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Två sidor av samma mynt? - Om den dubbla tillämpningen av armlängdsprincipen under artikel 7 och 9 i OECD:s modellavtal och vilka skillnader som finns däremellan.

Armlängdsprincipen kan betraktas som en av de mest centrala principerna inom den internationella beskattningsrätten. I OECD:s modellavtal, som ligger till grund för utformningen av bilaterala dubbelbeskattningsavtal, stadgas armlängdsprincipen i artikel 9, den regel som tillåter korrigering av ett företags vinst när interna transaktioner prissatts på ett sätt som inte är armlängdsmässigt. SamtidigThe ALP can be considered one of the most significant principles within international taxation law. It is regulated under article 9 of the OECD MTC, which acts as a model for developing new bilateral tax treaties. According to article 9, the profit of an enterprise may be adjusted if the enterprise has been involved in transactions with an associated enterprise on conditions that are not of an arm

Simulating Magnetized Plasma using an Accelerated Finite Element-Boundary Integral Code

This paper describes an accelerated finite element-boundary integral code with support for complex media. The code is implemented in Python using several open source packages, and uses Numba just-in-time compilation for improved performance. To accelerate the boundary integral part of the code, a multilevel implementation of the adaptive cross approximation is used. As a numerical example, scatter

Across landscapes and seascapes : The movement ecology of diving and flying guillemots and gulls during breeding

Some seabirds we encounter only fleetingly, as they fly by as we walk along the beach, or perhaps meet far out at sea when we take a boat trip. Others though we are more familiar with, such as the ‘seagulls’ that many will not even turn their head to appreciate. Yet, all seabirds have remarkable stories to tell, and we are fortunate now to live at a time where we can follow individual birds as theMost seabirds breed colonially, at which time they make central-place foraging trips. Parents must collect food both for themselves and for egg production/chick-rearing. How should they forage? I followed five species across two sites in Sweden in the Baltic Sea using GPS and time-depth recorder (TDR) devices, giving information on both flight and diving activity. I use a movement ecology approach

Coordination Complexes of Molybdenum with 3,6-Di-tert-butylcatechol. Addition Products of DMSO, Pyridine N-oxide, and Triphenylarsine Oxide to the Putative [MoVIO(3,6-DBCat)2] Monomer and Self-Assembly of the Chiral [{MoVIO(3,6-DBCat)2}4] Square

Molybdenum complexes of 3,6-di-tert-butylcatechol have been prepared from the reaction between [Mo(CO)6] and 3,6-di-tert-butyl-1,2-benzoquinone. A putative "[MoO(3,6-DBCat)2]" monomer is assumed to form initially by reaction with trace quantities of oxygen. Condensation of the reaction mixture leads to the formation of oligomeric products, including the [{MoO(3,6-DBCat)2}4] chiral square isolated

IL-25 and B cells in atherosclerosis

Popular Abstract in English Atherosclerosis is a disease of medium and large sized vessels of our bodies that is mainly characterized by the deposition of lipids in the vessel walls. Increased lipid levels in the blood of an individual, because of lifestyle habits but also because of genetics, can lead to the formation of an “atherosclerotic plaque”. Thus, although lipids are important for the norAtherosclerosis is a chronic inflammatory disease of medium and large vessels of the body which is mainly characterized by the formation of lipid rich plaques within the arterial tissue. It is the most common cause of cardiovascular disease leading to clinical manifestations of coronary artery and cerebrovascular disease. Immune responses targeting modified low density lipoprotein (LDL) play an im

Measuring Mindfulness: Pilot Studies with the Swedish Versions of the Mindful Attention Awareness Scale and the Kentucky Inventory of Mindfulness Skills.

The present article describes data from pilot studies with the Swedish versions of the Mindful Attention Awareness Scale (MAAS) and the Kentucky Inventory of Mindfulness Skills (KIMS). The MAAS and two of the KIMS scales, Act with Awareness and Accept without Judgment, were found to correlate in the predicted direction with measures of well-being and emotional distress. The KIMS scales Observe and

From Tweets to the Streets. New Media and Political Engagement - A Case Study of Amnesty International and the Egyptian Uprisings

Despite the so-called ‘great retreat’, in which people arguably are distancing themselves from the political sphere and civic engagement, the last two years has seen an upsurge in political activities. Outside the realms of institutionalised politics, i.e. political parties, lies a whole terrain of alternative political activities, including social movements and media institutions. Following the E

Protein Engineering Allows for Mild Affinity-based Elution of Therapeutic Antibodies

Presented here is an engineered protein domain, based on Protein A, that displays a calcium-dependent binding to antibodies. This protein, ZCa, is shown to efficiently function as an affinity ligand for mild purification of antibodies through elution with ethylenediaminetetraacetic acid. Antibodies are commonly used tools in the area of biological sciences and as therapeutics, and the most commonl