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Journal articles on the topic 'Arms length principle'

Author: Grafiati

Published: 4 June 2021

Last updated: 7 February 2022

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1

Setiawan, Benny, and Eko Sulistyono. "ANALISIS PENERAPAN KETENTUAN PERPAJAKAN TENTANG KRITERIA PINJAMAN YANG SESUAI DENGAN PRINSIP KEWAJARAN DAN KELAZIMAN USAHA DALAM TRANSAKSI HUBUNGAN ISTIMEWA." INFO ARTHA 1 (June 7, 2017): 73–96. http://dx.doi.org/10.31092/jia.v1i1.71.

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To counteract tax evasion (thin-capitalization), countries across the world including Indonesia begin to apply certain rules. One of the method is to limit the amount of debt of intra-group loan transactions based on the arms length principles. However, the application of this principle to assess the fairness of the loan transaction is not smooth. The unclear set of criteria cause disputes when it is applied. This study analyzes the implementation of the criteria and the relationship among these criteria when they are used simultaneously. The findings of the study initially found that the regu

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2

Shen, Yong Kang, Zheng Zhong Wang, and Chun Long Zhao. "Stability Bearing Capacity of Dendritic Arms in Tainter Gate." Applied Mechanics and Materials 733 (February 2015): 464–67. http://dx.doi.org/10.4028/www.scientific.net/amm.733.464.

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The new arms form of radial gate—dendritic arms is introduced for the proper mechanical mechanism, however the stability design is very difficult. According to the stability theory of structure, the stability analysis model of step column with lateral restraints was proposed for dendritic arms, some equations was derived from the principle of minimum potential energy, the practical formulas of buckling bearing capacity and effective length coefficient were provided. According to an example, the accuracy on formulas was verified by finite analysis method.

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3

Dewi, Ni Luh Rian, and Nur Aisyah Kustiani. "ANALISIS FAKTOR-FAKTOR YANG MEMPENGARUHI PROFITABILITAS PERUSAHAAN MANUFAKTUR INDEPENDEN DI KAWASAN ASIA DAN APLIKASINYA DALAM MENENTUKAN PEMBANDING KEWAJARAN DAN KEWAJARAN USAHA." INFO ARTHA 3 (May 23, 2017): 154–69. http://dx.doi.org/10.31092/jia.v3i0.50.

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In the tax audit on companies which involves transfer pricing in their transaction, tax auditor must determine benchmark companies to determine the arms length principle to be met by the companies. This study aims to analyze determinant factors of the profitability of independent manufacturing companies in Asia. Determinant factors of profitability can be used to determine the appropriate comparison companies. The study used two models with Plust net cost margin and return on assets as dependent variables of each model. Whereas, the independent variables used in this study are the ratio of ope

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Zeng, Ling Sheng, Zi Qiang Zhang, Run Dian Li, Yong Jie Zhao, Qing Ge Kang, and Zhang Lin Chen. "On Adaptable Design for SCARA Manipulator with Quick-Replaceable Arms." Applied Mechanics and Materials 741 (March 2015): 45–49. http://dx.doi.org/10.4028/www.scientific.net/amm.741.45.

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By surveying SCARA manipulator in the market, the question that the overall length of arms is fixed, which leads its operating range to be relatively fixed, and the manipulator has badly adaptive can be found. Aiming at the problem, a SCARA manipulator whose arms can be replaced quickly had been designed according to the concept of adaptable design, and the principle of replacement arms had been put forward basing on the analysis to the minimum operating radius of manipulator in this paper. Moreover, an adaptable interface for replacing quickly different grippers during the process of producti

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5

Mangset, Per. "El principi d’arm’s lenght i el sistema de finançament de les arts. Una aproximació comparativa." Debats. Revista de Cultura, Poder i Societat 130, no. 2 (2016): 53–72. http://dx.doi.org/10.28939/iam.debats.130-2.4.

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6

Mu, Dan, Jian-Quan Li, Xing-Shun Cong, and Han Zhang. "Mesoscopic Detection of the Influence of a Third Component on the Self-Assembly Structure of A2B Star Copolymer in Thin Films." Polymers 11, no. 10 (2019): 1636. http://dx.doi.org/10.3390/polym11101636.

