This study discusses the European Union’s proposal for a Regulation on Markets in Crypto-Assets,now subject to formal approval by the European Parliament.The objective is to explore whether it will positively impact ...This study discusses the European Union’s proposal for a Regulation on Markets in Crypto-Assets,now subject to formal approval by the European Parliament.The objective is to explore whether it will positively impact the adoption of crypto-assets in the financial sector.The use of crypto-assets is growing.However,some stakeholders in the financial service sector remain skeptical and hesitant to adopt assets that are yet to be defined and have an unclear legal status.This regulatory uncertainty has been identified as the primary reason for the reluctant adoption.The proposed regulation(part of the EU’s Digital Finance Strategy)aims to provide this legal certainty for currently unregulated crypto-assets.This study investigates whether or not the proposed regulation can be expected to have the intended effect by reviewing the proposed regulation itself,the opinions and reactions of the various stakeholders,and secondary literature.Findings reveal that such regulation will most likely not accelerate the adoption of crypto-assets in the EU financial services sector,at least not sufficiently or as intended.Some suggestions are made to improve the proposal.展开更多
Global warming has greatly concerned the whole world.Owing to the limitation we currently have,it is still difficult to completely understand the mechanism and physical science of climate change.Now both certainty and...Global warming has greatly concerned the whole world.Owing to the limitation we currently have,it is still difficult to completely understand the mechanism and physical science of climate change.Now both certainty and uncertainty coexist in the understanding of climate warming.This paper aims to summarize certainties and uncertainties in climate-warming studies,which focus on seven key problems related to human activities,namely,global warming,atmospheric concentrations of greenhouse gases,relationship between greenhouse gas emissions and climate warming,climate models,future climate change,2?warming threshold and tipping point in the Earth's system.We should comprehensively take into account the level of certainty and uncertainty in our understanding of climate change while adapting to and mitigating global warming and adjusting our industrial structures accordingly.This would allow us to respond to change with certainty,while avoiding the risks associated with uncertainty.展开更多
The paper presents some examples revealing the uncertainty and absolute certainty principles in kinetics of objects formation that are different in their physical nature and in space scales: sub-stances of microcosm, ...The paper presents some examples revealing the uncertainty and absolute certainty principles in kinetics of objects formation that are different in their physical nature and in space scales: sub-stances of microcosm, nanoparticles and mesostructures, astrophysical and cosmological objects. Under the proposed kinetic approach, the uncertainty principle covers a wider spectrum of processes of approaching to equilibrium and object formation, than the absolute certainty principle. It refers, in particular, to nano-range-of-problems and mesoscopics as well as to cosmology. Both principles predict formation of objects that are not well-known or, at least, well-described so far. Among these are neutron-rich super-heavy and giant nuclei, biologic and organic-silicon mesoobjects, cosmological objects with the sizes considerably exceeding the size of a light sphere.展开更多
When the ubiquitous quantum, acting as an active principle, generates meteons in the System of the World, the Absolute Certainty Principle (ACP) regulates the characteristics of their motion. This newly uncovered law ...When the ubiquitous quantum, acting as an active principle, generates meteons in the System of the World, the Absolute Certainty Principle (ACP) regulates the characteristics of their motion. This newly uncovered law of Nature suggests that the cosmos is filled with an “aether”, as Newton and others—even Einstein!—called it in their days, and explains quite simply why we stand erect vertically on the surface of the Earth and why the universe is in expansion.展开更多
A new approach combining the certainty factor(CF) and analytic hierarchy process(AHP) methods was proposed to assess landslide susceptibility in the Ziyang district, which is situated in the Qin-Ba Mountain region, Ch...A new approach combining the certainty factor(CF) and analytic hierarchy process(AHP) methods was proposed to assess landslide susceptibility in the Ziyang district, which is situated in the Qin-Ba Mountain region, China. Landslide inventory data were collected based on field investigations and remote sensing interpretations. A total of 791 landslides were identified. A total of 633 landslides were randomly selected from this data setas the training set, and the remaining landslides were used for validation as the test set. Nine factors, including the slope angle, slope aspect, slope