This paper explores the compatibility of the Income Inclusion Rule(IIR)and the Undertaxed Profits Rule(UTPR)with existing tax treaties.The paper first assesses whether the taxes under IIR and UTPR meet the coverage cr...This paper explores the compatibility of the Income Inclusion Rule(IIR)and the Undertaxed Profits Rule(UTPR)with existing tax treaties.The paper first assesses whether the taxes under IIR and UTPR meet the coverage criteria of Art.2 of the OECD Model Convention(MC)and then analyses potential treaty infringements,focusing on Art.7,9,and 10(5),highlighting the inherent contradiction between tax treaties,which aim to limit taxing rights,and the global minimum tax,which allows taxation of global profits.Next,the paper reviews the historical development of IIR and UTPR,emphasising the OECD's initial recognition of the need for treaty amendments but noting the current lack of multilateral solutions,which poses potential dispute risks.In conclusion,the paper argues that the global minimum tax presents compliance challenges and legal uncertainties,questioning the binding effect of double taxation agreements.The article calls on the OECD to resolve these uncertainties through international agreements and advises countries to carefully consider the legal implications when implementing the IIR and the UTPR.展开更多
跨学科研究在管理学理论发展过程中一直扮演着重要角色,但这种研究方法对管理学科的理论建构以及管理学科的合法性会产生什么样的影响呢?本期发表的3篇译文是2009年发表于Journal of Management Studies第46卷第6期的一个有关在管理领...跨学科研究在管理学理论发展过程中一直扮演着重要角色,但这种研究方法对管理学科的理论建构以及管理学科的合法性会产生什么样的影响呢?本期发表的3篇译文是2009年发表于Journal of Management Studies第46卷第6期的一个有关在管理领域开展跨学科研究的专题讨论,第一篇短文是编辑对该专题的简要说明,另外两篇论文是学者们围绕跨学科研究方法对于管理学科发展的意义所进行的针锋相对的讨论,其观点颇具启发性,特编发译文以飨读者。展开更多
Companies operating across borders face greater challenges in ensuring compliance with company strategy in different cultural contexts. Recent research shows the cognitive and emotional benefits of utilizing visual re...Companies operating across borders face greater challenges in ensuring compliance with company strategy in different cultural contexts. Recent research shows the cognitive and emotional benefits of utilizing visual representations of knowledge in organizations. This study aims to test if mapping a corporate strategy visually can improve attitudes toward firm strategy and the intention to comply with it. An experiment is conducted comparing two knowledge maps to a textual version of the same company strategy. In order to measure attitudes toward the strategy, a scale was developed and tested in Europe and China. The study outcome provides a parsimonious and effective tripartite scale of attitude with cognitive, affective and behavioral components. The scale was then applied to a different sample to test the effect of mapping a company strategy visually on attitude toward the strategy, and to test if the effect is persistent in Europe and China. The results of the experiment show that subjects exposed to the visual conditions had significantly more positive affective and cognitive attitudes toward the content.展开更多
Xiong Shili熊十力1885-1968 is not an easily accessible Chinese thinker.Contrary to most of his contemporaries as well as his students,he never attempted to express his views by means of a philosophy or a vocabulary br...Xiong Shili熊十力1885-1968 is not an easily accessible Chinese thinker.Contrary to most of his contemporaries as well as his students,he never attempted to express his views by means of a philosophy or a vocabulary brought to China from outside.Rather,he is reported to have expressed scepticism when questioned about similarities between his thought and the philosophies of Henri Bergson柏格森1859-1941,Francis Herbert Bradley布拉德雷1846-1924,or Alfred North Whitehead怀特海1861-1947.展开更多
文摘This paper explores the compatibility of the Income Inclusion Rule(IIR)and the Undertaxed Profits Rule(UTPR)with existing tax treaties.The paper first assesses whether the taxes under IIR and UTPR meet the coverage criteria of Art.2 of the OECD Model Convention(MC)and then analyses potential treaty infringements,focusing on Art.7,9,and 10(5),highlighting the inherent contradiction between tax treaties,which aim to limit taxing rights,and the global minimum tax,which allows taxation of global profits.Next,the paper reviews the historical development of IIR and UTPR,emphasising the OECD's initial recognition of the need for treaty amendments but noting the current lack of multilateral solutions,which poses potential dispute risks.In conclusion,the paper argues that the global minimum tax presents compliance challenges and legal uncertainties,questioning the binding effect of double taxation agreements.The article calls on the OECD to resolve these uncertainties through international agreements and advises countries to carefully consider the legal implications when implementing the IIR and the UTPR.
文摘跨学科研究在管理学理论发展过程中一直扮演着重要角色,但这种研究方法对管理学科的理论建构以及管理学科的合法性会产生什么样的影响呢?本期发表的3篇译文是2009年发表于Journal of Management Studies第46卷第6期的一个有关在管理领域开展跨学科研究的专题讨论,第一篇短文是编辑对该专题的简要说明,另外两篇论文是学者们围绕跨学科研究方法对于管理学科发展的意义所进行的针锋相对的讨论,其观点颇具启发性,特编发译文以飨读者。
文摘Companies operating across borders face greater challenges in ensuring compliance with company strategy in different cultural contexts. Recent research shows the cognitive and emotional benefits of utilizing visual representations of knowledge in organizations. This study aims to test if mapping a corporate strategy visually can improve attitudes toward firm strategy and the intention to comply with it. An experiment is conducted comparing two knowledge maps to a textual version of the same company strategy. In order to measure attitudes toward the strategy, a scale was developed and tested in Europe and China. The study outcome provides a parsimonious and effective tripartite scale of attitude with cognitive, affective and behavioral components. The scale was then applied to a different sample to test the effect of mapping a company strategy visually on attitude toward the strategy, and to test if the effect is persistent in Europe and China. The results of the experiment show that subjects exposed to the visual conditions had significantly more positive affective and cognitive attitudes toward the content.
文摘Xiong Shili熊十力1885-1968 is not an easily accessible Chinese thinker.Contrary to most of his contemporaries as well as his students,he never attempted to express his views by means of a philosophy or a vocabulary brought to China from outside.Rather,he is reported to have expressed scepticism when questioned about similarities between his thought and the philosophies of Henri Bergson柏格森1859-1941,Francis Herbert Bradley布拉德雷1846-1924,or Alfred North Whitehead怀特海1861-1947.
