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This book is a history of ancient Greek and Roman professionals: doctors, seers, sculptors, teachers, musicians, actors, athletes and soldiers. These individuals were specialist workers deemed to possess rare skills, for which they had undergone a period of training. They operated in a competitive labour market in which proven expertise was a key commodity. Success in the highest regarded professions was often rewarded with a significant income and social status. Rivalries between competing practitioners could be fierce. Yet on other occasions, skilled workers co-operated in developing associations that were intended to facilitate and promote the work of professionals. The oldest collegial code of conduct, the Hippocratic Oath, a version of which is still taken by medical professionals today, was similarly the creation of a prominent ancient medical school. This collection of articles reveals the crucial role of occupation and skill in determining the identity and status of workers in antiquity.
Dengue virus, the cause of tens of millions of cases of dengue annually, and Zika virus, the cause of recent explosive epidemics across Latin America associated with congenital defects and microcephaly, are pathogens with a significant burden on human health and well-being. Beyond their toll on health, these flaviviruses, as the genus is called, share a common evolutionary origin, have each adapted to replicate efficiently in the human host, and are spread by similar species of mosquitoes. These commonalities belie important clinical, epidemiological, and immunological differences between them that necessitate continued research into their respective biology. Moreover, these commonalities and differences have real consequences for control efforts in affected areas around the world.
Classroom management remains one of the greatest challenges for teachers. In this study, with 52 general and special education teachers, we examined the effectiveness of a screencast-delivered professional development program focused on classroom management practices in the first 3 days of school. Results suggest that after participating in the program, teachers report a positive change to the start of their school year across 12 different areas. Further, teachers’ classroom management self-efficacy increased significantly after completing the program, and there was a significant correlation (r = .41) between increases in classroom management self-efficacy and rate of implementation of new practices. Implications for practitioners and future directions for research are included.
Migration is in the news every day. Whether it be the plight of refugees fleeing Syria, or the outbreak of the Zika virus across Latin America, the modern world is fundamentally shaped by movement across borders. Migration, arising from the 2018 Darwin College Lectures, brings together eight leading scholars across the arts, humanities, and sciences to help tackle one of the most important topics of our time. What is migration? How has it changed the world? And how will it shape the future? The authors approach these questions from a variety of perspectives, including history, politics, epidemiology, and art. Chapters related to policy, as well as those written by leading journalists and broadcasters, give perspective on how migration is understood in the media, and engage the public more widely. This interdisciplinary approach provides an original take on migration, providing new insights into the making of the modern world.
Considers bilateral tax administration issues. Identifies the core areas of tax administration (provision of information, assessment, dispute resolution and collection of tax) and tax treaty rules targeted at three of these. Discusses automatic exchange of information, spontaneous exchange of information and information on request. Notes the importance of the 1988 multilateral convention on assistance in tax matters and developments and the BEPS project including the common reporting standard, country-by-country reporting and the tax inspectors without borders project. With regard to dispute resolution, the mutual agreement procedure in tax treaties is discussed as a logical extension to a domestic binding rulings system. The extension of that procedure to arbitration of tax disputes is considered, particularly the push toward arbitration under the BEPS project and the MLI. Finally, assistance in the collection of tax by one tax authority on behalf of another tax authority is discussed. The discussion considers the recent break down of an original resistance to assistance in collection and the importance of the 1988 multilateral convention is again noted. Relevant EU Law is discussed, including the Directive on Cooperation in the Field of Taxation, Directive on Dispute Resolution Mechanisms and Directive on Mutual Assistance for Recovery of Tax Claims.
Considers source country taxing rights under tax treaties. Initially follows the schedular approach of the OECD Model, the distributive provisions of which give source countries full taxing rights (immovable property, business, employment), limited taxing rights (dividends, interest) or no taxing rights (royalties, capital gains, other income). Source country rights, even if full, may be limited by treaty nondiscrimination provisions, which are compared to EU fundamental freedoms. Particular attention is devoted to taxation of business profits, including source country subsidiaries and permanent establishments. Problems inherent in the dual fictions of the authorised OECD approach to taxation of permanent establishments are noted. The second heading considers source country deductibility of payments made to non-residents. Deductibility of these payments can lead to base erosion while denying deductions raises issues of discrimination. The final heading first considers two fundamental features of payments that are critical for source country taxation; quantification and characterisation. Quantification raises issues of transfer pricing. Varying taxation based on characterisation raises issues of fungibility of payments, particularly in the definitions of ‘dividends’, ‘interest’ and ‘royalties’. These issues crossover in excessive interest payments and thin capitalisation. Finally, the chapter deals with reconciliation of provisions under the schedular approach.