curvature, lithology, distance to faults, distance to streams, precipitation, road network intensity degree and land use were chosen as the landslide causal factors for further susceptibility assessment. The weight of each factor and its subclass were calculated by AHP and CF methods. Landslide susceptibility was compared between the bivariate statistical method and the proposed CF-AHP method. The results indicate that the distance to streams, distance to faults and lithology are the most dominant causal factors associated with landslides. The susceptibility zonation was categorized into five classes of landslide susceptibility, i.e., very high, high, moderate, low and very low level. Lastly, the relative operating characteristics(ROC) curve was used to validate the accuracy of the new approach, and the result showed a satisfactory prediction rate of 78.3%, compared to 69.2% obtained with the landslide susceptibility index method. The results indicate that the CF-AHP combined method is more appropriate for assessing the landslide susceptibility in this area.展开更多
In the meizoseismal areas hit by the China Wenchuan earthquake on May 12, 2008, the disasterprone environment has changed dramatically, making the susceptibility assessment of debris flow more complex and uncertain. A...In the meizoseismal areas hit by the China Wenchuan earthquake on May 12, 2008, the disasterprone environment has changed dramatically, making the susceptibility assessment of debris flow more complex and uncertain. After the earthquake, debris flow hazards occurred frequently and effective susceptibility assessment of debris flow has become extremely important. Shenxi gully in Du Jiangyan city, located in the meizoseismal areas, was selected as the study area. Based on the research of disaster-prone environment and the main factors controlling debris flow, the susceptibility zonations of debris flow were mapped using factor weight method(FW), certainty coefficient method(CF) and geomorphic information entropy method(GI). Through comparative analysis, the study showed that these three methods underestimated susceptible degree of debris flow when used in the meizoseismal areas of Wenchuan earthquake. In order to solve this problem, this paper developed a modified certainty coefficient method(M-CF) to reflect the impact of rich loose materials on the susceptible degree of debris flow. In the modified method, the distribution and area of loose materials were obtained by field investigations and postearthquake remote sensing image, and four data sets, namely, lithology, elevation, slop and aspect, wereused to calculate the CF values. The result of M-CF method is in agreement with field investigations and the accuracy of the method is satisfied. The method has a wide application to the susceptibility assessment of debris flow in the earthquake stricken areas.展开更多
In this paper, we propose the principle, methods and calculating formulas for determining the certainty factors of earthquake precursory anomaly evidences CF (E). Based on the guidebooks for earthquake prediction, we ...In this paper, we propose the principle, methods and calculating formulas for determining the certainty factors of earthquake precursory anomaly evidences CF (E). Based on the guidebooks for earthquake prediction, we give the methods of determining the CF values of 22 evidences (including seismic gap, belt, b-value, c-value, velocity ratio, strengthen of anomalous activities, quiet of anomalous activities, seismic window, earthquake swarm,earthquake sequence, coda wave, initial motion of P wave, stress drop, geoelectricity, geomagnetism, stress,ground tilt, ground water level, radon and hydrochemistry, gravity, space environment and macroscopic anomalies), and show three examples. The purposes are to use the Expert System for Earthquake Prediction (ESEP) further.展开更多
This paper is concerned with Hepato-Cellular Carcinoma (HCC) patients treated naturopathic agents. Patients treated with ≥4 agents survived significantly longer than patients treated with ≤3 agents. The great effect...This paper is concerned with Hepato-Cellular Carcinoma (HCC) patients treated naturopathic agents. Patients treated with ≥4 agents survived significantly longer than patients treated with ≤3 agents. The great effect is seen in patients treated with at least 4 agents that include Cordyceps sinensis. This greater certainty of patient survival without toxic side effects is significant benefit comparing with the conventional therapy. Treatment of HCC with a regimen of ≥4 agents prepared from natural products is associated with greater certainty of patient survival in a substantial portion of patients. The information dynamic model for certainty of patient survival is derived based on fluid mechanics, where a series of approximate solutions of the flow between two parallel flat walls, one of which is at rest, the other is suddenly accelerated from the rest to a constant velocity are used. The kinetic energy of certainty of patient survival decreases with increasing time, while the potential energy increases with increasing time. Total mechanical energy of patients treated with 4 or more agents is smaller than that treated with 3 or fewer agents. The kinetic energy (potential energy) of patients treated with 4 or more agents decreases (increases) more slower than the kinetic energy (potential energy) of patients treated with 3 or fewer agents.展开更多