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The most common self-assembly structure for A2B copolymer is the micellar structure with B/A segments being the core/corona, which greatly limits its application range. Following the principle of structure deciding the properties, a reformation in the molecular structure of A2B copolymer is made by appending three segments of a third component C with the same length to the three arms, resulting (AC)2CB 3-miktoarm star terpolymer. A reverse micellar structure in self-assembly is expected by regulating the C length and the pairwise repulsive strength of C to A/B, aiming to enrich its application

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7

Kelly, Veronica. "The Globalized and the Local: Theatre in Australia and Aotearoa/New Zealand Enters the New Millennium." Theatre Research International 26, no. 1 (2001): 1–14. http://dx.doi.org/10.1017/s0307883301000013.

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Late in 1999 the Commonwealth of Australia's Department of Communications, Information Technology and the Arts released Securing the Future, the final Report of the Major Performing Arts Enquiry chaired by Helen Nugent (commonly referred to as the Nugent Report). The operations of the committee and the findings of the Report occasioned considerable public debate in the Australian arts world in the late 1990s, as the Enquiry solicited and analysed information and opinion on the financial health and artistic practices of thirty-one national major performing arts companies producing opera, ballet

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Bakvis, Herman. "Commissioned Ridings: Designing Canada's Electoral Districts. By John C. Courtney. Montreal: McGill-Queen's University Press, 2001. 337p. $75.00 cloth, $27.95 paper." American Political Science Review 96, no. 3 (2002): 655–56. http://dx.doi.org/10.1017/s0003055402680360.

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The approach to the design and revision of electoral districts in Canada is quite different from that found in the United States, despite the two countries' sharing of the same basic first-past-the-post electoral system. As John Courtney notes in his careful study of the topic, in Canada the emphasis in defining electoral districts, or constituencies or ridings, has been underpinned by concepts such as “community of interest” and “effective representation,” which encompass a wide range of political and social considerations—many local in nature—and which permit substantial deviation from the p

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9

Bonnitcha, Jonathan. "Article: Investment Treaties and Transition from Authoritarian Rule." Journal of World Investment & Trade 15, no. 5-6 (2014): 965–1011. http://dx.doi.org/10.1163/22119000-01506009.

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Following recent events in Egypt, Libya, Myanmar (Burma) and Tunisia, foreign investors have lodged international claims under investment treaties. Several of these cases follow a common fact pattern. They concern foreign investments acquired from authoritarian governments substantially below market value through transactions that were not arms’ length. Subsequently, new governments sought to renegotiate these contracts and concessions, or to change the regulatory arrangements that govern them. The investors then invoked the protections of an investment treaty. This article draws on political

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10

Paciolla, Mariarita, Daniel J. Arismendi-Arrieta, and Angel J. Moreno. "Coarsening Kinetics of Complex Macromolecular Architectures in Bad Solvent." Polymers 12, no. 3 (2020): 531. http://dx.doi.org/10.3390/polym12030531.

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This study reports a general scenario for the out-of-equilibrium features of collapsing polymeric architectures. We use molecular dynamics simulations to characterize the coarsening kinetics, in bad solvent, for several macromolecular systems with an increasing degree of structural complexity. In particular, we focus on: flexible and semiflexible polymer chains, star polymers with 3 and 12 arms, and microgels with both ordered and disordered networks. Starting from a powerful analogy with critical phenomena, we construct a density field representation that removes fast fluctuations and provide

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11

Huang, Zhixiong, and Yaohui Ying. "The application of the principle of distinction in the cyber context: A Chinese perspective." International Review of the Red Cross 102, no. 913 (2020): 335–65. http://dx.doi.org/10.1017/s1816383121000023.

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AbstractUp to now, the Chinese government has only made very general comments on the application of international humanitarian law to cyberspace. There are indeed Chinese academic papers concerning this issue, but the discussion of the principle of distinction is limited both in length and in academic depth. Compared with the West, research by Chinese scholars on this topic is still in a relatively preliminary stage. At present, there is no specific deconstruction or clarification of the application of the principle of distinction in cyberspace in Chinese academia. As the first paper written b

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12

Morimoto, Yoshiharu. "High-Speed Measurement of Shape and Vibration: Whole-Field Systems for Motion Capture and Vibration Modal Analysis by OPPA Method." Sensors 20, no. 15 (2020): 4263. http://dx.doi.org/10.3390/s20154263.

