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- Arfwidsson, Autilia, 1991-
(författare)
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Hybrid Mismatches in International Transactions : A Study of Linking Rules in EU and Tax Treaty Law
- 2024
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Doktorsavhandling (övrigt vetenskapligt/konstnärligt)abstract
- Hybrid mismatches, where differences in income characterisation across jurisdictions lead to double non-taxation, can be exploited by multinational enterprises to reduce their overall tax burden. Common hybrid mismatch rules addressing this issue have recently been introduced within the EU and the OECD. The adoption of these rules is unprecedented and poses a novelty for many states’ national tax systems. Beyond being technically complex, the operation of these rules necessitates interactions with other anti-avoidance rules, tax treaty provisions, EU law, OECD guidelines, and national rules in foreign jurisdictions.This thesis makes a significant contribution through its extensive structural examination of hybrid mismatches and their rules, covering both EU and tax treaty law. The examination primarily focuses on the hybrid mismatch rules in EU secondary law and their interactions with other aspects of EU and tax treaty law in preventing such mismatches. The analysis is conducted within the context of the rules’ underlying objectives.The study highlights five formal objectives of the rules: preventing tax avoidance, neutrality, equity, administrability, and legal certainty. However, a critical examination reveals that these objectives often lack substance or resemble political slogans. Several structural premises contributing to the occurrence of hybrid mismatches are identified, including the general trend of reducing or eliminating withholding taxes within EU and tax treaty law. While the hybrid mismatch rules play a crucial role in preventing mismatches, their complex design and technical limitations render them vulnerable to circumvention. Another issue is that they often risk resulting in unresolved double taxation when interacting with other parts of EU and tax treaty law. Ultimately, the rules are primarily focused on preventing tax avoidance but tend to overlook other objectives. The study particularly advocates for improved administrability and legal certainty.
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- Diamant, Adam, 1965-
(författare)
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Revisors oberoende
- 2004
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Doktorsavhandling (övrigt vetenskapligt/konstnärligt)abstract
- The main purpose of this study is to examine the Swedish regulations concerning auditors’ independence. In the study three questions are analysed. The first question concerns the function of the independence requirements. The basic thesis is that the regulations on independence are a part of the system securing the quality of the statutory auditors’ work. Therefore, it can be presumed that the purpose of the independence requirements is to secure the function of the audit requirements. Thus, by examining the function of the statutory audit, the purpose of the independence requirements can be established.The second question is what different kinds of threats to the auditors’ independence that may typically occur. The study is based on the conclusions concerning the purpose of the independence requirements. Two main categories of threats are identified. The first one occurs when the auditor has a too close relationship with the audit client or someone else who has a direct economical interest in the auditor’s work when performing the audit. The second type of threat is general in the meaning that the threat is related to the good reputation of the audit profession. The purpose of the study is to establish a basis for regulating the auditor’s independence.The last question to be answered is how the Swedish regulations concerning auditors’ independence are constructed. In this part of the study the regulations on independence of the 2001 Swedish Auditors Act (revisorslagen) are examined. Special attention will be paid to the so called self-review threat.
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- Grönqvist, Helena, 1975-, et al.
(författare)
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Fifteen Challenges in Establishing a Multidisciplinary Research Program on eHealth Research in a University Setting : A Case Study
- 2017
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Ingår i: Journal of Medical Internet Research. - : JMIR Publications Inc.. - 1438-8871. ; 19:5
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Tidskriftsartikel (refereegranskat)abstract
- BACKGROUND:U-CARE is a multidisciplinary eHealth research program that involves the disciplines of caring science, clinical psychology, health economics, information systems, and medical science. It was set up from scratch in a university setting in 2010, funded by a governmental initiative. While establishing the research program, many challenges were faced. Systematic documentation of experiences from establishing new research environments is scarce.OBJECTIVE:The aim of this paper was to describe the challenges of establishing a publicly funded multidisciplinary eHealth research environment.METHODS:Researchers involved in developing the research program U-CARE identified challenges in the formal documentation and by reflecting on their experience of developing the program. The authors discussed the content and organization of challenges into themes until consensus was reached.RESULTS:The authors identified 15 major challenges, some general to establishing a new research environment and some specific for multidisciplinary eHealth programs. The challenges were organized into 6 themes: Organization, Communication, Implementation, Legislation, Software development, and Multidisciplinarity.CONCLUSIONS:Several challenges were faced during the development of the program and several accomplishments were made. By sharing our experience, we hope to help other research groups embarking on a similar journey to be prepared for some of the challenges they are likely to face on their way.