In this paper,the transformative and critical potential of the groundlessness of praxis--a central issue in Wittgenstein’s On Certainty--is outlined.It argues that the groundlessness of human praxis entails neither a...In this paper,the transformative and critical potential of the groundlessness of praxis--a central issue in Wittgenstein’s On Certainty--is outlined.It argues that the groundlessness of human praxis entails neither a relativistic nor a foundationalistic epistemological position.On the contrary,following Stanley Cavell and a“resolute reading”of Wittgenstein’s philosophy,it claims that Wittgenstein’s aim is to let us acknowledge that both epistemological foundationalism and epistemic relativism are apparent needs,so as to invite us to change our practical way of acting.From this perspective,this paper suggests that Wittgenstein’s account of philosophy addresses the readers and involves a transformation of their own practical attitude and way of acting.展开更多
Raising tax certainty constitutes a fundamental for investment de-cisions by multinational enterprises(MNEs)while it is highly valuable also for tax administrations.Therefore,it has been considered as one of the core ...Raising tax certainty constitutes a fundamental for investment de-cisions by multinational enterprises(MNEs)while it is highly valuable also for tax administrations.Therefore,it has been considered as one of the core areas by the BRITACOM parties.Over the past few years,considerable attention has been devoted to improving tax certainty while new challenges arise.This article analyses some of the recent advances and emerging initiatives in terms of raising tax certaintywww.britacom.org mechanisms for cross-border transactions in areas such as dispute prevention and resolution,transfer pricing,General Anti-Avoidance Rules(GAARs)and the taxation of digital economy.展开更多
This article summarizes a Dutch court case regarding a business restructuring within a multinational enterprise,where the valuation of the transferred business activities was not confirmed by the tax authorities in ad...This article summarizes a Dutch court case regarding a business restructuring within a multinational enterprise,where the valuation of the transferred business activities was not confirmed by the tax authorities in advance.As a result of the lack of certainty beforehand,the taxpayer experienced a significant tax correction.According to the author’s perspective,this situation could have been prevented by seeking certainty in advance.展开更多
This article addresses the issue of tax certainty with emphasis on certainty in international taxation.It also discusses the most important methods and measures used to create and enhance tax certainty.
One of the most fascinating principles in quantum mechanics must be Heisenberg's uncertainty principle, which can be briefly stated as follows: every physicM observation cannot be precisely determined without some d...One of the most fascinating principles in quantum mechanics must be Heisenberg's uncertainty principle, which can be briefly stated as follows: every physicM observation cannot be precisely determined without some degree of error or uncertainty. And it is by no means can one use the principle within the limit of certainty region, as will be shown in this Letter. Two of the most important pillars in modern physics must be Einstein's relativity theory and SchrSdinger's contribution to quantum mechanics. Yet, there is a profound connection between these discoveries by means of the uncertainty relationship, in which we shown that the observation of a high-speed object is conceivable if the speed of the observer keeps up with object's speed.展开更多
The G20/OECD BEPS Project has resulted in many changes to both domestic law and tax treaties,including the adoption of anti-hybrid rules,earningsstripping rules to restrict the deduction of interest expenses,enhanced ...The G20/OECD BEPS Project has resulted in many changes to both domestic law and tax treaties,including the adoption of anti-hybrid rules,earningsstripping rules to restrict the deduction of interest expenses,enhanced transfer pricing rules and a multilateral treaty modifying hundreds of tax treaty changes.These extensive changes led to calls from both taxpayers and governments for enhancements to tax certainty.The BRITACOM has embraced these calls for enhanced tax certainty and made it one of its priority action items.This article puts current discussions about tax certainty into a broader context of the international tax system.It describes the nature and importance of tax certainty as a fundamental tax policy goal as well as the frequent conflicts between certainty and fairness in designing tax legislation and reviews the recent work of the IMF,the OECD and the BRITACOM on tax certainty.The article then explores the major sources of uncertainty,including deficiencies in tax legislation and tax administration,and discusses some methods for improving tax certainty for developing countries,including drafting better tax legislation,streamlining tax administration and adopting more efficient dispute-resolution mechanisms.展开更多