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In shape measurement systems using a grating projection method, the phase analysis of a projected grating provides accurate results. The most popular phase analysis method is the phase shifting method, which requires several images for one shape analysis. Therefore, the object must not move during the measurement. The authors previously proposed a new accurate and high-speed shape measurement method, i.e., the one-pitch phase analysis (OPPA) method, which can determine the phase at every point of a single image of an object with a grating projected onto it. In the OPPA optical system, regardle

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13

Rukomojnikov, Konstantin P., and Viktoriia O. Kuptcova. "Design Improvement of the Mechanism of Delimbing by Multi-Operational Forest Machines." Lesnoy Zhurnal (Forestry Journal), no. 3 (May 20, 2021): 117–24. http://dx.doi.org/10.37482/0536-1036-2021-3-117-124.

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The principles of increasing the use of modern multifunctional forest machines (harvesters and processors) for felling and delimbing in Russia and abroad are currently becoming more widespread and deserve increased attention from esearchers. The results of the studies performed made it possible to identify a wide range of constructive solutions of technological equipment interesting in the opinion of the authors of the publication and to develop a new technical solution. The idea of creating an additional shock load by the working body of multifunctional forest machines for delimbing during th

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14

Svinøy, Odd-Einar, Astrid Bergland, May Arna Risberg, Are Hugo Pripp, and Gunvor Hilde. "Better before–better after: efficacy of prehabilitation for older patients with osteoarthritis awaiting total hip replacement—a study protocol for a randomised controlled trial in South-Eastern Norway." BMJ Open 9, no. 12 (2019): e031626. http://dx.doi.org/10.1136/bmjopen-2019-031626.

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IntroductionHealth professions need to prepare for the increase of older patients with osteoarthritis requiring health services including those requiring total joint arthroplasty (TJA). The primary objective of this study is to assess the effect of a tailored prehabilitation programme of older patients awaiting primary surgery for total hip replacement on physical function measured by walking speed within 1 week after intervention as well as 6 weeks and 3 months after TJA surgery.Methods and analysisThis is a single-blinded randomised controlled trial. The participants are 70 years or older, s

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15

Jakoubek, Jiří. "Arm's Length Principle in Intangible Assets Valuation." Český finanční a účetní časopis 2013, no. 4 (2013): 70–83. http://dx.doi.org/10.18267/j.cfuc.353.

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16

Choe, Chongwoo, and Noriaki Matsushima. "The arm's length principle and tacit collusion." International Journal of Industrial Organization 31, no. 1 (2013): 119–30. http://dx.doi.org/10.1016/j.ijindorg.2012.12.001.

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17

Scott, Jessica, Samantha M. Thomas, James Emmett Herndon, et al. "Effects of Non-Linear or Linear Aerobic Training (AT) Dosing Regimens on Impaired Cardiovascular (CV) Function in Patients with Operable Breast Cancer: A Randomized Controlled Trial (RCT)." Journal of Clinical Oncology 37, no. 15_suppl (2019): 541. http://dx.doi.org/10.1200/jco.2019.37.15_suppl.541.

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541 Background: Breast cancer therapy causes marked impairments in CV function predisposing to elevated risk of CV morbidity. We investigated the effects of two AT dosing regimens on CV function in post-treatment patients with operable breast cancer. Methods: In a three-arm, parallel-group RCT, 174 post-menopausal patients (2.8 years post primary adjuvant therapy) with impaired age/sex-matched peak oxygen consumption (VO2peak) were randomized to: (1) conventional linear AT (uniform dose-intensity / session), (2) nonlinear AT (variable dose-intensity / session), or (3) stretching (attention con

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18

Yao, Jen-Te. "The arm's length principle, transfer pricing, and location choices." Journal of Economics and Business 65 (January 2013): 1–13. http://dx.doi.org/10.1016/j.jeconbus.2012.09.004.

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19

Van Thiel, Sandra, and Amanda Smullen. "Principals and Agents, or Principals and Stewards? Australian Arms Length Agencies’ Perceptions of Arm’s Length Government Instruments." Public Performance & Management Review 44, no. 4 (2021): 758–84. http://dx.doi.org/10.1080/15309576.2021.1881803.