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- Malinski, Bartosz, et al.
(författare)
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Novel pathological variants of NHP2 affect N-terminal domain flexibility, protein stability, H/ACA Ribonucleoprotein (RNP) complex formation and telomerase activity
- 2023
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Ingår i: Human Molecular Genetics. - : OXFORD UNIV PRESS. - 0964-6906 .- 1460-2083. ; 32:19, s. 2901-2912
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Tidskriftsartikel (refereegranskat)abstract
- Telomere biology disorders (TBDs) are characterized by short telomeres, premature aging, bone marrow failure and cancer predisposition. Germline mutations in NHP2, encoding for one component of the telomerase cofactor H/ACA RNA binding complex together with Dyskerin, NOP10 and GAR1, have been previously reported in rare cases of TBDs. Here, we report two novel NHP2 variants (NHP2-A39T and NHP2-T44M) identified in a compound heterozygous patient affected by premature aging, bone marrow failure/myelodysplastic syndrome and gastric cancer. Although still able to support cell viability, both variants reduce the levels of hTR, the telomerase RNA component, and telomerase activity, expanding the panel of NHP2 pathological variants. Furthermore, both variants fail to be incorporated in the H/ACA RNA binding complex when in competition with wild-type endogenous NHP2, and the lack of incorporation causes their drastic proteasomal degradation. By RoseTTAFold prediction followed by molecular dynamics simulations, we reveal a dramatic distortion of residues 33-41, which normally position on top of the NHP2 core, as the main defect of NHP2-A39T, and high flexibility and the misplacement of the N-terminal region (residues 1-24) in NHP2-T44M and, to a lower degree, in NHP2-A39T. Because deletion of amino acids 2-24 causes a reduction in NHP2 levels only in the presence of wild-type NHP2, while deletion of amino acids 2-38 completely disrupts NHP2 stability, we propose that the two variants are mis-incorporated into the H/ACA binding complex due to the altered dynamics of the first 23 amino acids and/or the distortion of the residues 25-41 loop.
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| 7. |
- Norberg, Claes, et al.
(författare)
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Accounting and Taxation, Kari Tikka Memorial Lecture
- 2008
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Ingår i: Accounting and taxation with special regard to trading in emission rights ; & Assessment of ECJ case law in matters of direct taxes and state aid : 2007 EATLP Congress; EATLP International Tax Series 5. - 9789081281911 ; 5
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Konferensbidrag (refereegranskat)
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| 19. |
- Olsson, Erik, et al.
(författare)
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U-CARE : a research program on psychosocial care via the internet
- 2012
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Konferensbidrag (refereegranskat)abstract
- U-CARE is one of the Swedish government’s strategic research programs atUppsala University. The overarching goal is to promote psychosocial healthamong patients suffering from somatic disease and their significant others by means of self-help programs delivered via an internet platform. Another goal is to reduce costs for individuals and the society caused by emotional distress in response to somatic disease. Professionals within clinical psychology, health economics, and information systems collaborate to reach this goal.Approximately 20% of patients suffering from somatic disease as well as theirsignificant others experience a clinically relevant level of emotional distress in response to disease and treatment. This is in itself alerting, but becomes even moreproblematic since physicians and nurses show low sensitivity and specificityin detecting patients and significant others experiencing a clinically relevant level of distress. This can result in persistent distress causing human suffering as well as costs for individuals and the society.During 2010-2011 an internet platform: www.u-care.se to provide interactive support and cognitive behavioral therapy has been constructed within the U-CARE program. The platform supports, among other things, rule-based unfolding of self-help material for participants, interaction between participants and therapists, interaction within a participant community, and research including a detailed log of participants’ behaviors on the platform. In addition self-help programs of interactive support and cognitive behavioural therapy for adolescents with cancer: U-CARE: TeenCan, adults with cancer: U-CARE: AdultsCan, and adults having had a myocardial infarct: U-CARE: Heart to be provided via www.u-care.se have been constructed.Through a multi-disciplinary and design-oriented approach, the U-CARE program aims at developing new evidence-based knowledge in basic and applied psychosocial health care,and actively promoting its implementation in health care practice as well as in undergraduate and advanced education.
