Problems Involving Permanent Establishments: Overview of Relevant Issues in Today’s International Economy

The present article analyzes the most common problems related to the Permanent Establishment (PE) concept in International Tax in current modern economy, after the booming of e-commerce, the consolidation of the globalization process, and the new attempts to update and improve such concept in double tax treaties. For that purpose, this article addresses the structure of Article 5 of the OECD Model Tax Convention and gives readers an overview of the concepts, definitions, and problems arising from each of the Article 5 paragraphs of such Model Convention. After such overview, it examines the hottest topics in today‟s international economy that are creating new PE problems, like e-commerce, attribution of profits under new Transfer Pricing methods, and the Service PE rule. Lastly, it analyzes the recent OECD discussion draft on interpretation and application of Article 5 of the OECD Model Convention and its developments to current problems. It concludes with reference to the most known issues on each PE topic, and an opinion on what should be improved in each sub-area of the Permanent Establishment article in tax treaties

Pyramidal Fisher Motion for Multiview Gait Recognition

Submitted to International Conference on Pattern Recognition, ICPR, 2014The goal of this paper is to identify individuals by analyzing their gait. Instead of using binary silhouettes as input data (as done in many previous works) we propose and evaluate the use of motion descriptors based on densely sampled short-term trajectories. We take advantage of state-of-the-art people detectors to define custom spatial configurations of the descriptors around the target person. Thus, obtaining a pyramidal representation of the gait motion. The local motion features (described by the Divergence-Curl-Shear descriptor) extracted on the different spatial areas of the person are combined into a single high-level gait descriptor by using the Fisher Vector encoding. The proposed approach, coined Pyramidal Fisher Motion, is experimentally validated on the recent `AVA Multiview Gait' dataset. The results show that this new approach achieves promising results in the problem of gait recognition

Fisher Motion Descriptor for Multiview Gait Recognition

The goal of this paper is to identify individuals by analyzing their gait. Instead of using binary silhouettes as input data (as done in many previous works) we propose and evaluate the use of motion descriptors based on densely sampled short-term trajectories. We take advantage of state-of-the-art people detectors to de ne custom spatial con gurations of the descriptors around the target person, obtaining a rich representation of the gait motion. The local motion features (described by the Divergence-Curl-Shear descriptor [1]) extracted on the di erent spatial areas of the person are combined into a single high-level gait descriptor by using the Fisher Vector encoding [2]. The proposed approach, coined Pyramidal Fisher Motion, is experimentally validated on `CASIA' dataset [3] (parts B and C), `TUM GAID' dataset [4], `CMU MoBo' dataset [5] and the recent `AVA Multiview Gait' dataset [6]. The results show that this new approach achieves state-of-the-art results in the problem of gait recognition, allowing to recognize walking people from diverse viewpoints on single and multiple camera setups, wearing di erent clothes, carrying bags, walking at diverse speeds and not limited to straight walking paths

A theoretical study of the cluster glass-Kondo-magnetic disordered alloys

The physics of disordered alloys, such as typically the well known case of CeNi1-xCux alloys, showing an interplay among the Kondo effect, the spin glass state and a magnetic order, has been studied firstly within an average description like in the Sherrington-Kirkpatrick model. Recently, a theoretical model (PRB 74, 014427 (2006)) involving a more local description of the intersite interaction has been proposed to describe the phase diagram of CeNi1-xCux. This alloy is an example of the complex interplay between Kondo effect and frustration in which there is in particular the onset of a cluster-glass state. Although the model given in Ref. PRB 74, 014427 (2006) has reproduced the different phases relatively well, it is not able to describe the cluster-glass state. We study here the competition between the Kondo effect and a cluster glass phase within a Kondo Lattice model with an inter-cluster random Gaussian interaction. The inter-cluster term is treated within the cluster mean-field theory for spin glasses, while, inside the cluster, an exact diagonalisation is performed including inter-site ferromagnetic and intra-site Kondo interactions. The cluster glass order parameters and the Kondo correlation function are obtained for different values of the cluster size, the intra-cluster ferromagnetic coupling and the Kondo intra-site coupling. We obtain, for instance, that the increase of the Kondo coupling tends to destroy the cluster glass phase.Comment: 6 pages, 2 figures, Accepted for publication in Physica

Density-dependent effects on the survival and growth of the rodent stomach worm Protospirura muricola in laboratory mice