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20

CHOE, CHONGWOO, and CHARLES E. HYDE. "Multinational Transfer Pricing, Tax Arbitrage and the Arm's Length Principle*." Economic Record 83, no. 263 (2008): 398–404. http://dx.doi.org/10.1111/j.1475-4932.2007.00429.x.

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21

Keuschnigg, Christian, and Michael P. Devereux. "The arm's length principle and distortions to multinational firm organization." Journal of International Economics 89, no. 2 (2013): 432–40. http://dx.doi.org/10.1016/j.jinteco.2012.08.007.

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22

Berry, Robert, and Joyce Wiggins. "Spotlight on the Principles/Standards: Measurement in the Middle Grades." Mathematics Teaching in the Middle School 7, no. 3 (2001): 154–56. http://dx.doi.org/10.5951/mtms.7.3.0154.

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People use measurement ideas everyday because the ideas arise out of the need to compare attributes of the real world and because humans are naturally inclined to make comparisons. Comparison is the basis for measurement. We make simple comparisons, such as that “the width of the desk is about an arms length,” and complex comparisons expressed in terms of precise numerical measurements. Although measurement encompasses such topics as time, temperature, length, perimeter, and volume, this article specifically focuses on how middle school students learn about angle measurement.

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23

Bustos, Sebastián, Dina Pomeranz, José Vila-Belda, and Gabriel Zucman. "Challenges of Monitoring Tax Compliance by Multinational Firms: Evidence from Chile." AEA Papers and Proceedings 109 (May 1, 2019): 500–505. http://dx.doi.org/10.1257/pandp.20191045.

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This paper reviews common challenges of taxing multinational firms, using Chile as a case study. We briefly describe key international tax avoidance methods: profit shifting to low-tax jurisdictions through transfer pricing and debt shifting. We discuss the prevalent policy to tax multinationals--the arm's length principle--and alternative proposals using apportionment formulas. Novel data from Chile show that multinationals make up a large share of GDP but report lower profit and effective tax rates than local firms. In 2011, Chile implemented a reform following OECD guidelines to enforce the

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24

Lee, Koo-Hyoung, and Karl H. E. Kroemer. "A Finger Model with Constant Tendon Moment Arms." Proceedings of the Human Factors and Ergonomics Society Annual Meeting 37, no. 10 (1993): 710–14. http://dx.doi.org/10.1177/154193129303701014.

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A kinematic finger model was developed with the assumption that the tendon moment arms at the finger joints were constant, and that the finger moved in the sagittal plane. Equations of static equilibrium for the model, derived using the principle of virtual work, were indeterminate. The number of variables was reduced based on the muscular activities in finger movements. The finger strengths were computed from the equilibrium equations, and mathematically expressed as functions of finger positions, tendon moment arms, and lengths of phalanges. Experiments were performed to measure finger stren

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25

Nerudová, D., and V. Solilová. "Transfer pricing in agricultural enterprises." Agricultural Economics (Zemědělská ekonomika) 57, No. 7 (2011): 311–21. http://dx.doi.org/10.17221/84/2010-agricecon.

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International tax issues already have not been problems of multinational enterprises. The effect of globalization and international business development causes that many small and medium size firms including agricultural entities are now engaged in the cross-border transactions and have to face the international tax issues. One of the important areas of international taxes is transfer pricing. The transactions between these persons should be assessed at their arm's length price according to the arm's length principle (internationally accepted standard) as the price which would have been agreed

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26

Li, Yongjun, Lin Lin, Qianzhi Dai, and Linda Zhang. "Allocating common costs of multinational companies based on arm's length principle and Nash non-cooperative game." European Journal of Operational Research 283, no. 3 (2020): 1002–10. http://dx.doi.org/10.1016/j.ejor.2019.11.049.

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27

Quinn, Ruth‐Blandina M. "Distance or intimacy?—The arm's length principle, the British government and the arts council of Great Britain1." International Journal of Cultural Policy 4, no. 1 (1997): 127–59. http://dx.doi.org/10.1080/10286639709358066.

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28

Chen, Zhe, and Simon Haykin. "On Different Facets of Regularization Theory." Neural Computation 14, no. 12 (2002): 2791–846. http://dx.doi.org/10.1162/089976602760805296.