This book has set about identifying, explaining, categorising and analysing, at a basic level, the rules that govern income taxation of international commercial transactions. The lasting impression is one of various sets of overlaying, largely uncoordinated and complex measures that deal with some matters (not necessarily the most important) better than others.
Focuses on cross-border acquisitions, mergers and reconstructions, particularly those involving permanent establishments and subsidiaries. Previous chapters presume a stable jurisdiction to tax on the basis of source or residence. This chapter considers changes of source and changes of residence. There are limited ways in which a source of income may be changed. It may be created, such as where assets are transferred to a new subsidiary or permanent establishment. Source may be terminated, such as where an existing subsidiary or permanent establishment is liquidated. A source may be transferred, such as on the sale of a subsidiary or permanent establishment. Finally, a source of income may be varied, such as on the conversion of a permanent establishment into a subsidiary, conversion of a subsidiary into a permanent establishment or in cases of mergers and demergers involving corporate groups. Changes of residence are simpler. The tax consequences of commencing residence or terminating residence are considered. In all these matters, the dearth of tax treaty rules is compared with the position under EU Law and particularly the Mergers Directive.
Considers tax treaty limitations on residence country taxing rights, including the obligation to provide foreign tax relief and methods of relief for double taxation, especially the exemption method and credit method. The treaty obligation is compared to the limited approach under EU Law. The separate legal identity of corporations causes two problems for foreign tax relief. First, economic double taxation of corporate income results if the tax charge cascades on distributions up a chain of corporations. Methods of underlying foreign tax relief or indirect foreign tax relief are considered. Second, controlled foreign corporations may be used as a dividend trap or method of avoiding tax. Rules to address these are discussed. The second heading considers methods of calculating foreign income and the impact on foreign tax relief. Here there are few rules in tax treaties but burgeoning EU case law. Allocating expenses between foreign and domestic activities is critical when calculating the volume of exempt foreign income or, under the foreign tax credit method, the limitation on credit. Expenses may produce losses. The treatment of foreign losses on domestic income and domestic losses on foreign income are considered. Finally, cross-border intragroup losses under various systems of group relief are considered.
Considers the limited scope of tax treaties (i.e., things that tax treaties do not cover). Initially continues in a bilateral scenario investigating mismatches between source and residence countries regarding the fundamental features of payments. These may cause income to disappear or be recognised twice. Particularly considers hybrid entities, hybrid financial instruments, corresponding adjustments and secondary adjustments, as well as BEPS recommendations regarding hybrid mismatch arrangements. The second heading discusses limits inherent in the bilateral nature of tax treaties, particularly when three or more countries are involved (triangular situations). Tax treaties seek to resolve issues of source and residence in bilateral situations. Triangular situations can produce a mismatch of source of income or mismatch of residence of entities. Dual source of income and dual residence are discussed. Finally, re-sourcing and re-characterisation using intermediaries in third countries is considered. Two issues here are use of tax havens and treaty shopping, which are considered from the perspectives of intermediate, source and residence countries. Discusses rules on beneficial ownership, limitation of benefits, most favoured nation and the principal purpose test in tax treaty GAARs, as well as offshore indirect transfers. Responses under the BEPS project are compared to expanding EU rules and case law.
Discusses fundamentals of income tax that are relevant to international commercial transactions, including identification of the fundamental features of payments as the building blocks of the income tax base. Considers the major sources of rules for taxation of international commercial transactions, including the OECD Model, the UN Model, EU direct tax law and their interaction with domestic tax rules. This consideration includes the coverage of tax treaties, their status, whether a dualist or monist approach to implementation is adopted as well as treaty override and treaty underride. There is a particular focus on how countries might implement rules so as to avoid the restrictions of tax treaties. The chapter moves to consider the interpretation of tax treaties including the relevance of the Vienna Convention on the interpretation of treaties and the status and relevance of the Commentary on the OECD Model. The abuse of tax treaties is also considered including its link with interpretation of tax treaties, the specific tax treaty GAAR based on principal purpose test and the interaction between tax treaties and domestic anti-abuse rules. In all of these matters there is a comparison with EU direct tax law, its implementation and interpretation.