Акты налогового права Европей- ского Союза и соглашения об избежании двойного налогообложения: проблемы соотношения при установлении правил борьбы с налоговыми злоупотреблениями

The subject. The specifics of the functioning of tax systems and the risk of double taxation require a solution to the issue of whether tax competence can remain only at the national level. Modern cross-border tax relations operate within a multi-level system of legal regulation based on the norms of international, supranational and national lawThe difficulties of correlating these levels are rooted in the fact that, in accordance with international law, each State has the right to tax persons or transactions with which it has a sufficient connection. Different situations may occur when both countries believe that the taxpayer is their resident, or when each of them claims that the income was received in this state. States solve this problem both unilaterally with the help of national legislation, and on a bilateral basis with the help of a double tax treaty.With the adoption of the Action Plan aimed at combating the erosion of the tax base and the withdrawal of profits (hereinafter referred to as the BEPS plan) and the EU Council Directive 2016/1164 (ATAD), tax strategies for using gaps and inconsistencies in tax rules to artificially transfer profits to low-tax jurisdictions were limited.Purpose of the study. The article discusses possible scenarios arising from the interaction of tax agreements and acts of EU tax law. It is necessary to take into account the obligation of the Member States to eliminate inconsistencies between acts of national legislation and acts of EU law. Member States have committed to achieve this goal at the time of EU accession and, therefore, before the adoption of any secondary EU law.Methodology. The research was carried out with the application of the formally legal interpretation of legal acts as well as the comparative analysis of international and European legal literature. Structural and systemic methods are also the basis of the research.The main results. Due to the clear coordination between the European Union and the OECD of actions in terms of establishing common measures to combat tax evasion and focusing on the subjective element of assessing potential abuse situations, a new standard for combating tax evasion has been established.Сonclusions. The author comes to the conclusion that the priority of the EU law over DTTs has been established. However, Member States retain the right to establish their own tax regimes and enter into tax treaties, thereby creating conflicts in legal regulation. In order to be directly applicable, the norm of the treaty must be clearly and definitely formulated, as well as be unconditional and independent of any national implementation measures.National legislation provides measures to eliminate the legal multiple taxation only for its residents. On the other hand, with respect to tax agreements concluded with third countries, the predominance of one system over another depends on the specific scenario, and in some cases the result achieved is the result of interpretation of existing provisions. In particular, tax treaties should prevail only when concluded before a state joins the EU.Рассматриваются проблемы соотношения принципов действия норм налогового права Европейского Союза и соглашений об избежании двойного налогообложения. Также рассматриваются возможные сценарии, возникающие в результате взаимодействия налоговых соглашений и актов налогового права ЕС. Рассмотрены случаи, когда налоговые соглашения заключены между государствами – членами ЕС, а также между государствами – членами ЕС и третьими странами. Коллизии нередко разрешаются посредством решений Суда справедливости Европейского Союза (Суда ЕС), что показано на примерах из классической практики Суда ЕС, а также на примере «датских дел». Рассматривая проблему соотношения актов налогового права ЕС и международных соглашений, автор отмечает, что установлен приоритет интеграционного наднационального права над соглашениями об избежании двойного налогообложения. Тем не менее государства-члены сохраняют за собой право создавать свои собственные налоговые режимы и вступать в налоговые соглашения, тем самым создавая коллизии в правовом регулировании

Classification of double flag varieties of complexity 0 and 1

A classification of double flag varieties of complexity 0 and 1 is obtained. An application of this problem to decomposing tensor products of irreducible representations of semisimple Lie groups is considered

Spatial transformation as an institutional factor of the public management of macroeconomic systems

Purpose: The article analyzes the issue of substantiating the impact of the spatial organization of the territory of the Russian Federation on the public management at the level of macroeconomic systems. Design/Methodology/Approach: The federal districts were chosen as the object of the study as macro-regional socio-economic systems, the Southern Federal District and its constituent regions (subjects of the Russian Federation). The article investigates the main transformational processes taking place in the RF spatial development, concerning the development of the regional systems of the public management and the necessity of their consistency at the supra-regional (macro-regional) level. Findings: The authors propose a set of measures to form supra-regional system to coordinate the regional development priorities considering the peculiarities of the spatial transformation of Russia's territory and the position of the Southern macro-region in the spatial system of the country. This system formation allows involving as many interested parties as possible. Practical Implications: The results may be implemented into macro-region public administration to maximize the advantages of the geo-economic and strategic position, natural and climatic conditions of Russian regions' development. Originality/Value: The main contribution of this study is a tailored approach to the public administration of the social and economic development of the macro-regions in the context of the spatial transformation.peer-reviewe

Psychological diagnostics of the first-year students' adaptation to a higher school environment

© 2017 Serials Publications.The relevance of the investigated problem is caused by the need for theoretical basis for special activities aimed at prevention the first-year students' psychological maladjustment on the one hand, and insufficient development of theory, methodology and content of such activities on the other. It is important to diagnose emerging problems of first-year students' adaptation correctly in order to provide them with psychological help, to overcome psychological maladjustment factors during the initial period of their higher school training. The aim of the article is to justify the choice of psycho-diagnostic tools, to present the means of tools testing, to summarize the results of psycho-diagnostics of first-year students' social and psychological adaptation to a higher educational environment. The leading method of our research is psycho-diagnostics, it allows us to identify the most common causes, factors, and barriers in first-year students' effective adaptation to a higher school environment; the results of psycho-diagnostics can be used to provide students with timely psychological assistance, and to overcome psychological maladjustment factors. The results indicate that special activities aimed at the prevention of students' psychological maladjustment are of critical importance. The parameters of first-year students' adaptation levels, received on the basis of special criteria and with the help of psycho-diagnostic toolset, are presented in the article. The algorithm of psycho-diagnostic tools implementation is also given. The implementation of the proposed psycho-diagnostic toolset is aimed at prevention the first-year students' psychological maladjustment; it is focused on providing students with individual counseling and overcoming psychological maladjustment during their initial period of training

