A Critical Analysis of the Authorised OECD Approach and Its Implementation in German Tax Law under Specific Consideration of the Challenges Imposed to the PE Concept by the Digitalisation of the Economy
A Critical Analysis of the Authorised OECD Approach and Its Implementation in German Tax Law under Specific Consideration of the Challenges Imposed to the PE Concept by the Digitalisation of the Economy
This book provides a comprehensive analysis of the rules governing the taxation of permanent establishments as implemented in the OECD Model Tax Convention and German national tax law. Deviations between the OECD approach and the German approach are identified and modifications to the rules as a result of the Base Erosion and Profit Shifting (BEPS) project are examined. Moreover, challenges imposed to the PE concept as a result of the digitalisation of the economy are identified and discussed. Against this background, the Pillar One Blueprint proposing a long-term solution to overcome the tax challenges arising from the digitalisation of the economy is presented and assessed against widely accepted overarching principles of tax policy.
Research Paper (undergraduate) from the year 2012 in the subject Politics - Topic: Peace and Conflict, Security, grade: 1,0, Ewha Womans University (Graduate School of International Studies), course: International Negotiations, language: English, abstract: Throughout history there have been many attempts to establish peace between Israel and Palestine but all of these attempts were to no avail. This term paper will examine the underlying problem why all these attempts could not lead to a mutually satisfactory solution and will then describe what needs to be done in order to establish a new and sustainable peace agreement between Israel and Palestine. To do so this paper firstly illustrates the historical background of previous peace negotiations before describing the complex relationship of Israel and Palestine on an internal, regional and external level. It will then look at the opposed positions of both parties and illustrates to what extent the model of the Prisoner’s Dilemma can explain the situation that both sides are facing. Based on these findings ways how to potentially resolve this dilemma will be presented. The most promising solution of a Hegemonic Coalition that can put pressure on both parties to negotiate with each other over interests rather than positions will be explained in detail. Especially the framework under what conditions the negotiations should take place to avoid mistakes made by the Oslo peace negotiations will be addressed. Under consideration of that framework this paper develops a potential solution how the agreement between Israel and Palestine could look like to achieve peace between both parties. The Israel-Palestine peace process can be seen as a series of attempts to establish a lasting end to the Israeli-Palestinian conflict. Some of these attempts were more promising than others but until now none of them could establish peace between both parties.6 The decision tree in the appendix (Figure 1) helps to give a short overview of the main stages taken towards peace in the region. Throughout that paper some of these stages will need to be examined in further detail but for now this overview is sufficient to see that negotiations between both parties continuously failed mainly due to the unstable political environment within Israel and Palestine.
A Critical Analysis of the Authorised OECD Approach and Its Implementation in German Tax Law under Specific Consideration of the Challenges Imposed to the PE Concept by the Digitalisation of the Economy
A Critical Analysis of the Authorised OECD Approach and Its Implementation in German Tax Law under Specific Consideration of the Challenges Imposed to the PE Concept by the Digitalisation of the Economy
This book provides a comprehensive analysis of the rules governing the taxation of permanent establishments as implemented in the OECD Model Tax Convention and German national tax law. Deviations between the OECD approach and the German approach are identified and modifications to the rules as a result of the Base Erosion and Profit Shifting (BEPS) project are examined. Moreover, challenges imposed to the PE concept as a result of the digitalisation of the economy are identified and discussed. Against this background, the Pillar One Blueprint proposing a long-term solution to overcome the tax challenges arising from the digitalisation of the economy is presented and assessed against widely accepted overarching principles of tax policy.
Die Faszination des Führerbunkers ist ungebrochen. Besucher Berlins suchen immer wieder nach Resten. Vergeblich: Es ist einfach nichts zu sehen.Das Buch zeigt, wo der Bunker lag und was an seiner Stelle heute steht. Es erläutert die Baugeschichte der Betonhöhle, schildert das Drama des Untergangs anhand von Zeitzeugenberichten und geht auf die Versuche ein, den Bunker zu beseitigen. Fotos und genaue Pläne veranschaulichen die Lage und das Leben im Bunker.Der Geschichtsjournalist Sven Felix Kellerhoff beschäftigt sich seit Jahren mit dem Nationalsozialismus. Er stellt die wichtigsten Quellem und Fakten über den Führerbunker zusammen-von Baubeginn bis heute. September 2003 erschien der Band in deutsch.
The subject of Euro-regions is topical and controversial, but those of Central Europe have been neglected by scholars. 'Central Europe' is demarcated variously according to geographical, political, economic and cultural criteria. The subjective term 'region' and its theoretical implications are considered in the opening chapters. The empirical section ranges in time from the appearance of the German 'stern' duchies in the Middle Ages to cross-border cooperation in the Oder area today, and geographically from Baden-Wurttemberg in the west to Transylvania, Carpatho-Ruthenia and the Kaliningrad enclave in the east. The authors all highlight the complex problems of local identity and the centrality of culture in shaping notions of the region.
While standardization has empowered the software industry to substantially scale software development and to provide affordable software to a broad market, it often does not address smaller market segments, nor the needs and wishes of individual customers. Software product lines reconcile mass production and standardization with mass customization in software engineering. Ideally, based on a set of reusable parts, a software manufacturer can generate a software product based on the requirements of its customer. The concept of features is central to achieving this level of automation, because features bridge the gap between the requirements the customer has and the functionality a product provides. Thus features are a central concept in all phases of product-line development. The authors take a developer’s viewpoint, focus on the development, maintenance, and implementation of product-line variability, and especially concentrate on automated product derivation based on a user’s feature selection. The book consists of three parts. Part I provides a general introduction to feature-oriented software product lines, describing the product-line approach and introducing the product-line development process with its two elements of domain and application engineering. The pivotal part II covers a wide variety of implementation techniques including design patterns, frameworks, components, feature-oriented programming, and aspect-oriented programming, as well as tool-based approaches including preprocessors, build systems, version-control systems, and virtual separation of concerns. Finally, part III is devoted to advanced topics related to feature-oriented product lines like refactoring, feature interaction, and analysis tools specific to product lines. In addition, an appendix lists various helpful tools for software product-line development, along with a description of how they relate to the topics covered in this book. To tie the book together, the authors use two running examples that are well documented in the product-line literature: data management for embedded systems, and variations of graph data structures. They start every chapter by explicitly stating the respective learning goals and finish it with a set of exercises; additional teaching material is also available online. All these features make the book ideally suited for teaching – both for academic classes and for professionals interested in self-study.
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