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734 Uppsatser om Arm\'s length principle - Sida 1 av 49

Den korta armen : En studie i mångfald och armlängdsavstånd i kultursamverkansmodellen

The name of the study means ?The short arm - a study in diversity and arm?s length in the cultural collaboration model?. Right now there is a reform in the Swedish cultural administration where the responsibility for handing out state funds and grants to cultural organizations is changing from the state government to the local regional governments. The purpose of this study is to map the organisational changes caused by the reform and investigate how this affects the regional policies concerning cultural diversity and the arm?s length principle.

Armlängdsprincipen och Statens kulturråd: En fallstudie om maktfördelning i svensk kulturpolitik

This Masters Thesis is about the Swedish National Council for Cultural Affairs and the arms length principle. The principle is used to explain the separation of power between two parts with a common interest. The main purpose is to elucidate if, and if so in what way, the arms length principle can be used to explain the relation between the National Council for Cultural Affairs and the Ministry of Education and Culture, i.e. the Swedish government, but also to examine the structures of power and relations within the Council. In the thesis we show that in the field of cultural policy the content of the arm lengths principle varies due to the many interpretations of the meaning.

Kunskap om marknaden : Besöksattraktioners vikt och dess relation till turistmålgrupp och resesyfte

The name of the study means ?The short arm - a study in diversity and arm?s length in the cultural collaboration model?. Right now there is a reform in the Swedish cultural administration where the responsibility for handing out state funds and grants to cultural organizations is changing from the state government to the local regional governments. The purpose of this study is to map the organisational changes caused by the reform and investigate how this affects the regional policies concerning cultural diversity and the arm?s length principle.

Tillämpningen av armlängdsprincipen : En studie om hur tillämpningen av armlängdsprincipen påverkas av Skatteverkets ökade fokus på internprissättning

The arm?s length principle has existed in Swedish law since 1928 but has previously been given little attention. In 2007, documentation requirements were introduced, and the government began to do tax audits regarding transfer pricing. This thesis examines how the documentation requirements and tax audits affect the application of the arm's length principle. The research consists of nine interviews with a total of ten people at the tax authority (Skatteverket) and audit- and consulting agencies. The results of the interviews are analyzed using the agency theory. Many companies are risk averse and prefer having correct transfer pricing instead of taking on challenging strategies that can be risky in case of an investigation by Skatteverket.

Vilka effekter har lojalitetsprogram på kundlojalitet? : En studie om frequent flyer-program och deras effekt på kunderna

The arm?s length principle has existed in Swedish law since 1928 but has previously been given little attention. In 2007, documentation requirements were introduced, and the government began to do tax audits regarding transfer pricing. This thesis examines how the documentation requirements and tax audits affect the application of the arm's length principle. The research consists of nine interviews with a total of ten people at the tax authority (Skatteverket) and audit- and consulting agencies. The results of the interviews are analyzed using the agency theory. Many companies are risk averse and prefer having correct transfer pricing instead of taking on challenging strategies that can be risky in case of an investigation by Skatteverket.

Analys och modellering av ljusbåglängdsregleringen i pulsad MIG/MAG-svetsning

This master thesis deals with problems in the arc length control in Pulsed MIG/MAG Welding. The main problem is that it is not possible to measure the arc length. In the present solution the voltage over both the electrode and the arc represents the arc length. To improve the arc length control a model of the electrode melting has been built. One output from the model is the voltage over the electrode and with this voltage together with the measured voltage it is possible to calculate the voltage over just the arc.

Internprissättning på lån inom multinationella koncerner - En kvalitativ studie av det svenska rättsläget

Due to the growth of multinational concerns during the last decades, with large parts of international trade involving such corporations, the field of transfer pricing, including financial transactions such as internal loans, have received a great deal of attention in tax legislation. The internationally accepted foundation for transfer pricing is the so called Arm's length principle, expressed in Swedish law through the "Korrigeringsregeln". In the Diligentia court case, the concepts of transparency and control were given a crucial role in the calculation of an Arm's length's price of interest rates. The Swedish tax agency interpreted the ruling in that case as if a parent company always can be assumed to enjoy sufficient transparency and control to reduce the risk on their debt obligations. A great deal of uncertainty therefore surrounded their position and to what extent the Diligentia-ruling could be cited as precedent.

Why be an Eleatic Stranger?