As from time to time it is impractical to ask agents to provide linear orders over all alternatives,for these partial rankings it is necessary to conduct preference completion.Specifically,the personalized preference ...As from time to time it is impractical to ask agents to provide linear orders over all alternatives,for these partial rankings it is necessary to conduct preference completion.Specifically,the personalized preference of each agent over all the alternatives can be estimated with partial rankings from neighboring agents over subsets of alternatives.However,since the agents’rankings are nondeterministic,where they may provide rankings with noise,it is necessary and important to conduct the certainty-based preference completion.Hence,in this paper firstly,for alternative pairs with the obtained ranking set,a bijection has been built from the ranking space to the preference space,and the certainty and conflict of alternative pairs have been evaluated with a well-built statistical measurement Probability-Certainty Density Function on subjective probability,respectively.Then,a certainty-based voting algorithm based on certainty and conflict has been taken to conduct the certainty-based preference completion.Moreover,the properties of the proposed certainty and conflict have been studied empirically,and the proposed approach on certainty-based preference completion for partial rankings has been experimentally validated compared to state-of-arts approaches with several datasets.展开更多
In this paper some improvements on certainty factor model are discussed aiming at:1)including, in a rule“E→H”,not only the CF of H when E exists but also CF of(?)when E does not exist(partly or completely).For this...In this paper some improvements on certainty factor model are discussed aiming at:1)including, in a rule“E→H”,not only the CF of H when E exists but also CF of(?)when E does not exist(partly or completely).For this purpose another factor(?)is added into the original model;2) improving the model so that it can tackle problems with unknown evidence.In this aspect two concepts are introduced:(relative)maximum existence risk and(relative)maximum non-existence risk.An impor- tant result is that even if some necessary evidence is unknown one can still know the tendency whether the conclusion is true.Based on the improvements a conflict resolution model for problem-level conflict is also presented展开更多
BEPS 2.0 is set to have a profound effect on the Belt and Road jurisdic-tions’ tax certainty environment. In the initial stage, a heightening of tax uncertainty can be envisioned, though in the longer term there is r...BEPS 2.0 is set to have a profound effect on the Belt and Road jurisdic-tions’ tax certainty environment. In the initial stage, a heightening of tax uncertainty can be envisioned, though in the longer term there is reason to be optimistic that a new and more certain BRI tax environment will emerge, in which the BRITACOM can play a crucial role.展开更多
An effective mechanism for dispute prevention and resolution is im-portant to both tax administrations and taxpayers in achieving tax certainty.The Hong Kong Special Administrative Region of the People’s Republic of ...An effective mechanism for dispute prevention and resolution is im-portant to both tax administrations and taxpayers in achieving tax certainty.The Hong Kong Special Administrative Region of the People’s Republic of China(Hong Kong)has implemented frontend dispute prevention and backend dispute resolution mech-anisms,including advance ruling,advance pricing arrangement(APA)and mutual agreement procedure(MAP)systems.This article explains in detail the requirements and procedures and shares the practical experience relating to advance ruling,APA and MAP in Hong Kong region.展开更多
文摘This study discusses the European Union’s proposal for a Regulation on Markets in Crypto-Assets,now subject to formal approval by the European Parliament.The objective is to explore whether it will positively impact the adoption of crypto-assets in the financial sector.The use of crypto-assets is growing.However,some stakeholders in the financial service sector remain skeptical and hesitant to adopt assets that are yet to be defined and have an unclear legal status.This regulatory uncertainty has been identified as the primary reason for the reluctant adoption.The proposed regulation(part of the EU’s Digital Finance Strategy)aims to provide this legal certainty for currently unregulated crypto-assets.This study investigates whether or not the proposed regulation can be expected to have the intended effect by reviewing the proposed regulation itself,the opinions and reactions of the various stakeholders,and secondary literature.Findings reveal that such regulation will most likely not accelerate the adoption of crypto-assets in the EU financial services sector,at least not sufficiently or as intended.Some suggestions are made to improve the proposal.