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This review provides a comprehensive understanding of regularization theory from different perspectives, emphasizing smoothness and simplicity principles. Using the tools of operator theory and Fourier analysis, it is shown that the solution of the classical Tikhonov regularization problem can be derived from the regularized functional defined by a linear differential (integral) operator in the spatial (Fourier) domain. State-ofthe-art research relevant to the regularization theory is reviewed, covering Occam's razor, minimum length description, Bayesian theory, pruning algorithms, information

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29

DUDLEY, GEOFFREY. "THE NEXT STEPS AGENCIES, POLITICAL SALIENCE AND THE ARM'S-LENGTH PRINCIPLE: BARBARA CASTLE AT THE MINISTRY OF TRANSPORT 1965-68." Public Administration 72, no. 2 (1994): 219–40. http://dx.doi.org/10.1111/j.1467-9299.1994.tb01009.x.

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30

Sari, Nuraini, and Ririn Susanti Hunar. "Analysis Method of Transfer Pricing Used by Multinational Companies Related to Tax Avoidance and its Consistencies to the Arm's Length Principle." Binus Business Review 6, no. 3 (2015): 341. http://dx.doi.org/10.21512/bbr.v6i3.944.

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The purpose of this study is to evaluate about how Starbucks Corporation uses transfer pricing to minimize the tax bill. In addition, the study also will evaluate how Indonesia’s domestic rules can overcome the case if Starbucks UK case happens in Indonesia. There are three steps conducted in this study. First, using information provided by UK Her Majesty's Revenue and Customs (HMRC) and other related articles, find methods used by Starbucks UK to minimize the tax bill. Second, find Organisation for Economic Co-Operation and Development (OECD) viewpoint regarding Starbucks Corporation cases. T

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31

Zemel, Richard S., and Geoffrey E. Hinton. "Learning Population Codes by Minimizing Description Length." Neural Computation 7, no. 3 (1995): 549–64. http://dx.doi.org/10.1162/neco.1995.7.3.549.

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The minimum description length (MDL) principle can be used to train the hidden units of a neural network to extract a representation that is cheap to describe but nonetheless allows the input to be reconstructed accurately. We show how MDL can be used to develop highly redundant population codes. Each hidden unit has a location in a low-dimensional implicit space. If the hidden unit activities form a bump of a standard shape in this space, they can be cheaply encoded by the center of this bump. So the weights from the input units to the hidden units in an autoencoder are trained to make the ac

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32

O'Sullivan, Janet. "LOST ON PENALTIES." Cambridge Law Journal 73, no. 3 (2014): 480–83. http://dx.doi.org/10.1017/s0008197314000920.

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FREEDOM of contract is a fundamental principle of English law, but it is of course qualified by numerous protective regimes, some common law, most statutory nowadays, which protect vulnerable parties from untrammelled, unequal free bargaining. It is, quite rightly, exceptional for an experienced commercial party, negotiating at arm's length and with the benefit of specialist professional advice, to succeed in invoking such a regime to escape being bound by what he freely agreed. Yet, in Cavendish Square Holdings BV v Makdessi [2013] EWCA Civ 1539, this was precisely the controversial result.

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Li, Jinyan, Nathan Jin Bao, and Huaning Christina Li. "Value Creation: A Constant Principle in a Changing World of International Taxation." Canadian Tax Journal/Revue fiscale canadienne 67, no. 4 (2019): 1107–34. http://dx.doi.org/10.32721/ctj.2019.67.4.sym.li.

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The authors consider the new nomenclature of value creation in terms of its meaning, theoretical basis, and importance in the context of the international taxation of business profits. The authors' central claim is that the principle of value creation is a profound elaboration of the doctrine of economic allegiance, which is the theoretical basis for the current international tax system; and that international tax norms, such as the arm's-length principle, are meant to give effect to the doctrine of economic allegiance (and now to the principle of value creation). As demonstrated by the Organi

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34

Hukamawati, Dinartika, and Arifah Fibri Andriani. "ANALISIS PENERAPAN ARM’S LENGTH PRINCIPLE PADA TRANSAKSI PEMBAYARAN ROYALTI ATAS PEMANFAATAN MEREK DAGANG (TRADEMARK) KEPADA PERUSAHAAN AFILIASI." INFO ARTHA 4 (May 24, 2017): 1–18. http://dx.doi.org/10.31092/jia.v4i4.34.

