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In October 2015, the Organisation for Economic Co-operation and Development (OECD) released finalisation of the Base Erosion and Profit Shifting (BEPS) action 8. This action 8 contains recommendations for transfer pricing issues related to intangibles. The main objective of this transfer pricing guidelines’ reform is to realign transfer pricing outcomes from intangibles with value creation. Therefore it would prevent base erosion and profit shifting by moving intangibles among group members of a multinational. 
The content of action 8 revolves around five axes. Firstly, it provides additional guidance on determination of arm’s length conditions including detailed discussion on location savings, assembled workforce, other local market features, group synergies and available realistic options. Secondly, it provides instructions for the identification of intangibles, especially a new definition of the intangible asset. Thirdly, the action 8 adds guidance to identify which entity or entities within a multinational group are entitled to outcomes from exploiting intangibles. In particular, it emphasises the importance of a detailed functional, risk and asset analysis stating the entities that perform functions, utilise assets and assume risks associated with the development, enhancement, maintenance, protection, and exploitation of intangibles. Fourthly, it provides guidance on the applicability of Transfer pricing methods with intangibles. And finally, it provides specific guidance when an intra-group transaction involves the transfer of hard-to-value intangibles.
Based on that observation, we wanted to study the opinion of transfer pricing specialists about the proposals resulting from the action 8. So the problematic viewed is: are action’s proposals in line with the main objective of this action? By using a qualitative approach, we identify the different outlooks of each transfer pricing experts. And the results of our dissertation show that some progresses have been made on the transfer pricing aspects of intangibles. However, the new guidance remains based on the arm’s length principle. Therefore, some orientations appear not to fit with the objective.

base erosion and profit shifting (BEPS), transfer pricing, intangibles, action 8, critical analysis --- Droit, criminologie & sciences politiques > Droit fiscal

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Psychology --- Psychologie --- Periodicals. --- Périodiques --- Psychology. --- Europe. --- Behavioral sciences --- Mental philosophy --- Mind --- Science, Mental --- Factors, Psychological --- Psychological Factors --- Psychological Side Effects --- Psychologists --- Psychosocial Factors --- Side Effects, Psychological --- Factor, Psychological --- Factor, Psychosocial --- Factors, Psychosocial --- Psychological Factor --- Psychological Side Effect --- Psychologist --- Psychosocial Factor --- Side Effect, Psychological --- Industries --- psychology --- psychological theory --- critical analysis --- Human biology --- Philosophy --- Soul --- Mental health

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An investigation of the phenomenon of the framed formal center in literature of the last 180 years, illuminating both the works and correspondences among works of different genres, periods, and nations.

American literature --- Symmetry in literature. --- History and criticism. --- 19th-21st centuries. --- Accessible interpretation. --- Allegory. --- Allusion. --- Anderson. --- Carroll. --- Central passage. --- Chandler. --- Chiasmus. --- Critical analysis. --- Critical breakthroughs. --- Formal structure. --- Framed center. --- Genre. --- Hammett. --- Hawthorne. --- Hemingway. --- Highsmith. --- Interpretation. --- Joyce. --- Language. --- Literary analysis. --- Literary patterns. --- Literary techniques. --- Literature. --- Melville. --- Metaphor. --- Mirroring plot. --- Mise en abyme. --- Multiple meanings. --- National origins. --- Oates. --- Parallelism. --- Period. --- Poe. --- Thoreau. --- Unknown correspondences. --- Zadie Smith.

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Understanding the chimpanzee mind is akin to opening a window onto human consciousness. Many of our complex cognitive processes have origins that can be seen in the way that chimpanzees think, learn, and behave. The Mind of the Chimpanzee brings together scores of prominent scientists from around the world to share the most recent research into what goes on inside the mind of our closest living relative. Intertwining a range of topics-including imitation, tool use, face recognition, culture, cooperation, and reconciliation-with critical commentaries on conservation and welfare, the collection aims to understand how chimpanzees learn, think, and feel, so that researchers can not only gain insight into the origins of human cognition, but also crystallize collective efforts to protect wild chimpanzee populations and ensure appropriate care in captive settings. With a breadth of material on cognition and culture from the lab and the field, The Mind of the Chimpanzee is a first-rate synthesis of contemporary studies of these fascinating mammals that will appeal to all those interested in animal minds and what we can learn from them.

Chimpanzees --- Cognition in animals --- Social behavior in animals --- Behavior --- Psychology --- Ecology --- Conservation --- chimps, animals, nonhuman, ecology, experiment, consciousness, conscience, zoology, conservation, apes, zoo, evolution, evolutionary, science, scientist, scientific, academic, scholarly, research, study, college, university, higher education, textbook, relatives, imitation, tools, facial, recognition, culture, cooperation, reconciliation, critical, analysis, commentary, psychology.

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Ranging from Los Angeles to Havana to the Bronx to the U.S.-Mexico border and from klezmer to hip hop to Latin rock, this groundbreaking book injects popular music into contemporary debates over American identity. Josh Kun insists that America is not a single chorus of many voices folded into one, but rather various republics of sound that represent multiple stories of racial and ethnic difference. To this end he covers a range of music and listeners to evoke the ways that popular sounds have expanded our idea of American culture and American identity. Artists as diverse as The Weavers, Café Tacuba, Mickey Katz, Rahsaan Roland Kirk, Bessie Smith, and Ozomatli reveal that the song of America is endlessly hybrid, heterogeneous, and enriching-a source of comfort and strength for populations who have been taught that their lives do not matter. Kun melds studies of individual musicians with studies of painters such as Jean-Michel Basquiat and of writers such as Walt Whitman, James Baldwin, and Langston Hughes. There is no history of race in the Americas that is not a history of popular music, Kun claims. Inviting readers to listen closely and critically, Audiotopia forges a new understanding of sound that will stoke debates about music, race, identity, and culture for many years to come.

Popular music --- Music --- Multiculturalism --- History and criticism. --- Social aspects --- america. --- american culture. --- american identity. --- american studies. --- art and music. --- artists. --- bronx. --- critical analysis. --- cultural studies. --- discussion books. --- ethnic demographic studies. --- ethnic differences. --- ethnic minorities. --- havana. --- hip hop. --- klezmer. --- latin rock. --- literary movements. --- los angeles. --- modern history. --- music and culture. --- music historians. --- music history. --- music lovers. --- music studies. --- music. --- nonfiction. --- popular music. --- race issues. --- racial history. --- racial issues. --- retrospective. --- us borders.