Anti-BEPS Measures in the EU This Master's thesis analyses the directives and legislative initiatives of the European Union aimed at fighting base erosion and profit shifting. The adoption of BEPS Action Plan, which sets out 15 specific recommendations to change national rules and tax treaties to effectively combat tax planning strategies and double taxation worldwide, has also led to significant developments in the European Union hard law. Council Directive (EU) 2016/1164 of 12 July 2016 laying down rules against tax avoidance practices that directly affect the functioning of the internal market and the Council Directive (EU) 2017/952 of 29 May 2017 amending Directive (EU) 2016/1164, as well as European Commission proposals for Common Consolidated Corporate Tax Base implement measures 2, 3 and 4 of the BEPS Action Plan, as well as, the amendments to the Administrative Cooperation Directive DAC 3, DAC 4 and DAC 6 implement measures 5, 12 and 13 of the BEPS Action Plan.
Anti-BEPS Measures in the EU This Master's thesis analyses the directives and legislative initiatives of the European Union aimed at fighting base erosion and profit shifting. The adoption of BEPS Action Plan, which sets out 15 specific recommendations to change national rules and tax treaties to effectively combat tax planning strategies and double taxation worldwide, has also led to significant developments in the European Union hard law. Council Directive (EU) 2016/1164 of 12 July 2016 laying down rules against tax avoidance practices that directly affect the functioning of the internal market and the Council Directive (EU) 2017/952 of 29 May 2017 amending Directive (EU) 2016/1164, as well as European Commission proposals for Common Consolidated Corporate Tax Base implement measures 2, 3 and 4 of the BEPS Action Plan, as well as, the amendments to the Administrative Cooperation Directive DAC 3, DAC 4 and DAC 6 implement measures 5, 12 and 13 of the BEPS Action Plan.
Anti-BEPS Measures in the EU This Master's thesis analyses the directives and legislative initiatives of the European Union aimed at fighting base erosion and profit shifting. The adoption of BEPS Action Plan, which sets out 15 specific recommendations to change national rules and tax treaties to effectively combat tax planning strategies and double taxation worldwide, has also led to significant developments in the European Union hard law. Council Directive (EU) 2016/1164 of 12 July 2016 laying down rules against tax avoidance practices that directly affect the functioning of the internal market and the Council Directive (EU) 2017/952 of 29 May 2017 amending Directive (EU) 2016/1164, as well as European Commission proposals for Common Consolidated Corporate Tax Base implement measures 2, 3 and 4 of the BEPS Action Plan, as well as, the amendments to the Administrative Cooperation Directive DAC 3, DAC 4 and DAC 6 implement measures 5, 12 and 13 of the BEPS Action Plan.
Anti-BEPS Measures in the EU This Master's thesis analyses the directives and legislative initiatives of the European Union aimed at fighting base erosion and profit shifting. The adoption of BEPS Action Plan, which sets out 15 specific recommendations to change national rules and tax treaties to effectively combat tax planning strategies and double taxation worldwide, has also led to significant developments in the European Union hard law. Council Directive (EU) 2016/1164 of 12 July 2016 laying down rules against tax avoidance practices that directly affect the functioning of the internal market and the Council Directive (EU) 2017/952 of 29 May 2017 amending Directive (EU) 2016/1164, as well as European Commission proposals for Common Consolidated Corporate Tax Base implement measures 2, 3 and 4 of the BEPS Action Plan, as well as, the amendments to the Administrative Cooperation Directive DAC 3, DAC 4 and DAC 6 implement measures 5, 12 and 13 of the BEPS Action Plan.