基金the National Natural Science Foundation of China[41101083]
文摘Global warming has greatly concerned the whole world.Owing to the limitation we currently have,it is still difficult to completely understand the mechanism and physical science of climate change.Now both certainty and uncertainty coexist in the understanding of climate warming.This paper aims to summarize certainties and uncertainties in climate-warming studies,which focus on seven key problems related to human activities,namely,global warming,atmospheric concentrations of greenhouse gases,relationship between greenhouse gas emissions and climate warming,climate models,future climate change,2?warming threshold and tipping point in the Earth's system.We should comprehensively take into account the level of certainty and uncertainty in our understanding of climate change while adapting to and mitigating global warming and adjusting our industrial structures accordingly.This would allow us to respond to change with certainty,while avoiding the risks associated with uncertainty.
文摘The paper presents some examples revealing the uncertainty and absolute certainty principles in kinetics of objects formation that are different in their physical nature and in space scales: sub-stances of microcosm, nanoparticles and mesostructures, astrophysical and cosmological objects. Under the proposed kinetic approach, the uncertainty principle covers a wider spectrum of processes of approaching to equilibrium and object formation, than the absolute certainty principle. It refers, in particular, to nano-range-of-problems and mesoscopics as well as to cosmology. Both principles predict formation of objects that are not well-known or, at least, well-described so far. Among these are neutron-rich super-heavy and giant nuclei, biologic and organic-silicon mesoobjects, cosmological objects with the sizes considerably exceeding the size of a light sphere.
文摘When the ubiquitous quantum, acting as an active principle, generates meteons in the System of the World, the Absolute Certainty Principle (ACP) regulates the characteristics of their motion. This newly uncovered law of Nature suggests that the cosmos is filled with an “aether”, as Newton and others—even Einstein!—called it in their days, and explains quite simply why we stand erect vertically on the surface of the Earth and why the universe is in expansion.
基金financial support from National Natural Science Foundation of China (Grant No. 41272282)National Natural Science Foundation of China-Youth Foundation (Grant No. 41402254)+1 种基金geological disaster survey projects of China Geological Survey (Grant No. 1212011220135, Grant No. DDW2016-01)the Fundamental Research Funds for the Central Universities (Grant No. 310826175030)
文摘A new approach combining the certainty factor(CF) and analytic hierarchy process(AHP) methods was proposed to assess landslide susceptibility in the Ziyang district, which is situated in the Qin-Ba Mountain region, China. Landslide inventory data were collected based on field investigations and remote sensing interpretations. A total of 791 landslides were identified. A total of 633 landslides were randomly selected from this data setas the training set, and the remaining landslides were used for validation as the test set. Nine factors, including the slope angle, slope aspect, slope curvature, lithology, distance to faults, distance to streams, precipitation, road network intensity degree and land use were chosen as the landslide causal factors for further susceptibility assessment. The weight of each factor and its subclass were calculated by AHP and CF methods. Landslide susceptibility was compared between the bivariate statistical method and the proposed CF-AHP method. The results indicate that the distance to streams, distance to faults and lithology are the most dominant causal factors associated with landslides. The susceptibility zonation was categorized into five classes of landslide susceptibility, i.e., very high, high, moderate, low and very low level. Lastly, the relative operating characteristics(ROC) curve was used to validate the accuracy of the new approach, and the result showed a satisfactory prediction rate of 78.3%, compared to 69.2% obtained with the landslide susceptibility index method. The results indicate that the CF-AHP combined method is more appropriate for assessing the landslide susceptibility in this area.
