Download or read book The Future of the Profit Split Method written by Gabriella Cappelleri and published by Kluwer Law International B.V.. This book was released on 2020-11-23 with total page 341 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Future of the Profit Split Method Edited by Robert Danon, Guglielmo Maisto, Vikram Chand & Gabriella Cappelleri Among the various transfer pricing methods, the profit split method (PSM) is under the spotlight after the OECD’s Base Erosion and Profit Shifting (BEPS) project. However, both expert analysis and experience indicate that this method is not straightforward either for taxpayers to apply or for tax administrations to evaluate. In this thorough and detailed commentary – the first book to analyse this increasingly adopted transfer pricing method – notable scholars and practitioners working in the international tax community express their views on the method, answering some unresolved questions and highlighting issues that are still open and pending, especially in light of the digitalization of the economy. Crucial issues covered by the contributors include the following: choice of the appropriate splitting factors, their relative weights, and valuation of the contributions; uncertainties and outcomes potentially not aligned with the arm’s-length standard; possible role of assessments made by the European Commission on State aid; nexus with the work done by the EU Joint Transfer Pricing Forum; impact of profit split on indirect taxes (VAT/customs tax/excise tax); and application to digital business models and, in general, to the digitalized economy. Moreover, relevant experience of applying this method in France, Germany, Italy, Spain, Switzerland, the United Kingdom, and the United States is provided. A concluding chapter also deals with selected industry experiences. Due to a high level of uncertainty in alignment with international guidance in the application of the PSM – and to the underdeveloped nature of current literature on the subject – there is a need for this book because both tax administrations and taxpayers, going forward, will apply the PSM extensively. The book is highly relevant for policymakers, tax administrations, practitioners and academics engaged in the areas of international taxation, transfer pricing and tax policy.

Download or read book Transnational accounting Transacc 2 IASC USA written by Dieter Ordelheide and published by . This book was released on 1995 with total page 1644 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Bulletin de renseignements documentaires written by and published by . This book was released on 1983 with total page 630 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Dokumentationsbulletin written by and published by . This book was released on 1983 with total page 378 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book A Frequency Dictionary of Spanish written by Mark Davies and published by Routledge. This book was released on 2017-12-12 with total page 1457 pages. Available in PDF, EPUB and Kindle. Book excerpt: A Frequency Dictionary of Spanish has been fully revised and updated, including over 500 new entries, making it an invaluable resource for students of Spanish. Based on a new web-based corpus containing more than 2 billion words collected from 21 Spanish-speaking countries, the second edition of A Frequency Dictionary of Spanish provides the most expansive and up-to-date guidelines on Spanish vocabulary. Each entry is accompanied with an illustrative example and full English translation. The Dictionary provides a rich resource for language teaching and curriculum design, while a separate CD version provides the full text in a tab-delimited format ideally suited for use by corpus and computational linguistics. With entries arranged both by frequency and alphabetically, A Frequency Dictionary of Spanish enables students of all levels to get the most out of their study of vocabulary in an engaging and efficient way.

Download or read book Bibliographic Guide to Law written by and published by . This book was released on 1987 with total page 826 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Bollettino di documentazione A written by and published by . This book was released on 1983 with total page 738 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book M Health written by Robert Istepanian and published by Springer Science & Business Media. This book was released on 2007-01-04 with total page 619 pages. Available in PDF, EPUB and Kindle. Book excerpt: M-health can be defined as the ‘emerging mobile communications and network technologies for healthcare systems.' This book paves the path toward understanding the future of m-health technologies and services and also introducing the impact of mobility on existing e-health and commercial telemedical systems. M-Health: Emerging Mobile Health Systems presents a new and forward-looking source of information that explores the present and future trends in the applications of current and emerging wireless communication and network technologies for different healthcare scenaria. It also provides a discovery path on the synergies between the 2.5G and 3G systems and other relevant computing and information technologies and how they prescribe the way for the next generation of m-health services. The book contains 47 chapters, arranged in five thematic sections: Introduction to Mobile M-health Systems, Smart Mobile Applications for Health Professionals, Signal, Image, and Video Compression for M-health Applications, Emergency Health Care Systems and Services, Echography Systems and Services, and Remote and Home Monitoring. This book is intended for all those working in the field of information technologies in biomedicine, as well as for people working in future applications of wireless communications and wireless telemedical systems. It provides different levels of material to researchers, computing engineers, and medical practitioners interested in emerging e-health systems. This book will be a useful reference for all the readers in this important and growing field of research, and will contribute to the roadmap of future m-health systems and improve the development of effective healthcare delivery systems.

Download or read book South Brazil written by Omer W. Herrmann and published by . This book was released on 1940 with total page 56 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Economical Notes on Brazil written by Brazil. Ministério da Agricultura. Serviço de Informações and published by . This book was released on 1916 with total page 100 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book A Frequency Dictionary of Contemporary American English written by Mark Davies and published by Routledge. This book was released on 2013-08-21 with total page 369 pages. Available in PDF, EPUB and Kindle. Book excerpt: First published in 2010 . Routledge is an imprint of Taylor & Francis, an informa company.

Download or read book Work Relief in New York State 1931 1935 written by Alexander Leopold Radomski and published by . This book was released on 1947 with total page 352 pages. Available in PDF, EPUB and Kindle. Book excerpt: Examines new phases during the 1930's of governmental provision for the economically insecure including state grants-in-aid for emergency employment relief and the creation of the Federal Emergency Relief Administration.

