that although legitimate attempts have been made to protect local services, the outcome of the CCT process has undoubtedly been the regeneration of public leisure provision away from its service roots towards a market model of provision.

Public leisure provision under Compulsory Competitive Tendering: the maintenance of ideological dominance?

Although much has been written about the effect on services of public sector restructuring, little is yet available on public leisure provision. This omission is addressed by considering how the delivery of public leisure services in Britain has been affected by the imposition of Compulsory Competitive Tendering (CCT). In particular, it focuses on the changing relationship between the central and local levels of government recognising, on the part of local government, a continuum of structural responses to central initiatives which have, in some cases, conspired to reduce the impact of CCT on public leisure provision. The paper concludes that although attempts have been made to protect local services, the outcome of the CCT process has been the regeneration of public leisure provision away from its service roots, but within an enduring ideological paradigm of conservative professionalism.

Language capital and development: the case of African language publishing for children in South Africa

In recognizing 11 official languages, the 1996 South African Constitution provides a context for the management of diversity with important implications for the redistribution of wealth and power. The development and implementation of the language-in-education policies which might be expected to flow from the Constitution, however, have been slow and ineffective. One of the casualties of government procrastination has been African language publishing. In the absence of well-resourced bilingual education, most learners continue to be taught through the medium of English as a second language. Teachers are reluctant to use more innovative pedagogies without the support of adequate African language materials and publishers are cautious about producing such materials. Nonetheless, activity in this sector offers many opportunities for African language speakers. This paper explores the challenges and constraints for African language publishing for children and argues that market forces and language policy need to work in mutually reinforcing ways. Further progress is necessarily dependent on the political will to implement language-in-education policies that promote additive bilingualism and, in the process, guarantee sales for risk-averse publishers.