基金Financial support was provided by Ministry of Water Resources welfare industry funding(Grant No.201301058)Key Laboratory of Mountain Hazards and Earth Surface Processes independent project funding:Dynamic process and buried risk of debris flow in Shenxi gully after Wenchuan earthquakethe international cooperation project of Ministry of Science and Technology(Grant No.2013DFA21720)
文摘In the meizoseismal areas hit by the China Wenchuan earthquake on May 12, 2008, the disasterprone environment has changed dramatically, making the susceptibility assessment of debris flow more complex and uncertain. After the earthquake, debris flow hazards occurred frequently and effective susceptibility assessment of debris flow has become extremely important. Shenxi gully in Du Jiangyan city, located in the meizoseismal areas, was selected as the study area. Based on the research of disaster-prone environment and the main factors controlling debris flow, the susceptibility zonations of debris flow were mapped using factor weight method(FW), certainty coefficient method(CF) and geomorphic information entropy method(GI). Through comparative analysis, the study showed that these three methods underestimated susceptible degree of debris flow when used in the meizoseismal areas of Wenchuan earthquake. In order to solve this problem, this paper developed a modified certainty coefficient method(M-CF) to reflect the impact of rich loose materials on the susceptible degree of debris flow. In the modified method, the distribution and area of loose materials were obtained by field investigations and postearthquake remote sensing image, and four data sets, namely, lithology, elevation, slop and aspect, wereused to calculate the CF values. The result of M-CF method is in agreement with field investigations and the accuracy of the method is satisfied. The method has a wide application to the susceptibility assessment of debris flow in the earthquake stricken areas.
文摘In this paper, we propose the principle, methods and calculating formulas for determining the certainty factors of earthquake precursory anomaly evidences CF (E). Based on the guidebooks for earthquake prediction, we give the methods of determining the CF values of 22 evidences (including seismic gap, belt, b-value, c-value, velocity ratio, strengthen of anomalous activities, quiet of anomalous activities, seismic window, earthquake swarm,earthquake sequence, coda wave, initial motion of P wave, stress drop, geoelectricity, geomagnetism, stress,ground tilt, ground water level, radon and hydrochemistry, gravity, space environment and macroscopic anomalies), and show three examples. The purposes are to use the Expert System for Earthquake Prediction (ESEP) further.
文摘This paper is concerned with Hepato-Cellular Carcinoma (HCC) patients treated naturopathic agents. Patients treated with ≥4 agents survived significantly longer than patients treated with ≤3 agents. The great effect is seen in patients treated with at least 4 agents that include Cordyceps sinensis. This greater certainty of patient survival without toxic side effects is significant benefit comparing with the conventional therapy. Treatment of HCC with a regimen of ≥4 agents prepared from natural products is associated with greater certainty of patient survival in a substantial portion of patients. The information dynamic model for certainty of patient survival is derived based on fluid mechanics, where a series of approximate solutions of the flow between two parallel flat walls, one of which is at rest, the other is suddenly accelerated from the rest to a constant velocity are used. The kinetic energy of certainty of patient survival decreases with increasing time, while the potential energy increases with increasing time. Total mechanical energy of patients treated with 4 or more agents is smaller than that treated with 3 or fewer agents. The kinetic energy (potential energy) of patients treated with 4 or more agents decreases (increases) more slower than the kinetic energy (potential energy) of patients treated with 3 or fewer agents.
文摘In this paper,the transformative and critical potential of the groundlessness of praxis--a central issue in Wittgenstein’s On Certainty--is outlined.It argues that the groundlessness of human praxis entails neither a relativistic nor a foundationalistic epistemological position.On the contrary,following Stanley Cavell and a“resolute reading”of Wittgenstein’s philosophy,it claims that Wittgenstein’s aim is to let us acknowledge that both epistemological foundationalism and epistemic relativism are apparent needs,so as to invite us to change our practical way of acting.From this perspective,this paper suggests that Wittgenstein’s account of philosophy addresses the readers and involves a transformation of their own practical attitude and way of acting.
文摘Raising tax certainty constitutes a fundamental for investment de-cisions by multinational enterprises(MNEs)while it is highly valuable also for tax administrations.Therefore,it has been considered as one of the core areas by the BRITACOM parties.Over the past few years,considerable attention has been devoted to improving tax certainty while new challenges arise.This article analyses some of the recent advances and emerging initiatives in terms of raising tax certaintywww.britacom.org mechanisms for cross-border transactions in areas such as dispute prevention and resolution,transfer pricing,General Anti-Avoidance Rules(GAARs)and the taxation of digital economy.
文摘This article summarizes a Dutch court case regarding a business restructuring within a multinational enterprise,where the valuation of the transferred business activities was not confirmed by the tax authorities in advance.As a result of the lack of certainty beforehand,the taxpayer experienced a significant tax correction.According to the author’s perspective,this situation could have been prevented by seeking certainty in advance.
