An analysis of how the voice was explored and problematized in literary and artistic practice during the Cold War period, in the wake of sound recording technology's breakthrough in everyday life, and, most prominently, through the use of magnetic recording.
Chapter 14 § 19 of the Swedish income taxation act, also known as the “cor-rection rule”, states that when the result of a business is lower than it should be because a contractual term deviates from what would be the contractual terms between independent businesses, the result shall be calculated as if such contractual terms did not exist. The rule is a manifestation of the international-ly recognized principle called the arm’s length principle. However, for the rule to be applicable it is further required that the income received from the benefi-cial contractual terms is not taxed in Sweden. It is also a prerequisite for the application of the correction rule that the contractual parties are associated en-terprises as defined in chapter 14 § 20 of the Swedish income taxation act. The third and final requirement for the application of the rule is that the bene-ficial contractual terms has no legitimate reason. This thesis aims to examine what further actions may be required to determine accurate taxation after the application of the correction rule in chapter 14 § 19 of the Swedish income taxation act. Especially in regard to the newly introduced general interest de-duction limitation rules. To fulfill the purpose of the thesis I have chosen a traditional legal method where authoritative sources of law are investigated to determine established law.
One of the more difficult aspects of the application of the correction rule is determining the market price. Swedish internal law is lacking in governance but according to precedents from the Supreme Administrative Court of Swe-den guidance may be derived from the OECD Transfer Pricing Guidelines. The usage of the OECD Transfer Pricing Guidelines could be seen as contro-versial from a constitutional law perspective.
As mentioned before the arm’s length principle is an international principle and several other countries have internal tax legislation similar to the Swedish correction rule. Within the EU this is of certain importance since even internal tax rules are required to align with EU-law. It seems most likely that the Swe-dish correction rule is in accordance with EU-law and as a consequence there is no hinderance for its application. However, it seems to be an interesting area where development could take place in the future.
To maintain an overview of whether multinational enterprises use arm’s length transfer pricing there are certain documentation requirements. The im-portance of the documentation should become more important in the future since the Swedish Tax Agency is of the opinion that the correct maintenance and usage of the documentation are grounds for reduction of or exemption from tax penalties.
The tax procedure in transfer pricing cases ought to have its basis for the most part in the institute of reconsideration. In many cases non arm’s length pricing is considered erroneous information which raises questions regarding tax as-sessments and tax penalties. This can however not be said in all cases since the mandated investigation duty of the Swedish Tax Agency could arise in case of an open claim. The frames of the tax procedure in transfer pricing cas-es could also be considered to be somewhat wider than other taxation cases because of the offset transactions which in precedents set down by the Su-preme Administrative Court of Sweden may be extended over several taxation years. This is a departure from the principle that transactions one taxation year may not affect another taxation year otherwise maintained in tax cases. The effect is a wider procedural frame where the correction rule is applied.
In accordance with the new general interest deduction rules only 30 percent of negative net interest will be deductible. The basis for the calculation of the deductible interest is the taxable result. Since an application of the correction rule affects the taxable result the tax deduction rules should also be affected by its application.
The application of the correction rule on the interest of an internal loan within a multinational enterprise group could potentially require multiple following actions to determine correct taxation. The reason for this is that the interest could affect not only the basis for the deduction of interest but the net interest that should be accounted for in accordance with chapter 24 § 23 of the Swe-dish taxation act.
Examines the relationship between geographic and linguistic border crossings in twentieth-century literature. This book reveals both the range of creative strategies developed in response to the interstitial situation of exile and the crucial role of exile for a renewed understanding of twentieth-century literature.
At the time of writing, it is April 2020 and large parts of the world are in various stages of Corona-lockdown.Both the severity of the penetration of the virus itself as well as the severity of the measures to combat it varies across the globe, but increasingly everywhere lives are turned upside down.Normality is suspended and it is frequently pronounced that the world will not look the same on the other side of this crisis.While we are launching a new volume, the current situation also gives renewed actuality to some of our previous publications.Not least, one of our 2016 issues is worth revisiting: Rupture and Exile: Permanent Liminality in Spaces for Movement and Abandonment, edited by Harmony Siganporia and Frank G. Karioris (Volume 8, issue 1).This thematic section is centred on liminality, a concept with which every sociocultural anthropologist and many other social and cultural theorists are well acquainted.Liminality is a concept that is most usually attributed to Arnold van Gennep (1873-1957) and his Les Rites de Passage (1909), but it is also tightly associated with Victor Turner and his The Forest of Symbols (1967) or (perhaps especially) The Ritual Process (1969).While Turner departed from a discussion of liminality as primarily an attribute of rites of passage, he also expanded the concept to include "a greater variety of ambiguous situations, epochs, and spaces that might be read as liminal" (Siganporia & Karioris 2016).Van Gennep had a three-stage model of rites of passage: separation, margin/ liminality and reintegration.It is in this middle stage we find liminality.Liminality is from Latin limen meaning threshold.It is the boundary between the outside and the inside, between two entities that are separated from one another.A rite of passage is a transition from something old to something new, and liminality is the state of neither nor in between the old and the new.In the case of initiation rites-neither child nor adult.Liminality is marked by ambiguity, uncertainty
Regarding the Popular charts the complex relationship between the avant-gardes and modernisms on the one hand and popular culture on the other. Covering (neo-)avant-gardists and modernists from various European countries, this second volume in the series European Avant-Garde and Modernism Studies explores the nature of so-called low culture, dealing with aspects as diverse as the everyday and the folkloric. Regarding the Popular charts the many ways in which the allegedly high modernists and avant-gardists looked at and represented the low. As such, this book will appeal to all those with an interest in the dynamic of modern experimental arts and literatures.
