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This interim report of the OECD/G20 Inclusive Framework on BEPS is a follow-up to the work delivered in 2015 under Action 1 of the BEPS Project on addressing the tax challenges of the digital economy. It sets out the Inclusive Framework’s agreed direction of work on digitalisation and the international tax rules through to 2020. It describes how digitalisation is also affecting other areas of the tax system, providing tax authorities with new tools that are translating into improvements in taxpayer services, improving the efficiency of tax collection and detecting tax evasion.
The Routledge Spanish Bilingual Dictionary of Psychology and Psychiatry contains over 100,000 entries making this the most comprehensive and up-to-date dictionary of its kind. The Dictionary provides concise, comprehensive and current coverage of every word or phrase used in the study and practice of psychiatry and psychology. This valuable reference tool covers all disciplines and sub-disciplines, both research-based and clinical. This is a vital resource to those in the healthcare professions, to academicians and to those who work in translation and/or interpretation, healthcare and the law who are in contact with the English and Spanish speaking communities.
In today's "global village", nearly 450 million people speak English while another 350 million speak Spanish. The United States alone, with its more than 22 million Hispanic Americans, is now considered by many to be a bilingual society. As the practice of law and the resolution of legal issues, to a great extent, is all about precise communication, the impact of this on legal and business professionals is obvious - Spanish/English, English/Spanish translations are fast becoming an indispensable component of any thriving law practice or business, be it a small company or a multinational corporation. Translations are now routinely required for trials, contracts, real estate and financial transactions, and in many other situations. Clearly then, the need for a comprehensive bilingual reference such as this one has never been greater. Wiley's English/Spanish and Spanish/English Legal Dictionary offers comprehensive, up-to-date coverage of more than 40,000 essential words and phrases spanning all legal disciplines and subdisciplines including construction, real estate, insurance, business, trial, environmental law, intellectual property, family law, and more. It was written by a professional translator in collaboration with an advisory committee comprising attorneys from some of the most prominent firms in the international legal community. Featuring an extremely user-friendly format, the Dictionary was designed for quick reference. It directs you instantly to the precise equivalent you need without first "rerouting" you through a maze of other irrelevant terms and phrases. Gender neutral equivalents are provided, and in cases where the nongender neutral term is the norm, both are given.Wiley's English/Spanish and Spanish/English Legal Dictionary puts all important English and Spanish legal terms at the fingertips of attorneys, businesspeople, paralegals, and law students. It belongs on the shelves of law firms, libraries, businesses, and international agencies. It is also an essential communications tool for translators, interpreters, and civil servants.
A new edition of the preeminent work on the permanent establishment (PE) is a major event in tax law scholarship. Taking into account changes in judicial and administrative practice as well as the Organisation for Economic Co-operation and Development’s (OECD’s) and the United Nation’s (UN’s) work in the three decades since the first edition, the present study brings the analysis up to date with the current internationally accepted interpretation of PE. The analysis is based on more than 720 cases from more than 20 countries, in addition to the OECD and UN model treaties and more than 630 books, articles, and official documents. The increased significance of the digital economy has rendered the traditional concept of PE inadequate for the allocation of taxing jurisdiction over the modern, mobile or digital international business. The author’s in-depth analysis explains the legal elements of the PE principle with attention to their continuing benefit and their shortcomings: criteria defining a PE- place of business, location, right of use, duration, business connection, business activity, ordinary course of business; evidence of a right of use to a place of business; business activities included in the PE concept of the tax treaties; identification of projects offshore and onshore; UN model treaty deviations from the OECD agency clause; distinction between jurisdictions with significant natural resources and countries possessing the capital, technology and know-how necessary to explore and exploit these resources; and how policies in each country may erode the PE concept. The book provides many synopses of court decisions and administrative rulings upon which the analysis is based. In addition to cases previously published in law reports and other publications, a number of unpublished decisions are included. A key word index makes it easy to find what is needed in any particular matter. The PE principle, in one version or another, is used in several thousand tax treaties in force today. This updated comprehensive study reveals the obligations imposed through the use of PE in tax treaties and will continue to be of immeasurable value to tax practitioners and scholars worldwide. In addition, the discussion of whether the notion of PE is an appropriate criterion for taxing jurisdiction in international fiscal law today provides authoritative and insightful food for thought.
The works of Makoto Sei Watanabe combine the functionality of aesthetic experience and the calculated organization of structures with the evocation of deep ancestral memories.
Includes text, vocabulary lists, and comprehension questions designed to acquaint students with the history of Africa.
City planning is a concept which usually covers the wide range of events, processes and developments taking place in our cities, but individual plans and designs cannot do justice to the complex realities of the city. In "Induction Cities" the author aims to take the reader beyond our traditional understanding of city design to redefine our perception of design in this context. With the assistance of computers, a dynamic mechanism will be created which generates a result corresponding to the specific conditions and requirements stipulated. By this form of "meta-design" a greater degree of freedom is obtained than the conventional design methods provide. In this publication, this new theory and process is analysed, looking at the first computer-generated architecture in the world, the underground station "Iidabashi"in Tokyo. Makoto Sei Watanabe studied architecture and worked in the office of Arata Isozaki in Tokyo. In 1984 he founded his own architectural office which has realised numerous projects.
Traces the development of coffee-houses and their gradual evolution into the typical English institution, the club.
In this collection of essays, a group of distinguished American and British historians explores the relations between the American Revolution and its predecessors, the Puritan Revolution of 1641 and the Glorious Revolution of 1688. Originally published in 1980. The Princeton Legacy Library uses the latest print-on-demand technology to again make available previously out-of-print books from the distinguished backlist of Princeton University Press. These editions preserve the original texts of these important books while presenting them in durable paperback and hardcover editions. The goal of the Princeton Legacy Library is to vastly increase access to the rich scholarly heritage found in the thousands of books published by Princeton University Press since its founding in 1905.