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The Compatibility of Limitation on Benefits Provisions in Tax Treaties with EC Law

Most bilateral tax treaties contain provisions with the objective of preventing different types of treaty abuse. Limitation on benefits clauses are an example of such provisions, and are generally found in United States tax treaties. These include various tests, which need to be fulfilled by a taxpayer wishing to enjoy the benefits of a tax treaty. Most of the United States tax treaties with EU Me

"Den som sa det han var det"- Om prövning av erkännanden ur ett rättssäkerhetsperspektiv

”Den som sa det han var det”. Ett klassiskt svenskt ordspråk företrädelsevis populärt bland barn att dra till med när argumentationen tagit slut i en hetsig diskussion. Men också en ypperlig titel på denna uppsats då den ger uttryck för en mycket vanlig uppfattning; den som erkänner brott måste också vara skyldig till detsamma. I Rättegångsbalken stadgas det att ett erkännande i brottmål endast tj"Den som sa det han var det." A classic Swedish saying, especially popular amongst children when found themselves run out of arguments in a heated discussion. But also an excellent title for this paper as it reflects a very common belief; the one who confesses a crime must also be guilty of the same. The Swedish law states that a confession in criminal cases only serve as evidence, which

Taking ERP to ROI How to Benefit from ERP Investments

Problem definition Even though a great deal of research have been done exploring the ERP field, companies still have a hard time determining and obtaining the full potential scope of benefits that comes with a fully working ERP system. Implementing an ERP system is like changing a heart while the patient still is running. It is therefore hard to measure the benefits and the improved efficiencies,

Pricing from a 4PL perspective

Title Pricing from a 4PL perspective
Authors Louise Kjellberg and Maria Björholt, master students at Industrial Engineering and Management, Lund university
Supervisors Jenny Sjöholm, Logistics Developer, Schenker Dedicated Services AB
Dr. Andreas Norrman, Professor in Engineering Logistics, Department of Industrial Management and Logistics, the Faculty of Engineering at Lund Univers

Importance Sampling in Wireless Communication Systems with Ultra-Low Error Rates

Simulation mimics the behaviour of real world processes or the system over time. It helps us to understand the impact of modification and the effect of introducing various interventions to a system. One such simulation method is known as Monte Carlo (MC) simulation, which has been utilized to evaluate the performance of digital communication systems over the last 70 years. MC has been the most ex

Control of Hybrid Electric Vehicles with Diesel Engines

This thesis is an approach to improve electric hybrid vehicles with respect to fuel consumption and to fulfil the future intended NOX emission regulations. It is based upon the conclusions made in the licentiate thesis Analysing Hybrid Drive System Topologies (Jonasson, 2002). The study in this thesis is restricted to a parallel hybrid vehicle equipped with a diesel engine, two electric machines

Physical properties and processes of secondary organic aerosol and its constituents

Atmospheric aerosol particles are involved in several important processes including the formation of clouds and precipitation. A considerable fraction of the ambient aerosol mass consists of organic compounds of both primary and secondary origin. These organic compounds are often semi-volatile and susceptible to oxidation which makes the organic aerosol a dynamic system, both chemically and physic

A knowledge process perspective on the improvement of software processes

Popular Abstract in Swedish I och med att mjukvarubaserade produkter ökar i antal ökar också vikten av en effektiv mjukvaruutvecklingsprocess, ur ett konkurrensperspektiv. Bristfällig produktkvalitet och höga utvecklingskostnader är något som mjukvaruutvecklingsorganisationer under många år har kämpat med. Studier inom SPI (software process improvement) syftar till att förbättra produktkvalitet oc

EVALUATION OF BIOLOGICAL STRATEGIES TO ENHANCE HYDROLYSIS DURING ANAEROBIC DIGESTION OF COMPLEX WASTE

Anaerobic digestion (AD) offers considerable potential in the production of energy from renewable sources, and is being increasingly recognised as a sustainable technology for the treatment of waste. The production of energy from waste such as municipal solid waste (MSW), lipid-rich waste, and agricultural biomass and waste may play an important role in the production of renewable energy given the