Download or read book Insurgent Cuba written by Ada Ferrer and published by Univ of North Carolina Press. This book was released on 2005-10-12 with total page 288 pages. Available in PDF, EPUB and Kindle. Book excerpt: In the late nineteenth century, in an age of ascendant racism and imperial expansion, there emerged in Cuba a movement that unified black, mulatto, and white men in an attack on Europe's oldest empire, with the goal of creating a nation explicitly defined as antiracist. This book tells the story of the thirty-year unfolding and undoing of that movement. Ada Ferrer examines the participation of black and mulatto Cubans in nationalist insurgency from 1868, when a slaveholder began the revolution by freeing his slaves, until the intervention of racially segregated American forces in 1898. In so doing, she uncovers the struggles over the boundaries of citizenship and nationality that their participation brought to the fore, and she shows that even as black participation helped sustain the movement ideologically and militarily, it simultaneously prompted accusations of race war and fed the forces of counterinsurgency. Carefully examining the tensions between racism and antiracism contained within Cuban nationalism, Ferrer paints a dynamic portrait of a movement built upon the coexistence of an ideology of racial fraternity and the persistence of presumptions of hierarchy.

Download or read book Freedom Papers written by Rebecca J. Scott and published by Harvard University Press. This book was released on 2012-02-27 with total page 260 pages. Available in PDF, EPUB and Kindle. Book excerpt: Around 1785, a woman was taken from her home in Senegambia and sent to Saint-Domingue in the Caribbean. Those who enslaved her there named her Rosalie. Her later efforts to escape slavery were the beginning of a family's quest, across five generations and three continents, for lives of dignity and equality. Freedom Papers sets the saga of Rosalie and her descendants against the background of three great antiracist struggles of the nineteenth century: the Haitian Revolution, the French Revolution of 1848, and the Civil War and Reconstruction in the United States. Freed during the Haitian Revolution, Rosalie and her daughter Elisabeth fled to Cuba in 1803. A few years later, Elisabeth departed for New Orleans, where she married a carpenter, Jacques Tinchant. In the 1830s, with tension rising against free persons of color, they left for France. Subsequent generations of Tinchants fought in the Union Army, argued for equal rights at Louisiana's state constitutional convention, and created a transatlantic tobacco network that turned their Creole past into a commercial asset. Yet the fragility of freedom and security became clear when, a century later, Rosalie's great-great-granddaughter Marie-José was arrested by Nazi forces occupying Belgium. Freedom Papers follows the Tinchants as each generation tries to use the power and legitimacy of documents to help secure freedom and respect. The strategies they used to overcome the constraints of slavery, war, and colonialism suggest the contours of the lives of people of color across the Atlantic world during this turbulent epoch.

Download or read book Ever Faithful written by David Sartorius and published by Duke University Press. This book was released on 2014-01-10 with total page 333 pages. Available in PDF, EPUB and Kindle. Book excerpt: Known for much of the nineteenth century as "the ever-faithful isle," Cuba did not earn its independence from Spain until 1898, long after most American colonies had achieved emancipation from European rule. In this groundbreaking history, David Sartorius explores the relationship between political allegiance and race in nineteenth-century Cuba. Challenging assumptions that loyalty to the Spanish empire was the exclusive province of the white Cuban elite, he examines the free and enslaved people of African descent who actively supported colonialism. By claiming loyalty, many black and mulatto Cubans attained some degree of social mobility, legal freedom, and political inclusion in a world where hierarchy and inequality were the fundamental lineaments of colonial subjectivity. Sartorius explores Cuba's battlefields, plantations, and meeting halls to consider the goals and limits of loyalty. In the process, he makes a bold call for fresh perspectives on imperial ideologies of race and on the rich political history of the African diaspora.

Download or read book Paying the Price of Freedom written by Christine Hünefeldt and published by Univ of California Press. This book was released on 2024-06-14 with total page 282 pages. Available in PDF, EPUB and Kindle. Book excerpt: Christine Hünefeldt documents in impressive, moving detail the striving and ingenuity, the hard-won triumphs and bitter defeats of slaves who sought liberation in nineteenth-century urban Peru. Drawing on judicial, ecclesiastical, and notarial records—including the testimony of the slaves themselves—she uncovers the various strategies slaves invented to gain their freedom. Hünefeldt pays particular attention to marriage relations and family life. Slaves used their family solidarity as a strategy, while slaveowners used the conflicts within families to prevent manumission. The author's focus on gender relations between slaveowners and slaves, as well as between slaves, is particularly original. Her eye for ethnographic detail and her perceptive reading of the documentary evidence make this book a rich and important contribution to the study of slavery in Latin America. This title is part of UC Press's Voices Revived program, which commemorates University of California Press’s mission to seek out and cultivate the brightest minds and give them voice, reach, and impact. Drawing on a backlist dating to 1893, Voices Revived makes high-quality, peer-reviewed scholarship accessible once again using print-on-demand technology. This title was originally published in 1994.

Download or read book Constitution of the United States of Brazil written by Brazil and published by . This book was released on 1891 with total page 40 pages. Available in PDF, EPUB and Kindle. Book excerpt: