This paper explores the compatibility of the Income Inclusion Rule(IIR)and the Undertaxed Profits Rule(UTPR)with existing tax treaties.The paper first assesses whether the taxes under IIR and UTPR meet the coverage cr...This paper explores the compatibility of the Income Inclusion Rule(IIR)and the Undertaxed Profits Rule(UTPR)with existing tax treaties.The paper first assesses whether the taxes under IIR and UTPR meet the coverage criteria of Art.2 of the OECD Model Convention(MC)and then analyses potential treaty infringements,focusing on Art.7,9,and 10(5),highlighting the inherent contradiction between tax treaties,which aim to limit taxing rights,and the global minimum tax,which allows taxation of global profits.Next,the paper reviews the historical development of IIR and UTPR,emphasising the OECD's initial recognition of the need for treaty amendments but noting the current lack of multilateral solutions,which poses potential dispute risks.In conclusion,the paper argues that the global minimum tax presents compliance challenges and legal uncertainties,questioning the binding effect of double taxation agreements.The article calls on the OECD to resolve these uncertainties through international agreements and advises countries to carefully consider the legal implications when implementing the IIR and the UTPR.展开更多
Both reasonable accommodation and accessibility are crucial concepts in the UN Convent ion on the Rights of Persons with Disabilities Those two concepts promote each other and should develop as a whole State parties...Both reasonable accommodation and accessibility are crucial concepts in the UN Convent ion on the Rights of Persons with Disabilities Those two concepts promote each other and should develop as a whole State parties of the Convention undertake immediate obligations to ensure the provision of reasonable accommodation, which has advantages such as characteristics of subjective rights, individualization, justiciability and convenience, making it a flexible tool for the protection of rights It can serve as a supplement to insufficient accessibility and play a unique role in other areas which are irrelevant to accessibility, so as to satisfy the special needs of certain subjects to the largest extent The State Party has an ex ante and progressive obligations to the realization of the accessibility construction, which has advantages of comman design, large scale, economization and no need for individualization consideration In China, various forms of reasonable accommodation have been applied in employment, but they have disadvantages of contingency, randomness, simplicity and lack of systematic support In the process of further promoting the employment of people with disabilities in China, in addition to strengthening accessibility construction, we must fully understand and flexibly adopt reasonable accommodation.展开更多
A close study of Heisenberg uncertainty principles reveals many significant facts,and all four major physical quantities,energy,time,momentum and length,have both lower and upper limits.Now,many questions come up.What...A close study of Heisenberg uncertainty principles reveals many significant facts,and all four major physical quantities,energy,time,momentum and length,have both lower and upper limits.Now,many questions come up.What are these limits?Some answers may lead to the understanding of the development of our universe.What is the shortest limit of time?At the beginning of big bang,there exists a tre-mendously short time,the Planck time.This may be just the shortest time limit in our universe.The longest time limit might be the lifetime of our universe.The longest length might be the final diameter of our expanding universe.All these lead to a finite universe.Two more coupling formulae are formed for the other two pairs of physical quantities,mass and speed,thermal energy and temperature.These four physical quantities must also have limits.We already knew that speed has upper limit and temperature has lower limit.By these two formulae,Planck and Einstein equations are derived directly.Since most other physical quantities are somewhat related to these major physical quantities,it seems that there exists a principle of limitation of physical quantities.A quantitative sketch of big bang is described.It also shows that our universe will contract back to another big bang.The principle of limitation opens up some fields of investigation.It may bring nature back to the harmony and determined world described by classical physics.展开更多
文摘This paper explores the compatibility of the Income Inclusion Rule(IIR)and the Undertaxed Profits Rule(UTPR)with existing tax treaties.The paper first assesses whether the taxes under IIR and UTPR meet the coverage criteria of Art.2 of the OECD Model Convention(MC)and then analyses potential treaty infringements,focusing on Art.7,9,and 10(5),highlighting the inherent contradiction between tax treaties,which aim to limit taxing rights,and the global minimum tax,which allows taxation of global profits.Next,the paper reviews the historical development of IIR and UTPR,emphasising the OECD's initial recognition of the need for treaty amendments but noting the current lack of multilateral solutions,which poses potential dispute risks.In conclusion,the paper argues that the global minimum tax presents compliance challenges and legal uncertainties,questioning the binding effect of double taxation agreements.The article calls on the OECD to resolve these uncertainties through international agreements and advises countries to carefully consider the legal implications when implementing the IIR and the UTPR.
文摘Both reasonable accommodation and accessibility are crucial concepts in the UN Convent ion on the Rights of Persons with Disabilities Those two concepts promote each other and should develop as a whole State parties of the Convention undertake immediate obligations to ensure the provision of reasonable accommodation, which has advantages such as characteristics of subjective rights, individualization, justiciability and convenience, making it a flexible tool for the protection of rights It can serve as a supplement to insufficient accessibility and play a unique role in other areas which are irrelevant to accessibility, so as to satisfy the special needs of certain subjects to the largest extent The State Party has an ex ante and progressive obligations to the realization of the accessibility construction, which has advantages of comman design, large scale, economization and no need for individualization consideration In China, various forms of reasonable accommodation have been applied in employment, but they have disadvantages of contingency, randomness, simplicity and lack of systematic support In the process of further promoting the employment of people with disabilities in China, in addition to strengthening accessibility construction, we must fully understand and flexibly adopt reasonable accommodation.
文摘A close study of Heisenberg uncertainty principles reveals many significant facts,and all four major physical quantities,energy,time,momentum and length,have both lower and upper limits.Now,many questions come up.What are these limits?Some answers may lead to the understanding of the development of our universe.What is the shortest limit of time?At the beginning of big bang,there exists a tre-mendously short time,the Planck time.This may be just the shortest time limit in our universe.The longest time limit might be the lifetime of our universe.The longest length might be the final diameter of our expanding universe.All these lead to a finite universe.Two more coupling formulae are formed for the other two pairs of physical quantities,mass and speed,thermal energy and temperature.These four physical quantities must also have limits.We already knew that speed has upper limit and temperature has lower limit.By these two formulae,Planck and Einstein equations are derived directly.Since most other physical quantities are somewhat related to these major physical quantities,it seems that there exists a principle of limitation of physical quantities.A quantitative sketch of big bang is described.It also shows that our universe will contract back to another big bang.The principle of limitation opens up some fields of investigation.It may bring nature back to the harmony and determined world described by classical physics.