Comparison of conventional and Si-photomultiplier-based PET systems for image quality and diagnostic performance

BACKGROUND: A new generation of positron emission tomography with computed tomography (PET-CT) was recently introduced using silicon (Si) photomultiplier (PM)-based technology. Our aim was to compare the image quality and diagnostic performance of a SiPM-based PET-CT (Discovery MI; GE Healthcare, Milwaukee, WI, USA) with a time-of-flight PET-CT scanner with a conventional PM detector (Gemini TF; P

Acute tissue reactions, inner segment pathology, and effects of the antioxidant α1-microglobulin in an in vitro model of retinal detachment

The purpose of this study was to explore acute tissue reactions, ultrastructural photoreceptor morphology with emphasis on inner segments, and the effect of antioxidant treatment in an in vitro model of rhegmatogenous retinal detachment (RRD). A previously described method of RRD simulation was used with adult retinal porcine explants kept free-floating in culture medium with or without treatment

Case and sequence in coordination : A corpus-based study of English and Danish

Although much research has been done on case and sequence within coordination structures separately, few studies have investigated the impact the two have on each other. Moreover, very little research has dealt with the striking similarity of English and Danish regarding case and sequence within CoDPs. This thesis, therefore, aimed to explore this matter to uncover the complex system which determi

Intrauterine Blood Flow and Postnatal Development

An increasing number of long-term follow-up studies of growth-restricted infants has been published during the recent years. This chapter reviews implications of abnormal fetal blood flow in fetal growth restriction (FGR) on postnatal development. The majority of follow-up studies has focused on examining relationships between absent or reverse end-diastolic flow in the umbilical artery or the fet

Feasibility of ActivABLES to promote home-based exercise and physical activity of community-dwelling stroke survivors with support from caregivers : A mixed methods study

BACKGROUND: Technical applications can promote home-based exercise and physical activity of community-dwelling stroke survivors. Caregivers are often able and willing to assist with home-based exercise and physical activity but lack the knowledge and resources to do so. ActivABLES was established to promote home-based exercise and physical activity among community-dwelling stroke survivors, with s

Self-Reported Shorter Than Desired Ejaculation Latency and Related Distress—Prevalence and Clinical Correlates : Results From the European Male Ageing Study

Background: Few data have looked at the occurrence and clinical correlates of self-reported shorter than desired ejaculation latency (rapid ejaculation, RE) and its related distress in the general population. Aim: To determine the prevalence and clinical correlates of self-reported RE and RE- related distress in middle age and older European men. Methods: Subjects were recruited from population sa

OGS2: genome re-annotation of the jewel wasp Nasonia vitripennis

Nasonia vitripennis is an emerging insect model system with haplodiploid genetics. It holds a key position within the insect phylogeny for comparative, evolutionary and behavioral genetic studies. The draft genomes for N. vitripennis and two sibling species were published in 2010, yet a considerable amount of transcriptiome data have since been produced thereby enabling improvements to the origina

The effect of functional capacity and concomitant medications on life expectancy in Alzheimer’s disease.

Background: An increased knowledge of predictors that might affect survival in Alzheimer’s disease (AD) patients treated with cholinesterase inhibitors (ChEIs) is important for clinicians and for the health services. Impairment in activities of daily living (ADL), somatic diseases, and psychiatric symptoms may influence mortality in AD. We aimed to study the impact of functional capacity and conco

Breast cancer screening with digital breast tomosynthesis : comparison of different reading strategies implementing artificial intelligence

OBJECTIVES: Digital breast tomosynthesis (DBT) can detect more cancers than the current standard breast screening method, digital mammography (DM); however, it can substantially increase the reading workload and thus hinder implementation in screening. Artificial intelligence (AI) might be a solution. The aim of this study was to retrospectively test different ways of using AI in a screening workf

Formation of planetary systems by pebble accretion and migration : Growth of gas giants

Giant planets migrate though the protoplanetary disc as they grow their solid core and attract their gaseous envelope. Previously, we have studied the growth and migration of an isolated planet in an evolving disc. Here, we generalise such models to include the mutual gravitational interaction between a high number of growing planetary bodies. We have investigated how the formation of planetary s