Konwencja Wielostronna (MLI) – podatkowa ewolucja czy rewolucja?

The Multilateral Convention (Multilateral Instrument to Modify Bilateral Tax Treaties – MLI) is an international agreement, which was signed on 7 June 2017 in Paris. The provisions thereof introduce a tax settlement counteracting the abuse of double taxation agreements. The aim of this article is to offer an insight into both the origin and the resolutions of MLI. In the publication, an attempt was made in order to analyse and assess the impact of the Convention on the taxation system.Konwencja Wielostronna (Multilateral Instrument to Modify Bilateral Tax Treaties – MLI) to umowa międzynarodowa, która została podpisana 7 czerwca 2017 r. w Paryżu. Zapisy Konwencji MLI wprowadzają porozumienie podatkowe zapobiegające nadużywaniu umów o unikaniu podwójnego opodatkowania. Celem opracowania jest przybliżenie genezy oraz założeń Konwencji Wielostronnej. Podjęto też próbę analizy i oceny wpływu Konwencji na system podatkowy

Protection of a Taxpayer’s Rights and the Admissible Scope of Information Provided under Article 45 (1) of the National Tax Administration Act: Approving Commentary on the Judgment of the Polish Supreme Administrative Court of 4 May 2021 (III FSK 928/21, LEX no. 3181325)

In the analyzed judgment, the Polish Supreme Administrative Court sets the limits on the tax authorities’ request for access to tax information pursuant to Article 45 (1) of the National Tax Administration Act. In the rationale for the judgment, the Court emphasized that this provision concerns a specific form of the authority’s action with respect to the collection, use, and processing of tax information. For this reason, the use of such a form of action is subject to certain restrictions. On the basis of this provision, tax authorities may not, in particular, take actions that are appropriate for formal proceedings (administrative, tax, or customs-fiscal). In the commentary, the justification of the Supreme Administrative Court was welcomed, developing the arguments supporting the main theses of the judgment and organizing the arguments presented in other judgments on this subject

Regional distribution and relevance in paleonvironmental studies of lakes in the Tatra Mts. (Western Carpathians)

Scientific limnological research in the Tatra Mountains were initiated by Stanislaw Staszic in the early XIX century.  After the World War II, the evolution of Tatra lakes was investigated by Kondracki, Klimaszewski, Baumgart-Kotarba and. Extensive paleolimnological investigations in the Tatra Mountains were started by the group of scientists led by K. Starmach in the beginning of the second half of the 20th century. There has been not much research concerned to the regional distribution of lakes and their properties in the Tatra Mountains (Pociask-Karteczka 2013). Very early division of lakes presented A. Gadomski (1922), which distinguished four types of lakes: a) tarns (cirque lake or corrie loch), b) bedrock-dammed lakes, c) moraine lakes. This division was concerned in subsequent publications (Choiński 2007). M. Lukniš (1973, 1985) recognized additional types: kettles and landslide-dammed lakes and M. Klimaszewski (1988) – inter-sheepback lakes. J. Pacl and K. Wit-Jóźwik in Klima Tatier (Pacl, Wit-Jóźwik 1974) were focused on the temperature of water in lakes in Polish and Slovak parts and M. Borowiak (2000a,b) provided a comprehensive analysis of types, dimensions, temperature and chemical composition of water in lakes in the Tatra Mountains.According to present day state of knowledge, one may distinguish following genetic types of lakes: I) glacial, II) not-glacial. There are four types of the glacial origin lakes in the Tatra Mountains (Fig. 1): a) tarns (cirque lakes or corrie loch), b) bedrock-moraine dammed lakes, c) inter-sheepback lakes, d) moraine lakes, e) kettles.Most of lakes in the Tatra Mountains are tarns and bedrock-moraine dammed lakes, and they are located at the elevation over 1400 m a.s.l. in the Western Tatra Mountains, and over 1600 m a.s.l. in the High Tatra Mountains. Some of them are paternoster lakes – a series of stair-stepped lakes formed in individual rock basins aligned down the course of a glaciated valley. Lakes in the Five Polish Lakes Valley is an example of such type. The inter-sheepback lakes occur at higher elevations (e.g. Wyżnie Mnichowe Stawki, Zamrznuté oká). There is a little number of moraine lakes in the Tatra Mountains (e.g. Smreczyński, Toporowy Niżni) and kettles (e.g. Štrbské Pleso, Kotlinowy Stawek). Some lakes are located among rock debris or rock debris and moraine material (Dwoisty Staw Gąsienicowy, Anitino očko) – they are of polygenetic origin. </p

