Stałe zakłady w świetle Filarów – znaczenie analizy cen transferowych

This paper analyses the treatment of Permanent Establishments (PEs) under the OECD’s Pillar One and Pillar Two frameworks. It delves into the complexities of the Global Anti Base Erosion Model Rules (GloBE) and the Qualified Domestic Minimum Top-Up Tax (QDMTT) rules under Pillar Two, as well as the reallocation of taxing rights under Pillar One. The role of transfer pricing in dealing with PEs is scrutinised, particularly its influence on the calculation of Adjusted GloBE income and Elimination Profit. The practical implications of these rules on PEs are illustrated through case studies. The paper also highlights the potential for disputes and the need for upfront certainty on transfer pricing positions.W artykule przeanalizowano sposób podejścia do stałych zakładów w ramach Filaru I oraz II OECD. Porusza się w nim złożoną tematykę globalnych zasad przeciwdziałania erozji podstawy opodatkowania (GloBE) oraz kwalifikowanego krajowego minimalnego podatku wyrównawczego (QDMTT) w ramach Filaru II, a także ponownego przydziału praw podatkowych w ramach Filaru I. Analizowana jest rola cen transferowych w kontekście podejścia do stałych zakładów, a w szczególności ich wpływ na obliczanie skorygowanego dochodu do celów GloBE oraz zysku eliminacyjnego. Praktyczne implikacje tych zasad dla stałych zakładów zilustrowano za pomocą studiów przypadku. W artykule podkreślono także, że potencjalnie może dochodzić do sporów, jak również potrzebę uzyskiwania zawczasu pewności w zakresie pozycji przedsiębiorstwa w kontekście cen transferowych

The effect of general anaesthesia versus conscious sedation in dosimetric distribution of intracavitary radiotherapy in cervical cancer patients

Background: Majority of Indian patients presents in locally advanced stage and most of them treated by combination of external teletherapy and intracavitary brachytherapy (ICRT). Because of deficient infrastructure, the waiting period is generally long at existing caner canters. Hence ICRT may be done in conscious sedation to treat more patients by avoiding time consuming general anaesthesia. The aim of this study is to know the effect of general anaesthesia vs. conscious sedation in dosimetric distribution in brachytherapy and its feasibility.Methods: Total 80 ICRT applications were randomized to general anaesthesia (GA) and conscious sedation (CS) groups. Fletcher suit type of applicators was used and dose delivery equipment was cobalt 60 high dose rate remote after loading brachytherapy unit. In CS group, injection midazolam 0.5-8mg (median 2.5mg) in the form of slow i.v. infusion was used along with antiemetic support.Results: Total 6 parameters were analyzed. e.g., Dose to point A1, Dose to point A2, Bladder max dose, Bladder mean dose, Rectal max dose and Rectal mean dose. The dose distribution was found similar both   groups and it did not depend on type of anaesthesia.Conclusions: The high volume centers of developing countries are most suitable candidate to opt conscious sedation to perform ICRT to treat more cancer cervix patients in same time frame

Cancer oesophagus: is sequential chemo radiation better in elderly patients or patients with severe dysphagia?

Background:This study was conducted to analyse the local control, regional control and toxicities of sequential versus concurrent chemo radiation in the patients of oesophageal cancer especially in elderly.Methods: A total of newly diagnosed 50 patients were randomized in concurrent and sequential arm. Two courses of 3 weekly chemotherapy (Cisplatin and 5-FU based) were given concurrently and three courses of same chemotherapy were given neoadjuvantly with EBRT (44 Gys) respectively in randomised arms. HDR-ICBT (2 fractions of 5 Gy) delivered after two weeks of completion of EBRT in both arm.Results: Concurrent arm had higher incidence of grade III+IV overall all toxicity especially in elderly patients or patients that presented with grade IV or higher dysphagia. Other haematological and non-haematological toxicities were equal in both arms. Complete response at both primary and mediastina was higher in concurrent arm but there was no statistically significant difference.Conclusions: Our data suggest that if a patient can tolerate the combination of chemotherapy and radiation, this approach offers superior results but at the cost of higher incidence of severe toxicities especially in patients with grade IV or higher dysphagia or elderly patients. So this group could be treated with sequential chemo radiation

Structure–conductivity correlation in ferric chloride-doped poly(3-hexylthiophene)

Poly(3-hexylthiophene) (P3HT) matrix has been chemically doped (redox doping) by ferric chloride (FeCl3) with different molar concentrations to get P3HT–FeCl3 charge-transfer complexes. The effect of redox doping on photo-physical, structural, and morphological properties and dc electrical conductivity of P3HT matrices has been examined. The dc conductivity has been measured on films of pristine P3HT and P3HT–FeCl3 charge-transfer complexes in the temperature range 6–300 K. Analysis of dc conductivity data reveals that in the temperature range 40–300 K, the dc conductivity is predominantly governed by Mott's 3-dimensional variable range hopping (3D-VRH); however, below 40 K tunnelling seems to dominate. A slight deviation from 3D-VRH to 1D-VRH is observed with an increase in doping level or precisely with an increase in the extent of P3HT–FeCl3 charge-transfer complexes. We attribute this deviation to the induced expansion in crystallographic lattices as revealed by x-ray diffraction data and formation of discrete conducting domains as observed by atomic force microscope imaging

Phase diagram and upper critical field of homogenously disordered epitaxial 3-dimensional NbN films