文摘This article addresses the issue of tax certainty with emphasis on certainty in international taxation.It also discusses the most important methods and measures used to create and enhance tax certainty.
文摘One of the most fascinating principles in quantum mechanics must be Heisenberg's uncertainty principle, which can be briefly stated as follows: every physicM observation cannot be precisely determined without some degree of error or uncertainty. And it is by no means can one use the principle within the limit of certainty region, as will be shown in this Letter. Two of the most important pillars in modern physics must be Einstein's relativity theory and SchrSdinger's contribution to quantum mechanics. Yet, there is a profound connection between these discoveries by means of the uncertainty relationship, in which we shown that the observation of a high-speed object is conceivable if the speed of the observer keeps up with object's speed.
文摘The G20/OECD BEPS Project has resulted in many changes to both domestic law and tax treaties,including the adoption of anti-hybrid rules,earningsstripping rules to restrict the deduction of interest expenses,enhanced transfer pricing rules and a multilateral treaty modifying hundreds of tax treaty changes.These extensive changes led to calls from both taxpayers and governments for enhancements to tax certainty.The BRITACOM has embraced these calls for enhanced tax certainty and made it one of its priority action items.This article puts current discussions about tax certainty into a broader context of the international tax system.It describes the nature and importance of tax certainty as a fundamental tax policy goal as well as the frequent conflicts between certainty and fairness in designing tax legislation and reviews the recent work of the IMF,the OECD and the BRITACOM on tax certainty.The article then explores the major sources of uncertainty,including deficiencies in tax legislation and tax administration,and discusses some methods for improving tax certainty for developing countries,including drafting better tax legislation,streamlining tax administration and adopting more efficient dispute-resolution mechanisms.
基金supported by the National Natural Science Foundation of China(No.62076087,No.61906059&No.62120106008)the Program for Changjiang Scholars and Innovative Research Team in University(PCSIRT)of the Ministry of Education of China under grant IRT17R32
文摘As from time to time it is impractical to ask agents to provide linear orders over all alternatives,for these partial rankings it is necessary to conduct preference completion.Specifically,the personalized preference of each agent over all the alternatives can be estimated with partial rankings from neighboring agents over subsets of alternatives.However,since the agents’rankings are nondeterministic,where they may provide rankings with noise,it is necessary and important to conduct the certainty-based preference completion.Hence,in this paper firstly,for alternative pairs with the obtained ranking set,a bijection has been built from the ranking space to the preference space,and the certainty and conflict of alternative pairs have been evaluated with a well-built statistical measurement Probability-Certainty Density Function on subjective probability,respectively.Then,a certainty-based voting algorithm based on certainty and conflict has been taken to conduct the certainty-based preference completion.Moreover,the properties of the proposed certainty and conflict have been studied empirically,and the proposed approach on certainty-based preference completion for partial rankings has been experimentally validated compared to state-of-arts approaches with several datasets.
文摘In this paper some improvements on certainty factor model are discussed aiming at:1)including, in a rule“E→H”,not only the CF of H when E exists but also CF of(?)when E does not exist(partly or completely).For this purpose another factor(?)is added into the original model;2) improving the model so that it can tackle problems with unknown evidence.In this aspect two concepts are introduced:(relative)maximum existence risk and(relative)maximum non-existence risk.An impor- tant result is that even if some necessary evidence is unknown one can still know the tendency whether the conclusion is true.Based on the improvements a conflict resolution model for problem-level conflict is also presented
文摘BEPS 2.0 is set to have a profound effect on the Belt and Road jurisdic-tions’ tax certainty environment. In the initial stage, a heightening of tax uncertainty can be envisioned, though in the longer term there is reason to be optimistic that a new and more certain BRI tax environment will emerge, in which the BRITACOM can play a crucial role.
文摘An effective mechanism for dispute prevention and resolution is im-portant to both tax administrations and taxpayers in achieving tax certainty.The Hong Kong Special Administrative Region of the People’s Republic of China(Hong Kong)has implemented frontend dispute prevention and backend dispute resolution mech-anisms,including advance ruling,advance pricing arrangement(APA)and mutual agreement procedure(MAP)systems.This article explains in detail the requirements and procedures and shares the practical experience relating to advance ruling,APA and MAP in Hong Kong region.