The spirurid nematode, Protospirura muricola, is of intrinsic interest as a rodent model of gastric nematode infections. Since worm burdens can be very heavy in nature, density dependent processes may constrain parasite growth. Laboratory mice (BKW) were exposed to varying doses of infective larvae of P. muricola in the range 5 to 40 third-stage larvae (L3), in four separate experiments in which progressively higher doses were utilized. All mice were culled 60 days after infection and a total of 518 worms (226 male and 292 female worms) was recovered, measured and weighed. Overall survival was 58.9%, but survival declined significantly with increasing dose by approximately 21% (from 66% at 5 L3 per mouse to 52% at 40 L3 per mouse). The length and weight of worms correlated positively in both sexes. Total worm biomass increased linearly with increasing numbers of worms. However, whilst the length and weight of male worms declined with increasing worm burden (8.4 and 24.6% respectively), female worms were less affected, only length showing a significant reduction with increasing parasite burden (16.0%). Therefore, increasing worm burdens impeded growth of P. muricola, but reduction in length and weight were relatively small in relation to the overall size of this nematode. Increasing worm burdens were associated with loss of host weight and reduction in stomach weight and worm burdens in excess of 20 exerted a measurable cost to the host, which in the field, may be associated with loss of overall host fitness

Formation of Ceramide/Sphingomyelin Gel Domains in the Presence of an Unsaturated Phospholipid: A Quantitative Multiprobe Approach

AbstractTo better understand how ceramide modulates the biophysical properties of the membrane, the interactions between palmitoyl-ceramide (PCer) and palmitoyl-sphingomyelin (PSM) were studied in the presence of the fluid phospholipid palmitoyl-oleoyl-phosphatidylcholine (POPC) in membrane model systems. The use of two fluorescent membrane probes distinctly sensitive to lipid phases allowed a thorough biophysical characterization of the ternary system. In these mixtures, PCer recruits POPC and PSM in the fluid phase to form extremely ordered and compact gel domains. Gel domain formation by low PCer mol fraction (up to 12mol %) is enhanced by physiological PSM levels (∼20–30mol % total lipid). For higher PSM content, a three-phase situation, consisting of fluid (POPC-rich)/gel (PSM-rich)/gel (PCer-rich) coexistence, is clearly shown. To determine the fraction of each phase a quantitative method was developed. This allowed establishing the complete ternary phase diagram, which helps to predict PCer-rich gel domain formation and explains its enhancement through PSM/PCer interactions

Chemokines and pain in the trigeminal system

Chemotactic cytokines or chemokines are a large family of secreted proteins able to induce chemotaxis. Chemokines are categorized according to their primary amino acid sequence, and in particular their cysteine residues that form disulphide bonds to maintain the structure: CC, CXC, CX3C, and XC, in which X represents variable amino acids. Among their many roles, chemokines are known to be key players in pain modulation in the peripheral and central nervous systems. Thus, they are promising candidates for novel therapeutics that could replace current, often ineffective treatments. The spinal and trigeminal systems are intrinsically different beyond their anatomical location, and it has been suggested that there are also differences in their sensory mechanisms. Hence, understanding the different mechanisms involved in pain modulation for each system could aid in developing appropriate pharmacological alternatives. Here, we aim to describe the current landscape of chemokines that have been studied specifically with regard to trigeminal pain. Searching PubMed and Google Scholar, we identified 30 reports describing chemokines in animal models of trigeminal pain, and 15 reports describing chemokines involved in human pain associated with the trigeminal system. This review highlights the chemokines studied to date at different levels of the trigeminal system, their cellular localization and, where available, their role in a variety of animal pain models

Establishment and neural differentiation of neural crest-derived stem cells (NCSCs) from human dental pulp in serum-free conditions

The potential of obtaining cell cultures with neural crest resemblance (neural crest-derived stem cells; NCSCs) from dental-related tissues, including human dental pulp cells (hDPCs) has been discussed in the literature. However, most reports include the use of serum-rich conditions and do not describe the potential for neural differentiation, slowing translation to the clinic. Therefore, we aimed to culture and characterize NCSCs from the human dental pulp in vitro and evaluate their ability to differentiate into neurons; we also investigated the effectiveness of the addition of BMP4 to enhance this potential. Cultures were established from a varied cohort of patient samples and grown, as monolayers, in serum, serum-free and also under sphere-aggregation conditions to induce and identify a NCSC phenotype. hDPC cultures were characterized by immunocytochemistry and reverse transcription quantitative polymerase chain reaction. Monolayer cultures expressed stem cell, neural progenitor and neural crest-related markers. Culturing hDPCs as neurospheres (hDPCNCSCs) resulted in an increased expression of neural crest-related genes, while the addition of BMP4 appeared to produce better NCSC characteristics and neural differentiation. The neural-like phenotype was evidenced by the expression of TUJ1, peripherin, NFH, TAU, SYN1 and GAP43. Our results describe the establishment of hDPC cultures from a large variety of patients in serum-free medium, as NCSC that differentiate into neural-like cells, as well as an important effect of BMP4 in enhancing the neural crest phenotype and differentiation of hDPCs