This master thesis examines the phenomenon of anti-Americanism in Western Europe in general and in Italy in particular. After the events of September 11th the US had received sympathy and support from many states of the world. However, just in two years all this disappeared: the war on terrorism incited by the US and finally the military offensive of 2003 against Iraq without a resolution of the UN brought an immense negative reaction in the world. The results of the opinion polls showed a general trend: the rise of negative attitudes towards America. Though the manifestations of anti-Americanism existed long before, it seems as many scholars have discovered the phenomenon of anti-Americanism anew and the main idea is that the 20th century (often called the American century) is giving the way to the new one – the century of hatred for America. Of course, after September 11th the main research area of anti-Americanism became analysis of this phenomenon in the Middle East. However, anti-Americanism exists also in Western Europe notwithstanding a long history of close US-Western Europe relations. Besides, the case of military intervention in Iraq had shown that also the consequences of this phenomenon can vary a lot. Hence, the main aim of this thesis is to analyze anti-Americanism in Western Europe and by analyzing the case of Italy distinguish the most important causes and consequences of this phenomenon. This analysis eventually allows to confirm/to deny such hypothesis: H1: A complex of many reasons causes anti-Americanism (i.e. there is not any single reason that causes this phenomenon); H2: Anti-Americanism so noticeable in the society can influence significantly the relations with the US. Since in the thesis the old and new manifestations of anti-Americanism are analyzed it permits to confirm/ to deny also this hypothesis: H3: The "New" anti-Americanism does not differ significantly from the "Old" one. In pursue of the main aim the thesis is divided in four parts. First of all the complexity of the definition of anti-Americanism and the historical development of the phenomenon is presented. Secondly, the experience of Italy's encounter with the US is analyzed as it is very important for the analysis of anti-Americanism. Thirdly, the main sources of anti-Americanism in Italy are revealed. Finally, the analysis examines two cases of anti-Americanism in Italy: the case of Vietnam and the case of military base in Vicenza. The analysis revealed that notwithstanding the long history of anti-Americanism there still does not exist unanimous definition of anti-Americanism. However, at this moment we can understand anti-Americanism as a sum of criticism of American society/culture, the rejection of economical model of the US and the opposition to the global projection of the American power. Besides, each country's encounter with the US forms the unique context for anti-Americanism. Furthermore, many different sources of anti-Americanism exist. Hence, we can confirm the H1 hypothesis. The analysis of the case of Italy had revealed a some kind of myth of America which had been formed in Italy and transformed into a model of America after the Second World War. The attitude of the Italian sources of anti-Americanism toward America is also very ambiguous. The traditional political parties still appreciate a "special relation" with the US, which has lost its importance in the Italian society. The analysis of both cases (the Vietnam war and the military base in Vicenza) had shown very similar results: only in cases of society's reaction all the elements of anti-Americanism were found and we could not reveal any significant deterioration of Italy-US relations. Furthermore, both cases testified that anti-Americanism often becomes a significant tool in internal political dispute. Hence we can deny the H2 hypothesis and confirm the H3 hypothesis.
This master thesis examines the phenomenon of anti-Americanism in Western Europe in general and in Italy in particular. After the events of September 11th the US had received sympathy and support from many states of the world. However, just in two years all this disappeared: the war on terrorism incited by the US and finally the military offensive of 2003 against Iraq without a resolution of the UN brought an immense negative reaction in the world. The results of the opinion polls showed a general trend: the rise of negative attitudes towards America. Though the manifestations of anti-Americanism existed long before, it seems as many scholars have discovered the phenomenon of anti-Americanism anew and the main idea is that the 20th century (often called the American century) is giving the way to the new one – the century of hatred for America. Of course, after September 11th the main research area of anti-Americanism became analysis of this phenomenon in the Middle East. However, anti-Americanism exists also in Western Europe notwithstanding a long history of close US-Western Europe relations. Besides, the case of military intervention in Iraq had shown that also the consequences of this phenomenon can vary a lot. Hence, the main aim of this thesis is to analyze anti-Americanism in Western Europe and by analyzing the case of Italy distinguish the most important causes and consequences of this phenomenon. This analysis eventually allows to confirm/to deny such hypothesis: H1: A complex of many reasons causes anti-Americanism (i.e. there is not any single reason that causes this phenomenon); H2: Anti-Americanism so noticeable in the society can influence significantly the relations with the US. Since in the thesis the old and new manifestations of anti-Americanism are analyzed it permits to confirm/ to deny also this hypothesis: H3: The "New" anti-Americanism does not differ significantly from the "Old" one. In pursue of the main aim the thesis is divided in four parts. First of all the complexity of the definition of anti-Americanism and the historical development of the phenomenon is presented. Secondly, the experience of Italy's encounter with the US is analyzed as it is very important for the analysis of anti-Americanism. Thirdly, the main sources of anti-Americanism in Italy are revealed. Finally, the analysis examines two cases of anti-Americanism in Italy: the case of Vietnam and the case of military base in Vicenza. The analysis revealed that notwithstanding the long history of anti-Americanism there still does not exist unanimous definition of anti-Americanism. However, at this moment we can understand anti-Americanism as a sum of criticism of American society/culture, the rejection of economical model of the US and the opposition to the global projection of the American power. Besides, each country's encounter with the US forms the unique context for anti-Americanism. Furthermore, many different sources of anti-Americanism exist. Hence, we can confirm the H1 hypothesis. The analysis of the case of Italy had revealed a some kind of myth of America which had been formed in Italy and transformed into a model of America after the Second World War. The attitude of the Italian sources of anti-Americanism toward America is also very ambiguous. The traditional political parties still appreciate a "special relation" with the US, which has lost its importance in the Italian society. The analysis of both cases (the Vietnam war and the military base in Vicenza) had shown very similar results: only in cases of society's reaction all the elements of anti-Americanism were found and we could not reveal any significant deterioration of Italy-US relations. Furthermore, both cases testified that anti-Americanism often becomes a significant tool in internal political dispute. Hence we can deny the H2 hypothesis and confirm the H3 hypothesis.