In the last two decades something called ?the Eleatic Principle? has been quite frequent in philosophical literature. A wide range of philosophers have appealed to this principle when arguing for varioustheses but the principle itself has received comparatively little attention. Especially questions regarding the principle's justificationare often ignored or only mentioned in passing. The aim of this paper is to remedy this situation somewhat by focusing on how it could be justified.In section 2 I give an overview of the various ways in which the principle has been used to clarify just what we are dealing with here.

Dokumentationskrav vid internprissättning : En analys av lagförslagen till svenska dokumentationsregler i propositionen 2005/06:169

According to the arm?s length principle, transactions between associated multinational en-terprises (MNE) shall be based on the same conditions as transactions between unrelated parties. This means that intra-group prices on cross-boarding transactions must be at arm?s length range and consistent with conditions in the open market. The arm?s length principle is expressed in article 9.1 of the OECD Model Tax Convention and Chapter 14 section 19 of the Swedish Income Tax Act.When transfer pricing between associated MNEs is not reflecting the arm?s length princi-ple, states face the possibility of losing tax revenue.

Numerisk modell för global transport av spårämnen i atmosfären

The aim of this project was to develop a numerical model simulating the global transport of air pollution. The model currently used by SMHI, the Swedish Meteorological and Hydrological Institute, was intended to perform such simulations at regional scales. However, the usage of a grid based on longitudes and latitudes makes this model work poorly in global simulations. The problem with this grid is that the nodes are concentrated near the North and South Poles. Due to this characteristic, the Courant, Friedrich and Lewy-condition for numerical stability puts a sharp bound on the timestep length.

Kronandelsrelaskopering, en ny metod för att fastställa gallringsbehov?

In today´s forestry, assessments of needs for thinning are based on basal area measurements. This is an indirect measurement. The approach and the developed assessment tables are based on an assumed production forest, which implies that management proposals in stands that deviate from the basic model may be misleading. Since Walter Bitterlich in 1948 launched the idea of the relascope, several modifications have been developed for different purposes. In common is that all are based on a certain angle measurement principle.

Demokratins avgränsningsproblem : En kritik av det kosmopolitiska demokratiidealet

The aim of this paper is to examine whether the theory of cosmopolitan democracy provides a satisfactory solution to the boundary problem in democratic theory. I argue that David Held's version of cosmopolitan democracy rests on two incompatibleprinciples: the all-affected principle and the all-inclusive principle. However, the theory does not need to presuppose both these principles; it requires only one of them.Furthermore, I try to show that both of these principles fail to provide an adequate solution to the boundary problem. The all-inclusive principle suggests that all citizens of the world should be included in a global democratic unit. I argue that such an ideal is not desirable since it conflicts with the principle of subsidiarity and withdraws from regional political communities their sovereignty.

Kvalitativ analys av Holmen Skogs internprissättningsmodell :

Transfer pricing has attracted considerable interest among tax authorities in recent years. One of the reasons for this is that various countries have now begun to protect their own tax bases to a greater extent than they did in the past. Sweden has introduced a law on the documentation on the grounds that the tax office to review the pricing of transactions that occur within multinational corporations. The purpose of the law is that companies should apply a transfer pricing that meet arm's length principle, which means that internal pricing reflects market prices. The EU Commission has, together with the EU member states formed a Forum, the EU Joint Transfer Pricing Forum (JTPF), since cross-border trade within groups constitute a threat to the internal market. The Forum has drawn up a code of conduct which includes a model of documentation.

Principen mot rättsmissbruk inom det svenska mervärdesskatteområdet: är det hållbart?

The VAT Directive (2006/112/EC) does not regulate Member States? opportunities to intervene against tax evasion. The European Court of Justice has clarified the situation in case C-255/02 Halifax. This case establish that the universal principle against the abuse of rights applies to VAT, which means that Member States have the opportunity to redefine transactions not involving a breach of law but nevertheless goes past what the legislature envisaged at the introduction of the provision.A debate has risen as to whether the principle against the abuse of rights is equally ap-plicable in Swedish domestic law on VAT. The administrative court of appeal in Go-thenburg, Case No.

Operation Moked : Sexdagarskriget ? Överraskning inom de israeliska luftoperationerna

The research regarding the six day war and the aerial operations named Operation Moked is extensive but there are certain shortcomings in the research that examines both the operation and the principle of surprise.The aim of this paper is to contribute to this research by utilising existing military theories on the principle of surprise in order to identify indicators that are representative of surprise.  These indicators are thereafter used in a study of Operation Moked in order to examine the extent of in which the principle was utilised.The result of this research goes to show that the principle of surprise was utilised in great extent by Israel during Operation Moked..

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