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Trademark is a unique marketing intangible. It does not only involve the expenses of marketing, advertising, and promoting, but the reputation of the trademark's owners also takes part in the development of trademark. Many parties involve in the development of trademark. In the context of transfer pricing, these parties entitle to some compensation. And arm's length principle must be applied to determine the reasonable compensation for the use of trademark. Transaction payment of royalties on trademarks is subject to taxes.The taxation of transactions payment of royalties on the use of the tra

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35

Sulik-Górecka, Aleksandra. "Dilemmas of Transfer Pricing Comparability Analysis in Manufacturing Entities. Polish-Czech Case Study." Management Systems in Production Engineering 26, no. 2 (2018): 76–82. http://dx.doi.org/10.2478/mspe-2018-0012.

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Abstract Modern manufacturing entities often operate in capital groups, and their role is sometimes limited to the function of cost centers. From the legal point of view, however, they are separate entities obliged to apply transfer pricing regulations. Meeting the requirements of the arm's length principle can be very difficult at this time, given the relationships and conflicts of interest in the capital group. Complexity increases in capital groups operating in different countries, due to differences in tax regulations. The main purpose of the paper is to demonstrate that the need to valuat

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Khorasani, Manouchehr Moshtagh. "El arma sagrada: el combate con arco y flecha en Irán." Revista de Artes Marciales Asiáticas 5, no. 1 (2012): 53. http://dx.doi.org/10.18002/rama.v5i1.124.

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<p class="AMresumen">The following article presents the development of the bow and arrow, and its important role in the history of Iran. The bow always played an important role not only on the battlefield, but also in hunting. It was also considered as a sacred weapon and additionally a royal symbol. Bow and arrow were considered as a superior weapon in comparison with other types of weapons because one could fight with them at a safer distance as one offered by swords, maces and axes. The first part of the article presents a short history of the bow in Iran. Based on historical Persian

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Squires, Steven, Adam Prügel-Bennett, and Mahesan Niranjan. "Rank Selection in Nonnegative Matrix Factorization using Minimum Description Length." Neural Computation 29, no. 8 (2017): 2164–76. http://dx.doi.org/10.1162/neco_a_00980.

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Nonnegative matrix factorization (NMF) is primarily a linear dimensionality reduction technique that factorizes a nonnegative data matrix into two smaller nonnegative matrices: one that represents the basis of the new subspace and the second that holds the coefficients of all the data points in that new space. In principle, the nonnegativity constraint forces the representation to be sparse and parts based. Instead of extracting holistic features from the data, real parts are extracted that should be significantly easier to interpret and analyze. The size of the new subspace selects how many f

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Lehtokangas, Mikko, Jukka Saarinen, Pentti Huuhtanen, and Kimmo Kaski. "Predictive Minimum Description Length Criterion for Time Series Modeling with Neural Networks." Neural Computation 8, no. 3 (1996): 583–93. http://dx.doi.org/10.1162/neco.1996.8.3.583.

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Nonlinear time series modeling with a multilayer perceptron network is presented. An important aspect of this modeling is the model selection, i.e., the problem of determining the size as well as the complexity of the model. To overcome this problem we apply the predictive minimum description length (PMDL) principle as a minimization criterion. In the neural network scheme it means minimizing the number of input and hidden units. Three time series modeling experiments are used to examine the usefulness of the PMDL model selection scheme. A comparison with the widely used cross-validation techn

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Ravn-Højgaard, Signe. "Media policy in Greenland." Nordicom Review 42, s2 (2021): 36–52. http://dx.doi.org/10.2478/nor-2021-0016.

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Abstract This article describes the historical development of media policy in Greenland, and the shifts in the underlying normative and causal ideas that legitimise media policy. I argue that media policy reflects changes in Greenland's political system. Specifically, under colonial rule, Greenlandic media was state run and media was seen as an instrument to educate the population. Gradually, with the introduction of home rule, a paradigm shift took place, whereby media was seen as a vital instrument to strengthen Greenlandic language and identity. At the same time, normative ideas of media in

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40

Seex, Kevin A. "An anterior cervical retractor utilizing a novel principle." Journal of Neurosurgery: Spine 12, no. 5 (2010): 547–51. http://dx.doi.org/10.3171/2009.9.spine0955.