Risk-based Regulation of Russian Universities: Risk Indicators and Their Use for State Control Purposes

The article is devoted to the identification and analysis of indicators of the risk of low-quality education in Russian universities. In 2021-2022, the approach to higher education inspections has changed significantly: accreditation monitoring has been introduced, it includes eight indicators. However, this monitoring was formed by the expert community, so the results of its testing in practice have yet to be analyzed. The purpose of this work is to identify risk factors for estimation the likelihood of violations of mandatory requirements by universities, and to develop recommendations for expanding the set of risk indicators included in accreditation monitoring. The main methods used in the work are methods of quantitative analysis, including econometric modeling. The novelty of the work is determined by the approach used: risk indicators are identified using a quantitative econometric analysis of data on the observed characteristics and results of inspections of Russian universities in 2015-2019. The results of the study indicate the possibility of supplementing the set of accreditation monitoring indicators. As additional indicators, first of all, various characteristics of research activities of universities can be used. Such a change in accreditation monitoring will increase its effectiveness as a preliminary assessment tool used in the implementation of a risk-based approach to state control. In cases where the assessment of even extended monitoring is ambiguous, the quantitative model proposed by the authors can be used

Concentration dependence of terahertz generation in jets of water and ethanol mixtures

In this work, we considered mixtures of ethanol and water in the form of jets as samples for THz generation based on laser-induced filamentation. The dependence of the output energy of terahertz radiation on the concentration of ethanol in water was experimentally studied. It is shown that the energy grows linearly, which can be explained by an increase in the ionization energy due to the linear replacement of low-efficient charge carriers (water) with highly-efficient (ethanol). The dependence of the THz generation on the optical angle of incidence on the mixture jets was also demonstrated. The results of this study can be further used to create universal source of terahertz radiation

AI MENTORING AS A FORM AKMEOLOGICHESKOJ ORIENTED PROFESSIONAL INTERACTION

Optimization of professional relationships in the "mentor- apprentice" promotes the formation of a professional orientation akmeologicheskoj both subjects interaction. On the one hand , mentoring is one of the oldest and most effective ways to acquire knowledge and skills of young employees of the company in the process of adapting to a new team . On the other - allows teacher to identify their professional and personal opportunities and consciously decide to choose the optimum time of interaction with the students, based on their individual characteristics, as well as improve their own skills.Оптимизация профессиональных взаимоотношений в системе «наставник – ученик» способствует формированию акмеологической профессиональной направленности у обоих субъектов взаимодействия. Наставничество является одним из самых старых и эффективных способов приобретения знаний и навыков молодыми сотрудниками предприятия в процессе их адаптации в новом коллективе; позволяет наставнику выявить свои профессионально-личностные возможности и осознанно определиться в выборе оптимального стажа взаимодействия с учениками, с учетом их индивидуальных особенностей, а также повысить уровень собственного мастерства

Abnormal Ultrastructure of the Platelet Plasma Membrane in Systemic Lupus Erythematosus

© 2016, Springer Science+Business Media New York.Systemic lupus erythematosus (SLE) is an autoimmune disease in which the body’s immune system mistakenly attacks healthy tissue. It can affect the skin, joints, kidneys, brain, and other organs. Blood cells, including platelets, are also involved in SLE and contribute to the pathogenesis of disease. We studied ultrastructure of platelets isolated from the blood of SLE patients and found that the plasma membrane was rough and shaggy compared to the normally smooth cell surface. These changes in the membrane morphology increased with the disease severity and were more pronounced when SLE was associated with the antiphospholipid syndrome, suggesting that platelets are strongly affected by the immune reactions underlying SLE

Underestimated risks of recurrent long-range ash dispersal from northern Pacific Arc volcanoes

Widespread ash dispersal poses a significant natural hazard to society, particularly in relation to disruption to aviation. Assessing the extent of the threat of far-travelled ash clouds on flight paths is substantially hindered by an incomplete volcanic history and an underestimation of the potential reach of distant eruptive centres. The risk of extensive ash clouds to aviation is thus poorly quantified. New evidence is presented of explosive Late Pleistocene eruptions in the Pacific Arc, currently undocumented in the proximal geological record, which dispersed ash up to 8000?km from source. Twelve microscopic ash deposits or cryptotephra, invisible to the naked eye, discovered within Greenland ice-cores, and ranging in age between 11.1 and 83.7 ka b2k, are compositionally matched to northern Pacific Arc sources including Japan, Kamchatka, Cascades and Alaska. Only two cryptotephra deposits are correlated to known high-magnitude eruptions (Towada-H, Japan, ca 15 ka BP and Mount St Helens Set M, ca 28 ka BP). For the remaining 10 deposits, there is no evidence of age- and compositionally-equivalent eruptive events in regional volcanic stratigraphies. This highlights the inherent problem of under-reporting eruptions and the dangers of underestimating the long-term risk of widespread ash dispersal for trans-Pacific and trans-Atlantic flight route