Reforming the taxation of multijurisdictional enterprises in Europe: a tentative appraisal

In 2001, the European Commission proposed replacing the current system of taxation of multinational companies by the taxation of a consolidated base, computed at the level of all the European entities of a multijurisdictional enterprise, and then distributed for taxation purposes between the various jurisdictions in which these entities operate, according to pre-established criteria. This paper proposes a tentative appraisal of that reform based on a case study and an analytical exercise. There is a particular focus on two related issues, the choice of the formula and the composition of the consolidating area - either the entire EU or some Member States within an Enhanced Cooperation Agreement -, and on their impact on the size and interjurisdictional distribution of tax revenue and social welfare, and on the intensity of tax competition.The tentative policy conclusion is that this paper supports the reform provided that (1) the formula puts emphasis on criteria that the firm may not too easily manipulate, (2) the activities of the multijurisdictional enterprise are enough mobile, (3) the consolidation is made compulsory within the consolidating area, and (4) the consolidating area protects its capacity to actually levy tax by adopting a crediting system vis-à-vis the rest of the world.multinational enterprises, multinational companies, multijurisdictional enterprises, European taxation, tax consolidation, tax competition

Neural Modeling and Control of Diesel Engine with Pollution Constraints

The paper describes a neural approach for modelling and control of a turbocharged Diesel engine. A neural model, whose structure is mainly based on some physical equations describing the engine behaviour, is built for the rotation speed and the exhaust gas opacity. The model is composed of three interconnected neural submodels, each of them constituting a nonlinear multi-input single-output error model. The structural identification and the parameter estimation from data gathered on a real engine are described. The neural direct model is then used to determine a neural controller of the engine, in a specialized training scheme minimising a multivariable criterion. Simulations show the effect of the pollution constraint weighting on a trajectory tracking of the engine speed. Neural networks, which are flexible and parsimonious nonlinear black-box models, with universal approximation capabilities, can accurately describe or control complex nonlinear systems, with little a priori theoretical knowledge. The presented work extends optimal neuro-control to the multivariable case and shows the flexibility of neural optimisers. Considering the preliminary results, it appears that neural networks can be used as embedded models for engine control, to satisfy the more and more restricting pollutant emission legislation. Particularly, they are able to model nonlinear dynamics and outperform during transients the control schemes based on static mappings.Comment: 15 page

Differential memory persistence of odor mixture and components in newborn rabbits: competition between the whole and its parts

Interacting with the mother during the daily nursing, newborn rabbits experience her body odour cues. In particular, the mammary pheromone (MP) contained in rabbit milk triggers the typical behaviour which helps to localize and seize the nipples. It also promotes the very rapid appetitive learning of simple or complex stimuli (odorants or mixtures) through associative conditioning. We previously showed that 24h after MP-induced conditioning to odorants A (ethyl isobutyrate) or B (ethyl maltol), newborn rabbits perceive the AB mixture in a weak configural way, i.e. they perceive the odour of the AB configuration in addition to the odours of the elements. Moreover, after conditioning to the mixture, elimination of the memories of A and B does not affect the memory of AB, suggesting independent elemental and configural memories of the mixture. Here, we evaluated whether configural memory persistence differs from elemental one. First, whereas 1 or 3-day-old pups conditioned to A or B maintained their responsiveness to the conditioned odorant for 4 days, those conditioned to AB did not respond to the mixture after the same retention period. Second, the pups conditioned to AB still responded to A and B 4 days after conditioning, which indicates stronger retention of the elements than of the configuration when all information are learned together. Third, we determined whether the memory of the elements competes with the memory of the configuration: after conditioning to AB, when the memories of A and B were erased using pharmacological treatment, the memory of the mixture was extended to day 5. Thus, newborn rabbits have access to both elemental and configural information in certain odour mixtures, and competition between these distinct representations of the mixture influences the persistence of their memories. Such effects certainly occur in the natural context of mother-pup interactions and may contribute to early acquisition of knowledge about the surroundings

Effect of Technetium-99 sources on its retention in low activity waste glass

Small-scale crucible melting tests on simulated waste glass were performed with technetium-99 (Tc-99) introduced as different species in a representative low activity waste simulant. The glass saw an increase in Tc-99 retention when TcO2∙2H2O and various Tc-minerals containing reduced tetravalent Tc were used compared to tests in which pertechnetate with heptavalent Tc was used. We postulate that the increase of Tc retention is likely caused by different reaction paths for Tc incorporation into glass during early stages of melting, rather than the low volatility of reduced tetravalent Tc compounds, which has been a generally accepted idea. Additional studies are needed to clarify the exact mechanisms relevant to the effect of reduced Tc compounds on Tc incorporation into or volatilization from the glass melt

Development of the lesbian narrative through the texts of Hall, Woolf and Winterson

In this thesis, the author examines the lesbian narratives in Radclyffe Hall's The Well of Loneliness (1928) and Virginia Woolf's Orlando (1928), and explores the legacy of these works as seen in Jeanette Winterson's Oranges Are Not the Only Fruit (1985)

Current Status of the Thermodynamic Data for Technetium and Its Compounds and Aqueous Species

