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The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS—Some Thoughts on Complexity and Uncertainty

treaty. Article 6 reflects a minimum standard for protection against the abuse of treaties. A party may, therefore, reserve the right for the text not to apply to an existing tax treaty only if that treaty already contains preamble language that describes the same intent or that applies more broadly ( OECD 2016 ; see para. 85). Article 7 of the MLI presents an antiabuse provision in the form of the so-called principal purpose test (PPT), For an analysis of the PPT clause, see Chand (2018) . which since the 2017 update is also included in Article 29(9) of the OECD

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Basic Income—an early Icelandic experiment

1 Introduction Most developed nations provide assistance for persons with reduced ability to support themselves economically because of age, sickness, or physical or mental disability, either by direct financial transfers or by participation in the costs of basic necessities such as housing. The grant and subvention systems are, as a rule, complicated and nontransparent. New reforms and new reform ideas are regularly presented under the slogan of simplification of the existing “system.” The idea of “basic income” is one such reform idea. “Basic income

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Laffer Curves and Home Production

equilibrium unemployment. He finds that home production brings the basic search equilibrium model of labor market closer to reality so that the neutrality result of proportional tax rate on employment disappears with the introduction of home production. Engström et al . (2001) explore tax differentiation between (physical) goods and services in a labor market search and matching model with home production. The authors show that a tax cut on service sector reduces unemployment and also that the introduction of sectoral tax differentiation with lower tax on services is

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The taxpayer’s intentions: Subjective prerequisites in tax law

companies and subsidiaries and the Anti-Tax Avoidance Directive (ATAD). See Council Directive (EU) 2015/121 of 27 January 2015 amending Directive 2011/96/EU on the common system of taxation applicable in the case of parent companies and subsidiaries of different Member States, and Council Directive (EU) 2016/1164 of 12 July 2016 laying down rules against tax avoidance practices that directly affect the functioning of the internal market. In addition, a test of “principal purpose” is part of the multilateral instrument, based on the Base Erosion Profit Shifting (BEPS

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The Nordic model: 25 years of drawing the line between earned and capital income in Finland

system has been that because of the high marginal tax rates of earned income, it has been tempting to try to shift the fruit of work into the company’s shells and thus further within the capital income taxation. It can also be argued that the practice in case law and taxation has for a long time been quite permissive regarding the use of the company form. However, the legislator has intervened in some extreme situations through special tax legislation. The limits of the acceptable tax planning were tested, for instance, in the case KHO 2008:6, which is described in

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Taxation of Swedish Firm Owners: The Great Reversal from the 1970s to the 2010s

methods are tested ( Mantzavinos (2001) ). More radical innovations frequently emanate from smaller firms ( Baumol (2010) ). These firms, particularly the successful ones, are frequently spinoffs from large firms ( Klepper (2016) ). Thus, new technology is often developed, implemented, commercialized, and widely disseminated by new entrepreneurial firms. Acquiring new firms is also a way for leading firms to gain access to new technology. The most important factor behind job dynamics is not firm size but firm age ( Coad et al. (2014) ; Haltiwanger et al. (2017

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Study of Operational Capabilities of Chemical Sources of Electricity Influenced by Ambient Factors

References [1] Testing the effects of changes in temperature - BDS EN 60068-2-14:2009, Test N: Change of temperature [2] Testing the effects of reduced atmospheric pressure - BDS EN 60068-2-13:2003, Test М: Low air pressure

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Comunication Interface Prototype Used for Data Transmission at Electric Systems

References [1] Stroia M.D.,Anghel-Drugarin C. V., Issues of semi-automatic air processing using a DCS system , Scientific Conference SysStruc 2017, pp 380-385, Resita, Romania, 2017. [2] Novăcescu F., Haţiegan C., Răduca M., Răduca E., Pop N., Nedeloni M., A New Method for Testing the No-Load Work of an Electric One-Phase Transformer Using The Graphical Programming , Scientific Bulletin of “Politehnica” University of Timişoara, vol. 57 (71) 2, 2012. [3] Răduca E., PăunA. F., Răduca M., Haţiegan C., Drăghici S, Rudolf C., Candea L., Command

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Extracurricular Sport Activities and their Importance in Children Socialization and Integration Process

R eferences Arnold, P. (1979). Meaning in movement, sport and physical education , London: Heinemann. Dragnea, A. (2000). Teoria educaţiei fizice şi sportului , Bucureşti: Editura Cartea Școlii. Epuran, M. (1998). Aspecte ale socializării în sport, Conferinţa Știinţifică Naţională a CSSR. Activităţile fizice şi sportive – socializare şi performanţă , Bucureşti. Haywood, K. & Getchell, N. (2001). Life span motor development (3 rd edition), Champaign, IL: Human Kinetics. Magnane, G. (1964), Sociologie du sport , Paris: Gallimard

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Behavioural and Motivational Factors of Individual’s Behaviour in Emergency Situations

Abstract

In the presented research project we observed the influence of physical culture on the level of security culture, on personality, behavioural and axiological determinants of individual’s functioning in the context of physical activity under threatening conditions. We focused on testing of a group of people who were trained to act in the roles closely professionally related to security, including to hand-to-hand combat. It was assumed that their personality will develop in the direction of specific characteristics associated with security culture and display these characteristics. Considering this issue we took a securitological perspective focusing in particular on the first (of three: mental, organizational and material) dimension of security culture. In the research we referred the issue of personality and normative modifications of behaviour. We also touched on the subject of interpretation of people’s behaviour in the axiological categories which are essential for the full image of martial arts

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