Suchergebnisse

The suggestion to "align international taxation with value creation" first emerged in the context of the OECD BEPS Project aimed at tackling aggressive tax planning strategies resulting in base erosion and profit shifting. The concept of "value creation" was then further relied on in the broader discussion that followed about the impact of digitalization on the global economy generally and the fair allocation of taxes between countries in this new environment. Although the idea – or the guiding principle – that profits should be taxed where economic activities occur and where value is expected to be created initially received a relatively large support, it rapidly became clear (at least to academics) that there would be no obvious answer to the question "where is value being created?" in a manner that would be relevant for (international) tax purposes, inter alia in view of the different models of value creation within corporate entities. Based on 9 thematic reports (offering an interdisciplinary discussion of the concept of value creation mostly from an international perspective) and on 23 national reports (focusing on the meaning of value creation in domestic tax law), this book seeks to contribute to the discussion on whether the concept of value creation is viable, both theoretically and in practice, as a criterion for the allocation of taxing rights under a modernized international tax framework.

The Creation and Catastrophe Symposium was held on 7 April 2016 in London. The event brought together over 60 participants and was organised in collaboration with RMIT University, Oxford Brookes University and the International Federation of Red Cross and Red Crescent Societies. It was hosted by the Royal Institute of British Architects (RIBA). The community of practitioners, academics and representatives of government and non- government organisations working in the disaster and development sector were invited to facilitate information sharing and cross boundary links. With the diversity of professional roles across the participants, the organisers aspired to build links with the built environment and explore future collaborations as well as to create a frame of reference for the community. Among the topics to be debated were issues regarding professional recognition and accreditation of architectural work in the disaster and development sector as well as how to promote the interest of the architecture profession in risk reduction not just post- disaster settlement Furthermore, the symposium is thought to be the first in an annual event series or meeting forum to start a 'network of networks'. This report summarises the panel presentations and discussions and highlights the outcomes and future actions resulting from the symposium.

This article is a critical investigation and application of the aesthetic theory of Cornelius Castoriadis, one of the most important 20th-century theorists of radical democracy. We outline Castoriadis's thoughts on autonomy, the social-historical nature of Being, and creation -- key elements that inform his model of democratic culture. We then develop a Castoriadian critique of culture produced by capitalist institutions. By also drawing on the political economic thought of Thorstein Veblen, Jonathan Nitzan and Shimshon Bichler, our critique focuses on one sector of contemporary culture: Hollywood film. We show how Hollywood, as a business enterprise, uses techniques of sabotage and capitalization to control and occult the social-historical nature of creation. Lastly, by way of conclusion, we gesture toward a mode of artistic production that is able to affirm the democratic values that organize Castoriadis's thought.