Mli Made Easy

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MLI Made Easy

Author : Kuldeep Sharma
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403532610
Total Pages : 352 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis MLI Made Easy by : Kuldeep Sharma

Download or read book MLI Made Easy written by Kuldeep Sharma and published by Kluwer Law International B.V.. This book was released on 2021-04-22 with total page 352 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) provides an innovative approach to enable countries to swiftly modify their bilateral tax treaties in order to implement measures developed in the course of the Base Erosion and Profit Shifting (BEPS) Project. MLI, the first successfully concluded multilateral tax treaty, provides jurisdictions with the tools they need to ensure that profits are taxed where economic activities generating the profits are performed, while at the same time giving businesses greater certainty. MLI Made Easy makes it easier to get a complete grasp of this swift but complex modification process of tax treaties. This first and only self-contained book offers an unmatched article-by-article discussion of the MLI with an abundance of practical examples, diagrams, and flowcharts to make the information easier to understand and apply. Focusing on measures to combat tax evasion and abuse of tax treaties arising due to artificial avoidance of a permanent establishment status, hybrid mismatch arrangements, and other aspects of taxation, the book includes an in-depth discussion of the following and more: how specific gaps in existing bilateral tax treaties are addressed by the MLI; positions taken by selected jurisdictions and their impact on treaties; compatibility clauses, notification clauses, opting-in mechanisms, alternative provisions, and reservations; experiences in the course of implementation of the MLI; misconceptions and lingering doubts in respect of various substantive and procedural provisions of the MLI; interaction between the principal purpose test and simplified limitation on benefits; improving dispute resolution; and meaning of the phrases ‘on or after’, ‘other taxes’, and interpretational issues in entry into effect provisions. Adopted by a majority of jurisdictions worldwide, MLI preserves the tax sovereignty of its Parties and has been successful in overcoming barriers to the conclusion of a worldwide multilateral tax treaty. Because this easy-to-use book immensely facilitates understanding and application of the treaty measures developed in the course of the BEPS Project, it will be of immeasurable use to practitioners and other professionals engaging in international taxation, as well as to taxation authorities and interested academics in any part of the world.

GloBE Rules Made Easy

Author : Kuldeep Sharma
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403511664
Total Pages : 340 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis GloBE Rules Made Easy by : Kuldeep Sharma

Download or read book GloBE Rules Made Easy written by Kuldeep Sharma and published by Kluwer Law International B.V.. This book was released on 2022-12-09 with total page 340 pages. Available in PDF, EPUB and Kindle. Book excerpt: Worldwide implementation of the OECD’s Global Anti-Base Erosion Rules (GloBE Rules), published in December 2021, promises to strike a powerful blow at the tax avoidance rampantly indulged in by many multinational corporations since global minimum tax rate of 15% in all countries is expected to curb shifting of profits from higher tax jurisdiction to lower tax jurisdiction or tax havens. As Inclusive Framework (IF) Member jurisdictions prepare to implement legislation, the tax law community worldwide can turn to this extraordinarily practical, self-contained book for a complete understanding of the background and attributes of the Rules. The book includes such features as the following: text of each of the Rules’ ten chapters (including all forty-nine articles) along with both summary and detailed description; explanations of the Commentary and Illustrative Examples released by the OECD in March 2022; numerous flowcharts, tables, boxes, illustrations, and figures; elaborate technical discussions amidst specific policy considerations; analysis of IF Member jurisdictions regarding key parameters with suitable recommendations; ‘GloBE Rules at a Glance’ checklist encapsulating the features and application of the Rules in the form of FAQs; and implementation processes under way in ten representative jurisdictions. The various publications and releases by the OECD up to 31 May 2022 are considered and duly explained. In the struggle to curb harmful tax competition and aggressive tax planning, it is possible that the GloBE Rules will at last succeed in creating a level playing field in the realm of taxation. And given that OECD guidance and tax expert analysis may not suffice to fully comprehend the complexity of the Rules, this book will prove of enormous value among a wide array of stakeholders, including taxation authorities, tax advisors and lawyers, and academics. Also, multinational enterprises will get enough information to derive maximum benefits in terms of their preparedness, readiness, and responses to implementation of the Rules.

