190 research outputs found

    What do IP-intensive businesses have in common with the extractive industry?:The place of excess (incl. windfall) profits in the DEMPE analysis for intangible assets

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    In this article, we touch upon one of the most topical and debatable loopholes in transfer pricing: how market distortions, dominant market power and economic conditions that do not fit the normal economic cycle should affect a transfer pricing analysis of controlled transactions? During the most recent economic crises triggered by the COVID-19 pandemic and the energy security crisis as a consequences of the Russian invasion of Ukraine, it became clear that business profits may not always be a direct result of investors’ decisions, or in transfer pricing terms – of functions performed, assets used, or risks assumed, but, instead, a consequence of external circumstances. Such external circumstances may include rapid distortions in the supply and demand equilibrium for certain goods or services such as, for example, digital software or energy resources. Yet, some external factors are not connected to a stage of the economic cycle, among which are the market power or distorted competition, i.e. oligopoly, monopoly or monopsony position in the market. In this article, we observe that the ability of some sectors of the economy to capture abnormal returns is not a matter of luck or unpredictable events only. Instead, the ownership of certain scarce resources or artificially scarce assets determines the ability to generate excess (residual) returns. We build a parallel between the natural resources that produce economic rents and intellectual property assets, the scarcity of which is enabled by the strong system of legal protection of IP rights (in particular, patents) to demonstrate their common characteristic as rent-generating assets. We once again challenge the validity of the concept of value creation arguing that it does not account for the level of competition, market power and control and scarcity in the market, which are the main preconditions for a company to generate high profits. Finally, we challenge the mainstream concept of DEMPE for the allocation of profits from intangibles for the fact that it attributes too much value to the stage of development of intangibles. Based on the understanding that IP protection may induce artificial scarcity of Ip protected products in the market, which distorts competition and enables the IP owner to receive higher returns, the market jurisdiction should be entitled to a share of the residual profit for the facilitation of the IP protection regime. <br/

    Observation of associated production of a ZZ boson with a DD meson in the~forward region

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    A search for associated production of a ZZ boson with an open charm meson is presented using a data sample, corresponding to an integrated luminosity of 1.0 fb−‘1.0\,\mathrm{fb}^{-`} of proton--proton collisions at a centre-of-mass energy of 7\,TeV, collected by the LHCb experiment. %% Seven candidate events for associated production of a ZZ boson with a D0D^0 meson and four candidate events for a ZZ boson with a D+D^+ meson are observed with a combined significance of 5.1standard deviations. The production cross-sections in the forward region are measured to be σZ→Ό+ÎŒâˆ’â€‰âŁ,D0=2.50±1.12±0.22pb\sigma_{Z\rightarrow\mu^+\mu^-\!,D^0} = 2.50\pm1.12\pm0.22pb σZ→Ό+ÎŒâˆ’â€‰âŁ,D+=0.44±0.23±0.03pb,\sigma_{Z\rightarrow\mu^+\mu^-\!,D^+} = 0.44\pm0.23\pm0.03pb, where the first uncertainty is statistical and the second systematic.Comment: 18 pages, 2 figure

    Measurements of the B+B^+, B0B^0, Bs0B_s^0 meson and Λb0\Lambda_b^0 baryon lifetimes

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    Measurements of bb-hadron lifetimes are reported using pppp collision data, corresponding to an integrated luminosity of 1.0fb−1^{-1}, collected by the LHCb detector at a centre-of-mass energy of 77Tev. Using the exclusive decays B+→J/ψK+B^+\to J/\psi K^+, B0→J/ψK∗(892)0B^0\to J/\psi K^*(892)^0, B0→J/ψKS0B^0\to J/\psi K^0_{\rm S}, Λb0→J/ψΛ\Lambda_b^0\to J/\psi \Lambda and Bs0→J/ψϕB^0_s\to J/\psi \phi the average decay times in these modes are measured to be τB+→J/ψK+\tau_{B^+\to J/\psi K^+} = 1.637±1.637 \pm 0.004 ±\pm 0.003 ps, τB0→J/ψK∗(892)0\tau_{B^0\to J/\psi K^*(892)^0} = 1.524±1.524 \pm 0.006 ±\pm 0.004 ps, τB0→J/ψKS0\tau_{B^0\to J/\psi K^0_{\rm S}} = 1.499±1.499 \pm 0.013 ±\pm 0.005 ps, τΛb0→J/ψΛ\tau_{\Lambda_b^0\to J/\psi \Lambda} = 1.415±1.415 \pm 0.027 ±\pm 0.006 ps and τBs0→J/ψϕ\tau_{B^0_s\to J/\psi \phi} = 1.480±1.480 \pm 0.011 ±\pm 0.005 ps, where the first uncertainty is statistical and the second is systematic. These represent the most precise lifetime measurements in these decay modes. In addition, ratios of these lifetimes, and the ratio of the decay-width difference, ΔΓd\Delta\Gamma_d, to the average width, Γd\Gamma_d, in the B0B^0 system, ΔΓd/Γd=−0.044±0.025±0.011\Delta \Gamma_d/\Gamma_d = -0.044 \pm 0.025 \pm 0.011, are reported. All quantities are found to be consistent with Standard Model expectations.Comment: 28 pages, 4 figures. Updated reference