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| 21. |
- Sundell, Jonas, 1984, et al.
(författare)
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A framework for Risk Assessment of Groundwater Drawdown Induced Subsidence
- 2015
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Ingår i: 5th International Symposium on Geotechnical Safety and Risk (ISGSR). - Amsterdam : Ios Press. - 9781614995807 ; , s. 256-262
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Konferensbidrag (refereegranskat)abstract
- Sub-surface constructions generally involve drainage of groundwater, which can induce land subsidence in compressible soil deposits and cause extensive damage costs in urban areas. A probabilistic framework, in accordance with the risk management framework outlined by the International Standard Organization (ISO), for assessing risks of groundwater drawdown induced subsidence is presented here. The framework consists of five modules: (1) A stratified geostatistical (Kriging) procedure for probabilistic spatial analysis of soil layers. This module is necessary for a detailed understanding of the soil stratification, drainage paths, and their potential spatial variations; (2) A stochastic hydrogeological model capable of representing possible groundwater drawdowns for a specific sub-surface construction; (3) A stochastic subsidence model; (4) A model for estimating the economic consequences and calculating the risk, i. e. the expected cost, of groundwater induced subsidence; and (5) A module for evaluating the need for additional information to reduce the risk of erroneous decisions with respect to risk acceptance criteria based on economic Value of Information Analysis (VOIA), i. e. a cost-benefit analysis (CBA) of additional information collection alternatives for suggested strategies to reduce or control subsidence. The modelled land-area is represented by a grid with calculation points. When the three first modules are linked together in a Monte Carlo-simulation, it is possible to estimate the spatial distribution of probability of subsidence and evaluate the sensitivity to different model and parameter assumptions. An estimation of the risk of subsidence is performed by combining the probability of land subsidence with the locations and expected damage costs of existing buildings across the modeled area (module 4). With sensitivity analysis, significant weaknesses can be identified and robust safety measures at locations with significant risks for subsidence can be planned for. Uncertainties can be communicated by mapping and comparing different outcomes of the model, e. g. the expected value and the 95th percentile of the risk. Together with affected stakeholders the assumptions and the outcomes of the model should be discussed - both how well the model describes the system dynamics and how safety measures should be implemented.
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| 22. |
- Sundell, Jonas, 1984, et al.
(författare)
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Risk Mapping of Groundwater-Drawdown-Induced Land Subsidence in Heterogeneous Soils on Large Areas
- 2019
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Ingår i: Risk Analysis. - : Wiley. - 0272-4332 .- 1539-6924. ; 39:1, s. 105-124
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Tidskriftsartikel (refereegranskat)abstract
- Groundwater leakage into subsurface constructions can cause reduction of pore pressure and subsidence in clay deposits, even at large distances from the location of the construction. The potential cost of damage is substantial, particularly in urban areas. The large-scale process also implies heterogeneous soil conditions that cannot be described in complete detail, which causes a need for estimating uncertainty of subsidence with probabilistic methods. In this study, the risk for subsidence is estimated by coupling two probabilistic models, a geostatistics-based soil stratification model with a subsidence model. Statistical analyses of stratification and soil properties are inputs into the models. The results include spatially explicit probabilistic estimates of subsidence magnitude and sensitivities of included model parameters. From these, areas with significant risk for subsidence are distinguished from low-risk areas. The efficiency and usefulness of this modeling approach as a tool for communication to stakeholders, decision support for prioritization of risk-reducing measures, and identification of the need for further investigations and monitoring are demonstrated with a case study of a planned tunnel in Stockholm.
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| 23. |
- Thorell, Per, et al.
(författare)
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Revisionsplikten i små aktiebolag
- 2005
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Ingår i: Nordisk tidsskrift for selskabsret. - 1399-140X. ; :2, s. 35-50
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Rapport (övrigt vetenskapligt/konstnärligt)
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| 24. |
- Aad, G, et al.
(författare)
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- 2015
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swepub:Mat__t
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