VYAVAHARA AYURVEDA (FORENSIC MEDICINE) MADE EASY [PART 1]

Author : Vd. Urvashi M Patel
Publisher : RED'SHINE Publication. Pvt. Ltd
ISBN 13 : 9389840112
Total Pages : 206 pages
Book Rating : 4.3/5 (898 download)

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Book Synopsis VYAVAHARA AYURVEDA (FORENSIC MEDICINE) MADE EASY [PART 1] by : Vd. Urvashi M Patel

Download or read book VYAVAHARA AYURVEDA (FORENSIC MEDICINE) MADE EASY [PART 1] written by Vd. Urvashi M Patel and published by RED'SHINE Publication. Pvt. Ltd. This book was released on with total page 206 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Evolution of APA Regime

Author : Kuldeep Sharma
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403535520
Total Pages : 252 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis Evolution of APA Regime by : Kuldeep Sharma

Download or read book Evolution of APA Regime written by Kuldeep Sharma and published by Kluwer Law International B.V.. This book was released on 2021-07-19 with total page 252 pages. Available in PDF, EPUB and Kindle. Book excerpt: Advance pricing agreements or arrangements (APAs) are designed as a dispute prevention mechanism for transfer pricing related issues and provide certainty to taxpayers on taxation of cross-border transactions. Since the APA procedure was introduced by tax authorities in the late 1980s, it has gradually taken hold worldwide and evolved along several dimensions with important characteristics. This book, the first exclusively dedicated to the global APA regime, provides a comprehensive, in-depth discussion of the APA concepts and procedures in twenty-five jurisdictions across Europe, Asia, Asia Pacific, North America, South America and Africa, noting the particular genesis, features, and progress made under each programme. The analysis covers such elements as the following: the types of APAs and their characteristics; the main steps involved in an APA process; key advantages of APA programme and comparative study of the APA as a preferred dispute prevention mechanism over other dispute resolution mechanisms; key issues observed and in practice by various APA authorities worldwide inter alia involving, cost base of captive entities, resolution of transfer pricing issues involving intangibles, location savings, joint site visits, attribution of profits to PEs, APAs for small businesses, abbreviated procedure for renewal of APAs, significance of economic nexus prior to the grant of APAs and other relevant issues; exchange of APA rulings equip tax authorities to quickly identify risk areas so as to curb Base Erosion and Profits Shifting (BEPS), which augurs well for the APA programme and is another milestone in its evolution process; APAs provide jurisdictions with an excellent platform to fostering a non-adversarial tax regime. The author includes an extended case study of India’s APA programme, highlighting some of its conspicuous elements with equal focus on certain special characteristics of APAs in Australia, Canada, France, Germany, Ireland, Korea, The Netherlands, Poland, UK and the United States. Factors influencing speedier processing and suggestions on further improvement of APA programmes are also included. Numerous tables and figures illustrate all aspects associated with APAs. With more economies opening up and the worldwide implementation of the OECD/G20 BEPS Action Reports in an endeavour to combat BEPS, access and recourse to APAs is sure to grow. This invaluable book will enable tax administrations to learn from each other’s experiences and help to prevent costly and time-consuming transfer pricing audits and litigation for multinational enterprises. The book will be welcomed by revenue officials, professionals, and advisors concerned with international taxation, as well as by tax law academics.

Yachting

Author :
Publisher :
ISBN 13 :
Total Pages : 188 pages
Book Rating : 4./5 ( download)

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Book Synopsis Yachting by :

Download or read book Yachting written by and published by . This book was released on 1982-12 with total page 188 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Yachting

Author :
Publisher :
ISBN 13 :
Total Pages : 188 pages
Book Rating : 4./5 ( download)

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Book Synopsis Yachting by :

Download or read book Yachting written by and published by . This book was released on 1982-12 with total page 188 pages. Available in PDF, EPUB and Kindle. Book excerpt:

PC Mag

Author :
Publisher :
ISBN 13 :
Total Pages : 970 pages
Book Rating : 4./5 ( download)

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Book Synopsis PC Mag by :

Download or read book PC Mag written by and published by . This book was released on 1982-08 with total page 970 pages. Available in PDF, EPUB and Kindle. Book excerpt: PCMag.com is a leading authority on technology, delivering Labs-based, independent reviews of the latest products and services. Our expert industry analysis and practical solutions help you make better buying decisions and get more from technology.