    Surface Ig variable domain glycosylation affects autoantigen binding and acts as threshold for human autoreactive B cell activation

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    The hallmark autoantibodies in rheumatoid arthritis are characterized by variable domain glycans (VDGs). Their abundant occurrence results from the selective introduction of N-linked glycosylation sites during somatic hypermutation, and their presence is predictive for disease development. However, the functional consequences of VDGs on autoreactive B cells remain elusive. Combining crystallography, glycobiology, and functional B cell assays allowed us to dissect key characteristics of VDGs on human B cell biology. Crystal structures showed that VDGs are positioned in the vicinity of the antigen-binding pocket, and dynamic modeling combined with binding assays elucidated their impact on binding. We found that VDG-expressing B cell receptors stay longer on the B cell surface and that VDGs enhance B cell activation. These results provide a rationale on how the acquisition of VDGs might contribute to the breach of tolerance of autoreactive B cells in a major human autoimmune disease.Medicinal Chemistr

    Measurement of charged particle multiplicities and densities in pp collisions root s=7 TeV in the forward region

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    Charged particle multiplicities are studied in proton-proton collisions in the forward region at a centre-of-mass energy of TeV with data collected by the LHCb detector. The forward spectrometer allows access to a kinematic range of in pseudorapidity, momenta greater than and transverse momenta greater than . The measurements are performed using events with at least one charged particle in the kinematic acceptance. The results are presented as functions of pseudorapidity and transverse momentum and are compared to predictions from several Monte Carlo event generators

    A study of CP violation in B-+/- -> DK +/- and B-+/- -> D pi(+/-) decays with D -> (KSK +/-)-K-0 pi(-/+) final states

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    A first study of CP violation in the decay modes B-+/- -> [(KSK +/-)-K-0 pi(-/+)](D)h(+/-) and B-+/- -> [(KSK +/-)-K-0 pi(-/+)](D)h(+/-), where h labels a K or pi meson and D labels a D-0 or (D) over bar (0) meson, is performed. The analysis uses the LHCb data set collected in pp collisions, corresponding to an integrated luminosity of 3 fb(-1). The analysis is sensitive to the CP-violating CKM phase gamma through seven observables: one charge asymmetry in each of the four modes and three ratios of the charge-integrated yields. The results are consistent with measurements of gamma using other decay modes

    Evidence for the decay Bc+→J/ψ3π+2π−B_c^+ \rightarrow J/\psi 3\pi^+ 2\pi^-

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    Evidence is presented for the decay Bc+→J/ψ3π+2π−B_c+\rightarrow J/\psi 3\pi^+2\pi^- using proton-proton collision data, corresponding to an integrated luminosity of 3fb−1^{-1}, collected with the LHCb detector. A signal yield of 32±832\pm8 decays is found with a significance of 4.5 standard deviations. The ratio of the branching fraction of the Bc+→J/ψ3π+2π−B_c^+\rightarrow J/\psi 3\pi^+ 2\pi^- decay to that of the Bc+→J/ψπ+B_c^+ \rightarrow J/\psi \pi^+ decay is measured to be Br(Bc+→J/ψ3π+2π)Br(Bc+→J/ψπ+)=1.74±0.44±0.24, \frac{Br (B_c^+ \rightarrow J/\psi 3\pi^+2\pi^)}{Br (B_c^+ \rightarrow J/\psi \pi^+)} = 1.74\pm0.44\pm0.24, where the first uncertainty is statistical and the second is systematic.Comment: 12 pages, 3 figure

    A study of CP violation in B± → D K ± and B± → Dπ± decays with D → K0S K ±π∓ final states

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    A first study of CP   violation in the decay modes and , where h labels a K or π meson and D   labels a D0 or meson, is performed. The analysis uses the LHCb data set collected in pp collisions, corresponding to an integrated luminosity of 3 fb−1. The analysis is sensitive to the CP-violating CKM phase Îł through seven observables: one charge asymmetry in each of the four modes and three ratios of the charge-integrated yields. The results are consistent with measurements of Îł using other decay modes
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