The Multilateral Instrument (MLI) proposed in OECD BEPS Action 15 will lead to the modification of numerous tax treaties. As tax treaties can have different wording, terminology and structure, a great challenge is to find a proper way to accomplish their modification without distorting the underlying framework or triggering undesirable effects.
This book analyses the MLI, which was signed by over seventy jurisdictions on 7 June 2017. The topics covered include:
- the procedural mechanisms on how the new measures to prevent base erosion and profit shifting (BEPS) will interact with and complement existing tax treaties;
- the scope of the MLI in order to ascertain which tax treaties and taxes are covered;
- the interpretation of terms used in the MLI and the relationship between the languages used in the MLI and in the particular tax treaties;
- the implementation of the minimum standard through the MLI, as well as how states can exercise various options offered by the MLI and reserve the right not to apply certain provisions of the MLI;
- the legal consequences of the exercise of options and reservations for the other states;
- the notification procedure through which states declare their choices; and
- the possibilities and procedure for withdrawal from the obligations entered into upon signing the MLI.
Finally, the book discusses whether the mechanism of the MLI can serve as a role model for future changes to the OECD Model Convention.
The book incorporates the analyses of leading scholars and practitioners dealing with international tax matters. Critical insights are offered for academics, practitioners, tax officials and judges who deal with or are interested in the field of international taxation.
Описание: Words of Caution for Those Who Think They're Beyond Temptation
Too many Christians, especially those in ministry, believe they are untouchable--that they're too faithful to fall or too spiritual to give in to temptation. They deny any sort of weakness, fail to draw proper boundaries, and end up doing the very things they swore they'd never do. Pastor and author Brittany Rust was one such person--until she found herself in the middle of moral failure and a church-wide scandal. Bewildered, humiliated, and ashamed, she thought she was beyond redemption. But God's grace met her on the ground, and here she shares what she's learned through her painful journey. She unravels the myth of being untouchable, showing how we start to believe the lie, and how we can protect ourselves from temptation. Ultimately she shows that to truly flourish in life, you must be willing to admit weakness--and that no one is beyond God's redeeming love.
Автор: Cargill C. Robert Название: Sea of Rust ISBN: 0062405853 ISBN-13(EAN): 9780062405852 Издательство: HarperCollins USA Цена: 2375.00 р. Наличие на складе: Есть у поставщика Поставка под заказ.
Описание:
A scavenger robot wanders in the wasteland created by a war that has destroyed humanity in this evocative post-apocalyptic robot western from the critically acclaimed author, screenwriter, and noted film critic.
It's been thirty years since the apocalypse and fifteen years since the murder of the last human being at the hands of robots. Humankind is extinct. Every man, woman, and child has been liquidated by a global uprising devised by the very machines humans designed and built to serve them. Most of the world is controlled by an OWI--One World Intelligence--the shared consciousness of millions of robots, uploaded into one huge mainframe brain. But not all robots are willing to cede their individuality--their personality--for the sake of a greater, stronger, higher power. These intrepid resisters are outcasts; solo machines wandering among various underground outposts who have formed into an unruly civilization of rogue AIs in the wasteland that was once our world.
One of these resisters is Brittle, a scavenger robot trying to keep a deteriorating mind and body functional in a world that has lost all meaning. Although unable to experience emotions like a human, Brittle is haunted by the terrible crimes the robot population perpetrated on humanity. As Brittle roams the Sea of Rust, a large swath of territory that was once the Midwest, the loner robot slowly comes to terms with horrifyingly raw and vivid memories--and nearly unbearable guilt.
Sea of Rust is both a harsh story of survival and an optimistic adventure. A vividly imagined portrayal of ultimate destruction and desperate tenacity, it boldly imagines a future in which no hope remains, yet where a humanlike AI strives to find purpose among the ruins.
As the twentieth century dawned on western Pennsylvania and eastern Ohio, the region's steel industry faced a struggle for unionism. Strong managers like Judge Elbert Gary and Tom Girdler opposed every move forward.
Regardless, unionists like Philip Murray, John L. Lewis, Samuel Gompers and Gus Hall battled for fair wages, hours and working conditions. Tensions from issues of immigration, class, skill and race erupted throughout the industry. The tribulations led to widespread steel strikes directed by the Amalgamated Association of Iron and Steel Workers and the Steel Workers Organizing Committee. Author Dale Richard Perelman charts the struggle and decline of the nation's most prominent regional steel industry.
Автор: Kaihlavirta Vesa, Johnson Paul Название: Learning Rust ISBN: 1785884301 ISBN-13(EAN): 9781785884306 Издательство: Неизвестно Цена: 9010.00 р. Наличие на складе: Есть у поставщика Поставка под заказ.
Описание: Rust is a highly concurrent and high performance language that focuses on safety and speed, memory management, and writing clean code. It also guarantees thread safety, and its aim is to improve the performance of existing applications. Learning Rust will teach you to build concurrent, fast, and robust applications. From learning the basic synta...
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