NASA Tech Briefs

Author :
Publisher :
ISBN 13 :
Total Pages : 1004 pages
Book Rating : 4.:/5 (319 download)

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Book Synopsis NASA Tech Briefs by :

Download or read book NASA Tech Briefs written by and published by . This book was released on 1999 with total page 1004 pages. Available in PDF, EPUB and Kindle. Book excerpt:

The OECD Multilateral Instrument for Tax Treaties

Author : Michael Lang
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041189165
Total Pages : 382 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis The OECD Multilateral Instrument for Tax Treaties by : Michael Lang

Download or read book The OECD Multilateral Instrument for Tax Treaties written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2016-04-24 with total page 382 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.

Spacecraft Thermal Control Technologies

Author : Jianyin Miao
Publisher : Springer Nature
ISBN 13 : 9811549842
Total Pages : 360 pages
Book Rating : 4.8/5 (115 download)

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Book Synopsis Spacecraft Thermal Control Technologies by : Jianyin Miao

Download or read book Spacecraft Thermal Control Technologies written by Jianyin Miao and published by Springer Nature. This book was released on 2020-08-19 with total page 360 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book presents fundamental theories, design and testing methodologies, and engineering applications concerning spacecraft thermal control systems, helping readers gain a comprehensive understanding of spacecraft thermal control systems and technologies. With abundant design methods, advanced technologies and typical applications to help them grasp the basic concepts and principles of engineering applications, it is mainly intended for engineering and technical staff engaged in spacecraft thermal control areas. The book discusses the thermal environments commonly used for space flight missions, rules and regulations for system design, thermal analysis and simulation, and thermal testing methods, as well as the design and validation of the thermal control systems for Chinese spacecraft, such as the Shenzhou spacecraft and Chang’e Lunar Lander and Rover. It also introduces them to communication and remote sensing satellites and presents advanced thermal control technologies developed in recent years, including heat transfer, heat insulation, heating, refrigeration and thermal sensor technologies. Addressing the design and validation of thermal control systems for various types of Chinese spacecraft, the book offers a valuable theoretical and practical reference guide for researchers and engineers alike.

Advances in Cryogenic Engineering Materials

Author : U. Balu Balachandran
Publisher : Springer Science & Business Media
ISBN 13 : 1461542936
Total Pages : 467 pages
Book Rating : 4.4/5 (615 download)

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Book Synopsis Advances in Cryogenic Engineering Materials by : U. Balu Balachandran

Download or read book Advances in Cryogenic Engineering Materials written by U. Balu Balachandran and published by Springer Science & Business Media. This book was released on 2012-12-06 with total page 467 pages. Available in PDF, EPUB and Kindle. Book excerpt: The 1999 Joint Cryogenic Engineering Conference (CEC) and International Cryogenic Materials Conference (ICMC) were held in Montreal, Quebec, Canada from July 12th to July 16th. The joint conference theme was "Cryogenics into the Next Millennium". The total conference attendance was 797 with participation from 28 countries. As with previous joint CEC and ICMC Conferences, the participants were able to benefit from the joint conference's coverage of cryogenic applications and materials and their interactions. The conference format of plenary, oral and poster presentations, and an extensive commercial exhibit, the largest in CEC-ICMC history, aimed to promote this synergy. The addition of short courses, workshops, and a discussion meeting enabled participants to focus on some of their specialties. The technical tour, organized by Suzanne Gendron, was of Hydro-Quebec's research institute laboratories near Montreal. In keeping with the conference venue the entertainment theme was Jazz, culminating in .the performance of Vic Vogel and his Jazz Big Band at the conference banquet. This 1999 ICMC Conference was chaired by Julian Cave of IREQ - Institut de recherche d'Hydro-Quebec, and the Program Chair and Vice-Chair were Michael Green of the Lawrence Berkeley National Laboratory and Balu Balachandran of the Argonne National Laboratory respectively. We especially appreciate the contributions of both the CEC and ICMC Boards and the conference managers, Centennial Conferences, under the supervision of Paula Pair and Kim Bass, in making this conference a success.