The Coupled Magnetic Field Effects on the Microstructure Evolution and Magnetic Properties of As-Deposited and Post- Annealed Nano-Scaled Co-Based Films — Part II

Superimposed external magnetic fields during electrodeposition process offers the possibility to tailor the microstructure and properties of the obtained films in a very efficient, contactless, and easily controllable way, which is caused by so-called magnetohydrodynamic (MHD) effect. On the other hand, the non-equilibrium state of as-electrodeposited nanocrystalline films provides a strong thermodynamic potential for microstructural transformation. This means that the beneficial effect of magneto-electrodeposition on a nanocrystalline film can be completely consumed by thermal exposure at a relatively low temperature. Magnetic field annealing has been confirmed to be useful for tailoring the microstructure of as-deposited nanocrystalline films for their widespread uses

The typology of natural ephemeral landscapes in the context of the preceding research

Autorzy podjęli problematykę krajobrazów efemerycznych pochodzenia naturalnego, które współtworzone są przez zjawiska przyrodnicze o dużej nieregularności i krótkotrwałości występowania. Celem opracowania było usystematyzowanie dotychczasowego stanu wiedzy w tym zakresie w oparciu o autorską typologię krajobrazów efemerycznych. z przeglądu literatury wynika, że stopień rozpoznania krajobrazów efemerycznych wciąż pozostaje niewystarczający. Skoncentrowanie badaczy na wybranych zjawiskach krótkotrwałych uniemożliwia kompleksowe spojrzenie na badany krajobraz. Tymczasem krajobrazy efemeryczne percypowane są całościowo i mogą stanowić ważną atrakcję turystyczną.Although the relations between landscape and certain human activities are well recognised in landscape ecology literature, main emphasis is put on stable landscape features. This article, by contrast, focuses on ephemeral landscapes which are defined as the ones consisted of phenomena and features of a changeable character (Brassley 1998). It can be assumed that the phenomena, even of same type, construct a different ephemeral landscape each time. However, despite their evanescence and irregular occurrence (Palang et al.2007), they still need to be investigated due to their significant role in perception of the whole landscape and its evaluation for different functions (Brassley 1998). The article also refers to substantial theoretical connotations of landscape ephemera and multi-sensory model of perception. The link can be easily recognised in tourism management because a complexity of several landscape ephemera’s features strongly influences visitor preferences of certain regions (Huang 2013). Due to stated selective and superficial recognition of the problem, authors’ main aim was to propose a novel typology of natural-caused landscape ephemera based on a detailed literature review. in the typology, the visually dominant genetic factor criterion was used. Therefore, there were distinguished landscape ephemera mainly connected with: (1) astronomical factors, (2) weather conditions, (3) endogenic, (4) geomorphologic, (5) hydrological processes, (6) biological and (7) joint ephemeral factors (tab. 1). The typology also reflects different economic and social roles of landscapes assigned to particular groups – e.g. astronomical phenomena, due to their relatively higher predictability, can constitute a core of specific tourist products, while endogenic ones are often perceived as a danger and disruption of a trip ( Yang et al. 2008). The authors confirmed considerable inequality in a recognition degree of landscape ephemera of different types. Symptomatically, there are only a few works which present an issue in a complex way. The stress is often put on the short-lasting phenomena itself while there are some durable processes (e.g. aeolian) which can also subconstruct certain landscape ephemera (e.g. ripplemarks). Undoubtedly, there are still many cognitive gaps connected with presented subject which are strongly needed to be filled because of its potential applied role. An influence of landscape ephemera on creating local identity and resident’s embeddedness is of an example

The ephemeral landscape of sunrise as a tourists’ motivating factor for night-time ascents of Babia Góra

The aim of the study was to verify changeability of the sunrise ephemeral landscape observed from the peak of Babia Góra and to confirm that it acted as a tourist attraction. Every sunrise during summer holidays weekends was observed from Babia Góra peak and described. The data about the weather conditions and number of tourists were collected. Survey interviews with randomly selected tourists who had seen sunrise (269) were conducted in order to obtain information about their motivations for night-time ascents of Babia Góra. The changeability of the ephemeral landscape of sunrise was proved. Most of the tourists who have visited Babia Góra at dawn (84%) agreed that the will to observe the sunrise was one of motivating factors for them, however they pointed out many others, as well