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The alarmingly high soft-tissue complication rates after anterior cervical surgery suggests that the design of current retractors is inadequate. A review of retractor design and consideration of new designs is worthwhile. The author reviewed the literature and the 7 described devices (Cloward, Caspar, Thompson-Farley, Tresserras, Ozer, Takayasu, and Oh devices). With the exception of Cloward/Caspar and Thomson-Farley systems, the author's search of the literature failed to disclose any independent review or investigations of the other retractors, suggesting that the use of these devices is lim

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Will, B., and M. Gerding. "Determination of the permittivity of soils by use of double transmission measurements." Advances in Radio Science 7 (May 18, 2009): 1–4. http://dx.doi.org/10.5194/ars-7-1-2009.

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Abstract. Delay time measurements, e.g. time domain reflectometry (TDR), are a well-established method for the measurement of permittivity of various materials, especially soils. However, common measurement systems only provide one average value of the dielectric constant along the length of the TDR probe. This contribution deals with an advanced application of the TDR principle, the so-called double transmission method, for the determination of the water content of soil along a probe. To apply the advanced TDR technique, a probe, realized by a combination of a transmission line and a dielectr

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Brem, Markus, and Thomas Tucha. "Transfer Pricing: Conceptual Thoughts on the Nature of the Multinational Firm." Vikalpa: The Journal for Decision Makers 31, no. 2 (2006): 29–44. http://dx.doi.org/10.1177/0256090920060202.

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This paper deploys Transaction Cost Economics (TCE) to elaborate on the shortcomings of ‘mainstream‘ transfer pricing in multinational firms. Departing from the notion that multinationals increasingly (re-)organize their business along multinational value chains irrespective of jurisdictional borders, this paper discusses the nature of the multinational firm and the problem of choosing the right intra-group (transfer) price. The mainstream transfer pricing approach derived from the Arm�s Length Principle (ALP) is deemed inappropriate for globally operating multinational enterprises (MNEs). Ref

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Ayvaz, Ednan. "Outsourcing as a solution of problems of transfer price in multiple companies: A case studyÇokuluslu şirketlerde transfer fiyatlandırması sorunlarının çözümü olarak dış kaynak kullanımı (outsourcing): Bir vaka çalışması." Journal of Human Sciences 14, no. 4 (2017): 4251. http://dx.doi.org/10.14687/jhs.v14i4.4963.

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The scope and complexity of international tax regulations on transfer pricing is largely focused on adhering to taxation rather than market competition. Outsourcing has been extensively described in order to comprehend it better for comparability functions and analysis, transfer pricing methods accepted by the OECD and the arm's length principle to identify similar transactions between independent parties. The aim of this study is to demonstrate the necessity of minimizing of the conflict between the tax auditors and multinational corporations and of the inefficiencies of tax rules and the arb

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Hardiyanto, Ivan. "PERMASALAHAN TRANSFER PRICING DALAM UNDANG-UNDANG PAJAK DI INDONESIA." Jurnal Magister Hukum ARGUMENTUM 6, no. 1 (2019): 1082–103. http://dx.doi.org/10.24123/argu.v6i1.1859.

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Transfer pricing is a company policy in determining transfer prices to other companies, but in practice transfer pricing is done in order to avoid taxes. At present Indonesia has not been able to overcome the issue of transfer pricing because the regulations and sanctions are still unclear. Businessmen as taxpayers need legal certainty in the context of tax planning and business competition, while the government also requires legal certainty to secure revenues from the tax sector. The legal vacuum created legal uncertainty for both parties so that it was not in harmony with the principle of ju

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Gubaidullin, Renat R., Aleksandr P. Kuzin, and Vladimir V. Kulakov. "Surfactant therapy in combination treatment of COVID-19 related acute respiratory distress syndrome." Remedium. Journal about the Russian market of medicines and medical equipment, no. 1 (2021): 50–56. http://dx.doi.org/10.21518/1561-5936-2021-1-50-56.