A Collection of Technical Papers

Author :
Publisher :
ISBN 13 :
Total Pages : 694 pages
Book Rating : 4.0/5 ( download)

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Book Synopsis A Collection of Technical Papers by :

Download or read book A Collection of Technical Papers written by and published by . This book was released on 1979 with total page 694 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Multilevel Inverters

Author : Ersan Kabalci
Publisher : Academic Press
ISBN 13 : 0323907253
Total Pages : 256 pages
Book Rating : 4.3/5 (239 download)

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Book Synopsis Multilevel Inverters by : Ersan Kabalci

Download or read book Multilevel Inverters written by Ersan Kabalci and published by Academic Press. This book was released on 2021-03-27 with total page 256 pages. Available in PDF, EPUB and Kindle. Book excerpt: Multilevel Inverters: Control Methods and Power Electronics Applications provides a suite of powerful control methods for conventional and emerging inverter topologies instrumentalized in power electronics applications. It introduces readers to the conventional pulse width modulation control of multilevel voltage source inverter topologies before moving through more advanced approaches including hysteresis control, proportional resonance control, and model predictive control. Later chapters survey the power electronics connection between device topologies and control methods, particularly focusing on conversion in renewable energy systems, electric vehicles, static VAR compensators and solid-state transformers. - Examines modern design configurations for multilevel inverter controllers, emerging control methods, and their applications - Presents detailed application examples of multilevel inverters deployed in modern and recent power electronic areas including renewable energy sources, electric vehicles, and grid management - Discusses deployment and development of future power converter implementation

MLITemp: A Computer Program to Predict the Thermal Effects Associated with Hypervelocity Impact Damage to Space Station MLI

Author : William K. Rule
Publisher :
ISBN 13 :
Total Pages : 84 pages
Book Rating : 4.:/5 (317 download)

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Book Synopsis MLITemp: A Computer Program to Predict the Thermal Effects Associated with Hypervelocity Impact Damage to Space Station MLI by : William K. Rule

Download or read book MLITemp: A Computer Program to Predict the Thermal Effects Associated with Hypervelocity Impact Damage to Space Station MLI written by William K. Rule and published by . This book was released on 1991 with total page 84 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Space Debris

Author : Luciano Anselmo
Publisher :
ISBN 13 :
Total Pages : 184 pages
Book Rating : 4.3/5 (91 download)

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Book Synopsis Space Debris by : Luciano Anselmo

Download or read book Space Debris written by Luciano Anselmo and published by . This book was released on 2005 with total page 184 pages. Available in PDF, EPUB and Kindle. Book excerpt:

The Imperial Lexicon of the English Language

Author : John Boag
Publisher :
ISBN 13 :
Total Pages : 870 pages
Book Rating : 4.3/5 (91 download)

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Book Synopsis The Imperial Lexicon of the English Language by : John Boag

Download or read book The Imperial Lexicon of the English Language written by John Boag and published by . This book was released on 1850 with total page 870 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Cryogenic Process Engineering

Author : Klaus D. Timmerhaus
Publisher : Springer Science & Business Media
ISBN 13 : 1468487566
Total Pages : 614 pages
Book Rating : 4.4/5 (684 download)

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Book Synopsis Cryogenic Process Engineering by : Klaus D. Timmerhaus

Download or read book Cryogenic Process Engineering written by Klaus D. Timmerhaus and published by Springer Science & Business Media. This book was released on 2013-06-29 with total page 614 pages. Available in PDF, EPUB and Kindle. Book excerpt: Cryogenics, a term commonly used to refer to very low temperatures, had its beginning in the latter half of the last century when man learned, for the first time, how to cool objects to a temperature lower than had ever existed na tu rally on the face of the earth. The air we breathe was first liquefied in 1883 by a Polish scientist named Olszewski. Ten years later he and a British scientist, Sir James Dewar, liquefied hydrogen. Helium, the last of the so-caBed permanent gases, was finally liquefied by the Dutch physicist Kamerlingh Onnes in 1908. Thus, by the beginning of the twentieth century the door had been opened to astrange new world of experimentation in which aB substances, except liquid helium, are solids and where the absolute temperature is only a few microdegrees away. However, the point on the temperature scale at which refrigeration in the ordinary sense of the term ends and cryogenics begins has ne ver been weB defined. Most workers in the field have chosen to restrict cryogenics to a tem perature range below -150°C (123 K). This is a reasonable dividing line since the normal boiling points of the more permanent gases, such as helium, hydrogen, neon, nitrogen, oxygen, and air, lie below this temperature, while the more common refrigerants have boiling points that are above this temperature. Cryogenic engineering is concerned with the design and development of low-temperature systems and components.