We report the evolution of superconducting properties with disorder, in 3-dimensional homogeneously disordered epitaxial NbN thin films. The effective disorder in NbN is controlled from moderately clean limit down to Anderson metal-insulator transition by changing the deposition conditions. We propose a phase diagram for NbN in temperature-disorder plane. With increasing disorder we observe that as kFl-->1 the superconducting transition temperature (Tc) and minimum conductivity (sigma_0) go to zero. The phase diagram shows that in homogeneously disordered 3-D NbN films, the metal-insulator transition and the superconductor-insulator transition occur at a single quantum critical point at kFl~1.Comment: To appear in Journal of Superconductivity and Novel Magnetism (ICSM2010 proceedings

Superconducting properties and Hall Effect of epitaxial NbN thin films

We have measured the magnetotransport properties and Hall effect of a series of epitaxial NbN films grown on (100) oriented single crystalline MgO substrate under different conditions using reactive magnetron sputtering. Hall effect measurements reveal that the carrier density in NbN thin films is sensitive to the growth condition. The carrier density increases by a factor of 3 between the film with highest normal state resistivity (rho_n~3.83micro-Ohm-m) and lowest transition temperature (Tc~9.99K) and the film with lowest normal state resistivity (rho_n~0.94micro-Ohm-m) and highest transition temperature (Tc~16.11K) while the mobility of carriers does not change significantly except for the most resistive films. Our results show that the Tc of NbN is governed primarily by the carrier density rather than disorder scattering. By varying the carrier concentration during growth we can vary the effective disorder (kF_l) from the moderately clean limit to the dirty limit which makes this system ideal to study the interplay of carrier density and disorder on the superconducting properties of an s-wave superconductor.Comment: ps files with figures (accepted for publication in Phys. Rev. B

Penetration depth and tunneling studies in very thin epitaxial NbN films

We investigate evolution of the magnetic penetration depth and superconducting energy gap in epitaxial NbN films using a low frequency mutual inductance technique and tunneling spectroscopy using a low temperature scanning tunneling microscope (STM). The superconducting transition temperature (Tc) for films grown under optimal growth conditions decreases monotonically from 15.87K to 9.16K as the film thickness is decreased from 50nm to 3nm. With decrease in film thickness delta(0) monotonically decreases, whereas lambda(0) monotonically increases. We observe that Tc, lambda(o) and delta(0) are well described by Bardeen-Cooper-Schrieffer (BCS) theory in all films other than the two thinnest ones where we see evidence of the Kosterlitz-Thouless-Berezinski (KTB) transition close to Tc.Comment: Modified version with extensive analysis of the KTB transition. One new author adde

Phase diagram of a strongly disordered s-wave superconductor, NbN, close to the metal-insulator transition

We present a phase diagram as a function of disorder in three-dimensional NbN thin films, as the system enters the critical disorder for the destruction of the superconducting state. The superconducting state is investigated using a combination of magnetotransport and tunneling spectroscopy measurements. Our studies reveal 3 different disorder regimes. At low disorder the (k_{F}l~10-4), the system follows the mean field Bardeen-Cooper-Schrieffer behavior where the superconducting energy gap vanishes at the temperature where electrical resistance appears. For stronger disorder (k_{F}l<4) a "pseudogap" state emerges where a gap in the electronic spectrum persists up to temperatures much higher than Tc, suggesting that Cooper pairs continue to exist in the system even after the zero resistance state is destroyed. Finally, very strongly disordered samples (k_{F}l<1) exhibit a pronounced magnetoresistance peak at low temperatures, suggesting that localized Cooper pairs continue to survive in the system even after the global superconducting ground state is completely destroyed.Comment: pdf file with figures (Modified Version

Evolution of checkpoint inhibitors for the treatment of metastatic gastric cancers: Current status and future perspectives

Abstract Background Standard treatment options for patients with advanced gastric or gastroesophageal junction cancer (GC/GEJC) are associated with limited efficacy and some toxicity. Recently, immunotherapy with antibodies that inhibit the programmed death 1 (PD-1)/programmed death ligand 1 (PD-L1) interaction has emerged as a new treatment option. This manuscript reviews early-phase and late-phase trials of immunotherapy in advanced GC/GEJC. Methods Searches for studies of immunotherapy in GC/GEJC were performed using PubMed, ClinicalTrials.gov, and abstract databases for select annual congresses. Findings were interpreted based on expert opinion. Results Monotherapy with anti–PD-1/PD-L1 antibodies, including pembrolizumab, nivolumab, avelumab, durvalumab, and atezolizumab, has shown interesting objective response rates (ORRs; 7–26%) across varying GC/GEJC populations, with ORRs potentially higher in PD-L1 + vs PD-L1 − tumors. Safety profiles compare favorably with chemotherapy, with grade ≥3 treatment-related adverse events occurring in 5–17%. Based on a large phase 2 study, pembrolizumab was approved in the United States for third-line treatment of patients with PD-L1 + GC/GEJC. In a phase 3 trial, third-line or later nivolumab increased overall survival vs placebo in an Asian population, leading to regulatory approval in Japan, although other completed phase 3 trials did not show superiority for pembrolizumab or avelumab monotherapy vs chemotherapy. Other trials in advanced GC/GEJC are assessing various anti–PD-1/PD-L1–based strategies, including administration in first-line and later-line settings and as combination (with chemotherapy or agents targeting other immune checkpoint proteins, eg, CTLA-4, LAG-3, and IDO) or switch-maintenance regimens. Conclusions Anti–PD-1/PD-L1 antibodies have shown encouraging clinical activity in advanced GC/GEJC. Results from ongoing phase 3 trials are needed to further evaluate the potential roles of these agents within the continuum of care