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ntroduction. The COVID-19 pandemic caused an outbreak of viral lung infections with severe acute respiratory syndrome complicated with acute respiratory failure. Despite the fact that the pandemic has a lengthened run, none of the therapeutic approaches have proved to be sufficiently effective according to the evidence-based criteria. We consider the use of surfactant therapy in patients with severe viral pneumonia and acute respiratory distress syndrome (ARDS) as one of the possible methods for treating COVID-19 related pneumonia. Objective. To prove the clinical efficacy and safety of orally

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Dumiter, Florin Cornel, and Ștefania Amalia Jimon. "Theoretical and Practical Assessments of Transfer Prices. Legal Evidence from Romanian Case Law." Journal of Legal Studies 26, no. 40 (2020): 1–18. http://dx.doi.org/10.2478/jles-2020-0008.

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AbstractTransfer pricing represents the mainstream agenda in the light of tax law, lato sensu, and international taxation, stricto sensu. At the international level, there can be an emphasis on several problems related to taxation: double taxation, double non – taxation, permanent establishment, business profits, residence criteria, arm's length principle, mutual agreement procedure, dispute resolution of tax conflicts. However, the problem of transfer pricing has more profound judicial and economic implications. The main objective of this paper is to evaluate and assess the underlying feature

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Kennel, Matthew B., Jonathon Shlens, Henry D. I. Abarbanel, and E. J. Chichilnisky. "Estimating Entropy Rates with Bayesian Confidence Intervals." Neural Computation 17, no. 7 (2005): 1531–76. http://dx.doi.org/10.1162/0899766053723050.

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The entropy rate quantifies the amount of uncertainty or disorder produced by any dynamical system. In a spiking neuron, this uncertainty translates into the amount of information potentially encoded and thus the subject of intense theoretical and experimental investigation. Estimating this quantity in observed, experimental data is difficult and requires a judicious selection of probabilistic models, balancing between two opposing biases. We use a model weighting principle originally developed for lossless data compression, following the minimum description length principle. This weighting yi

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Kobetsky, Michael. "The Transfer-Pricing Profit-Split Method After BEPS: Back to the Future." Canadian Tax Journal/Revue fiscale canadienne 67, no. 4 (2019): 1077–105. http://dx.doi.org/10.32721/ctj.2019.67.4.sym.kobetsky.

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In 2018, the Organisation for Economic Co-operation and Development/Group of Twenty (OECD/G20) Inclusive Framework on base erosion and profit shifting (BEPS): action 10 issued revised guidance on the transactional profit-split method. Regrettably, the revised guidance failed to provide the opportunity for the profit-split method to be more often the most appropriate transfer-pricing method. The revised guidance expressly states that the lack of comparable uncontrolled transactions, by itself, is not a basis for the use of the profit-split method. Under the former guidance, the profit-split met

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Peluso, Heather, John D. Cull, and Marwan S. Abougergi. "Race Impacts Outcomes of Patients With Firearm Injuries." American Surgeon 86, no. 9 (2020): 1113–18. http://dx.doi.org/10.1177/0003134820943558.

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Background To study the relationship between race and outcomes of patients with firearm injuries hospitalized in the United States. Methods The 2016 National Inpatient Sample was used. Patients were included if they had a principal diagnosis of firearm injury. Exclusion criteria were age <16 years and elective admissions. The primary outcome was in-hospital mortality. Secondary outcomes were morbidity (traumatic shock, prolonged mechanical ventilation, acute respiratory distress syndrome [ADRS], and ventilator-associated pneumonia [VAP]), and resource utilization (length of stay and total h

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Connolly, Luke. "Beckett's Broken Circle: A Literary Fractal." Journal of Beckett Studies 29, no. 2 (2020): 196–215. http://dx.doi.org/10.3366/jobs.2020.0311.

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This essay proposes that the picture of a broken circle encountered by Watt during the second part of his tale marks a crucial collision point between Beckett's literary and mathematical interests and triggers a process of fractal scaling self-similarity. Building on recent interest concerning the role of the mathematics and mathematical forms found in Beckett's work, I argue that the broken circle depicted in the picture from Watt is a geometric form which (re)appears within at least three interlocking scales throughout Beckett's novel-length prose: (i) its moment of arrival in the picture fr

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