Sunrise as a tourist attraction in the context of tourist motivation theory : a case study of the peak of Babia Góra (Western Carpathians)

Tourist ascents of mountain peaks before sunrise are increasingly popular. Babia Góra (Western Carpathians) is a peak on the Polish-Slovak border frequently visited by a great number of tourists at sunrise. The main objective of our research, based on the case study of Babia Gora, was to answer a more general question whether the sunrise can be considered a tourist attraction. The research included the observation and description of every sunrise at summer holiday weekends during 2012 from the peak of Babia Góra as well as the collection of data on the number of tourists and weather conditions. Survey interviews, using questionnaire, with randomly selected hikers present on the peak of Babia Góra at sunrise (269) were conducted. The investigation showed that during summer holiday sunrises there were a maximum of 130 people on the summit of Babia Góra at the same time. Most of the surveyed people (84%) agreed that the opportunity to observe the sunrise was one of the pull factors for them. This confirms the hypothesis that sunrise constitutes a tourist attraction

Effects of High Magnetic Field Postannealing on Microstructure and Properties of Pulse Electrodeposited Co-Ni-P Films

The influence of high magnetic field annealing on the morphology, microstructure, and properties of pulsed-electrodeposited Co-Ni-P films was investigated. The as-deposited film with a rough surface changed into uniform nanocrystalline during the magnetic field annealing process. In particular, the formation of intestine-like appearance with spherical clusters vanishing is favored from a moderate magnetic field strength of 6 T, due to the polarized effects. Meantime, the diffraction peak (111) of α (fcc) phase shifts to the right direction, which is attributed to the fact that more Co atoms from phosphide phase are incorporated into the Ni lattice, in comparison with the case of annealing under 0 T and 12 T magnetic fields. The mechanical and magnetic properties of the films reach relative optimum values at B=6 T. The evolution of magneto-induced modification in the Co-Ni-P morphology, structure, and properties can be explained by the polarized effect and the diffusion-acceleration effect under a high magnetic field

Difference in expression between AQP1 and AQP5 in porcine endometrium and myometrium in response to steroid hormones, oxytocin, arachidonic acid, forskolin and cAMP during the mid-luteal phase of the estrous cycle and luteolysis

BACKGROUND: Recently, we demonstrated in vitro that AQP1 and AQP5 in the porcine uterus are regulated by steroid hormones (P4, E2), arachidonic acid (AA), forskolin (FSK) and cAMP during the estrous cycle. However, the potential of the porcine separated uterine tissues, the endometrium and myometrium, to express these AQPs remains unknown. Thus, in this study, the responses of AQP1 and AQP5 to P4, E2 oxytocin (OT), AA, FSK and cAMP in the porcine endometrium and myometrium were examined during the mid-luteal phase of the estrous cycle and luteolysis.METHODS: Real-time PCR and western blot analysis.RESULTS: Progesterone up-regulated the expression of AQP1/AQP5 mRNAs and proteins in the endometrium and myometrium, especially during luteolysis. Similarly, E2 also stimulated the expression of both AQPs, but only in the endometrium. AA led to the upregulation of AQP1/AQP5 in the endometrium during luteolysis. In turn, OT increased the expression of AQP1/AQP5 mRNAs and proteins in the myometrium during mid-luteal phase. Moreover, a stimulatory effect of forskolin and cAMP on the expression of AQP1/AQP5 mRNAs and proteins in the endometrium and myometrium dominated during luteolysis, but during the mid-luteal phase their influence on the expression of these AQPs was differentiated depending on the type of tissue and the incubation duration.CONCLUSIONS: These results seem to indicate that uterine tissues; endometrium and myometrium, exhibit their own AQP expression profiles in response to examined factors. Moreover, the responses of AQP1/AQP5 at mRNA and protein levels to the studied factors in the endometrium and myometrium are more pronounced during luteolysis. This suggests that the above effects of the studied factors are connected with morphological and physiological changes taking place in the pig uterus during the estrous cycle.</p