{sup 99}Tc is a major fission product from nuclear reactors. Because {sup 99}Tc has few applications outside of scientific research, most of this technetium will ultimately be disposed of as nuclear waste. The radioactive decay of {sup 99}Tc to {sup 99}Ru produces a low energy {beta}{sup -} particle, but because of its fairly long half-life of t{sub 1/2} = 2.13 x 10{sup 5} years, {sup 99}Tc is a major source of radiation in low level waste. Technetium forms the soluble TcO{sub 4}{sup -} anion under oxic conditions and this ion is very mobile in groundwater, but technetium is reduced to less soluble Tc(IV) hydrolyzed species under anoxic conditions. Geochemical modeling of the dissolution of nuclear waste, and of the solubility and speciation of the dissolved radionuclides in groundwaters, is an integral part of the Performance Assessment of the safety of a nuclear waste repository, and this modeling requires a critically-assessed thermodynamic database. Such a database for technetium was published in the book Chemical Thermodynamics of Technetium, with literature coverage through 1998. This database is described herein, along with more recent relevant studies. Gaps in the knowledge of the chemical and thermodynamic properties of technetium are pointed out, and recommendations are made for measurements that are needed to eliminate these gaps

A mutation in the LAMC2 gene causes the Herlitz junctional epidermolysis bullosa (H-JEB) in two French draft horse breeds

Epidermolysis bullosa (EB) is a heterogeneous group of inherited diseases characterised by skin blistering and fragility. In humans, one of the most severe forms of EB known as Herlitz-junctional EB (H-JEB), is caused by mutations in the laminin 5 genes. EB has been described in several species, like cattle, sheep, dogs, cats and horses where the mutation, a cytosine insertion in exon 10 of the LAMC2 gene, was very recently identified in Belgian horses as the mutation responsible for JEB. In this study, the same mutation was found to be totally associated with the JEB phenotype in two French draft horse breeds, Trait Breton and Trait Comtois. This result provides breeders a molecular test to better manage their breeding strategies by genetic counselling

Potential for radionuclide immobilization in the EBS/NFE: solubility limiting phases for neptunium, plutonium, and uranium

Retardation and dispersion in the far field of radionuclides released from the engineered barrier system/near field environment (EBS/NFE) may not be sufficient to prevent regulatory limits being exceeded at the accessible environment. Hence, a greater emphasis must be placed on retardation and/or immobilization of radionuclides in the EBS/NFE. The present document represents a survey of radionuclide-bearing solid phases that could potentially form in the EBS/NFE and immobilize radionuclides released from the waste package and significantly reduce the source term. A detailed literature search was undertaken for experimental solubilities of the oxides, hydroxides, and various salts of neptunium, plutonium, and uranium in aqueous solutions as functions of pH, temperature, and the concentrations of added electrolytes. Numerous solubility studies and reviews were identified and copies of most of the articles were acquired. However, this project was only two months in duration, and copies of some the identified solubility studies could not be obtained at short notice. The results of this survey are intended to be used to assess whether a more detailed study of identified low- solubility phase(s) is warranted, and not as a data base suitable for predicting radionuclide solubility. The results of this survey may also prove useful in a preliminary evaluation of the efficacy of incorporating chemical additives to the EBS/NFE that will enhance radionuclide immobilization

Conversion of Parameters Among Variants of Scatchard's Neutral-Electrolyte Model for Electrolyte Mixtures that Have Different Numbers of Mixing Terms

Various model equations are available for representing the excess Gibbs energy properties (osmotic and activity coefficients) of aqueous and other liquid mixed-electrolyte solutions. Scatchard's neutral-electrolyte model is among the simplest of these equations for ternary systems and contains terms that represent both symmetrical and asymmetric deviations from ideal mixing behavior when two single-electrolyte solutions are mixed in different proportions at constant ionic strengths. The usual form of this model allows from zero to six mixing parameters. In this report we present an analytical method for transforming the mixing parameters of neutral-electrolyte-type models with larger numbers of mixing parameters directly to those of models with fewer mixing parameters, without recourse to the source data used for evaluation of the original model parameters. The equations for this parameter conversion are based on an extension to ternary systems of the methodology of Rard and Wijesinghe [J. Chem. Thermodyn. 35, 439-473 (2003)] and Wijesinghe and Rard [J. Chem. Thermodyn. 37, 1196-1218 (2005)] that was applied by them to binary systems. It was found that the use of this approach with a constant ionic-strength cutoff of I {le} 6.2 mol {center_dot} kg{sup -1} (the NaCl solubility limit) yielded parameters for the NaCl + SrCl{sub 2} + H{sub 2}O and NaCl + MgCl{sub 2} + H{sub 2}O systems that predicted osmotic coefficients {phi} in excellent agreement with those calculated using the same sets of parameters whose values were evaluated directly from the source data by least-squares, with root mean square differences of RMSE({phi}) = 0.00006 to 0.00062 for the first system and RMSE({phi}) = 0.00014 to 0.00042 for the second. If, however, the directly evaluated parameters were based on experimental data where the ionic strength cutoff varied with the ionic-strength fraction, i.e. because they were constrained by isopiestic ionic strengths (MgCl{sub 2} + MgSO{sub 4} + H{sub 2}O) or solubility/oversaturation ionic strengths (NaCl + SrCl{sub 2} + H{sub 2}O and NaCl + MgCl{sub 2} + H{sub 2}O), then parameters converted by this approach assuming a constant ionic-strength cutoff yield RMSE({phi}) differences about an order of magnitude larger than the previous case. This indicates that for an accurate conversion of model parameters when the source model is constrained with variable ionic strength cutoffs, an extension of the parameter conversion method described herein will be required. However, when the source model parameters are evaluated at a constant ionic strength cutoff, such as when source isopiestic data are constrained to ionic strengths at or below the solubility limit of the less soluble component, or are Emf measurements that are commonly made at constant ionic strengths, then our method yields accurate converted models