A state of stalemate settled in on the frontlines of World War I, particularly on the Western Front, which was a result of defensive systems that had greatly improved at the beginning of the twentieth century. It was a trigger to develop new offensive techniques that would stir up the entrenched fronts of World War I. Mechanised corps, including tank units, was one of such newly introduced techniques. With the advent of a new type of weapon, the need had arisen to improve defence by reinforcing it with anti-tank systems. In the wake of the 1914–1918 war and with the mechanised forces rapidly developing in the interwar years, it became necessary to create motorised infantry mobility of which, in combination with mechanised units, had increased exponentially leading to an enhanced importance of anti-tank weapons in combat. The issue of anti-tank defence was also of major concern in the armed forces of interwar Lithuania. In view of the then geopolitical situation of Lithuania and taking into account the national defence plans, it was Poland, Germany and the Soviet Union that were deemed the key aggressors constituting a threat to Lithuania's sovereignty. An analysis of sources shows that the two latter states had highly developed concepts of mechanised armies, thereby making the issue of anti-tank defence even more important for the Lithuanian army. Hence, the aim of this research is to examine and estimate capabilities of the Lithuanian armed forces to maintain defence against the enemy's heavy (mechanised) forces by making an analysis of the provisions enshrined in the statutes of Lithuania's army, the reflections on the experiences of military conflicts between 1935 and 1940 in the ranks of the leadership of the Lithuanian army, and actual capabilities to conduct defence against mechanised forces of the hostile armies.
A state of stalemate settled in on the frontlines of World War I, particularly on the Western Front, which was a result of defensive systems that had greatly improved at the beginning of the twentieth century. It was a trigger to develop new offensive techniques that would stir up the entrenched fronts of World War I. Mechanised corps, including tank units, was one of such newly introduced techniques. With the advent of a new type of weapon, the need had arisen to improve defence by reinforcing it with anti-tank systems. In the wake of the 1914–1918 war and with the mechanised forces rapidly developing in the interwar years, it became necessary to create motorised infantry mobility of which, in combination with mechanised units, had increased exponentially leading to an enhanced importance of anti-tank weapons in combat. The issue of anti-tank defence was also of major concern in the armed forces of interwar Lithuania. In view of the then geopolitical situation of Lithuania and taking into account the national defence plans, it was Poland, Germany and the Soviet Union that were deemed the key aggressors constituting a threat to Lithuania's sovereignty. An analysis of sources shows that the two latter states had highly developed concepts of mechanised armies, thereby making the issue of anti-tank defence even more important for the Lithuanian army. Hence, the aim of this research is to examine and estimate capabilities of the Lithuanian armed forces to maintain defence against the enemy's heavy (mechanised) forces by making an analysis of the provisions enshrined in the statutes of Lithuania's army, the reflections on the experiences of military conflicts between 1935 and 1940 in the ranks of the leadership of the Lithuanian army, and actual capabilities to conduct defence against mechanised forces of the hostile armies.
A state of stalemate settled in on the frontlines of World War I, particularly on the Western Front, which was a result of defensive systems that had greatly improved at the beginning of the twentieth century. It was a trigger to develop new offensive techniques that would stir up the entrenched fronts of World War I. Mechanised corps, including tank units, was one of such newly introduced techniques. With the advent of a new type of weapon, the need had arisen to improve defence by reinforcing it with anti-tank systems. In the wake of the 1914–1918 war and with the mechanised forces rapidly developing in the interwar years, it became necessary to create motorised infantry mobility of which, in combination with mechanised units, had increased exponentially leading to an enhanced importance of anti-tank weapons in combat. The issue of anti-tank defence was also of major concern in the armed forces of interwar Lithuania. In view of the then geopolitical situation of Lithuania and taking into account the national defence plans, it was Poland, Germany and the Soviet Union that were deemed the key aggressors constituting a threat to Lithuania's sovereignty. An analysis of sources shows that the two latter states had highly developed concepts of mechanised armies, thereby making the issue of anti-tank defence even more important for the Lithuanian army. Hence, the aim of this research is to examine and estimate capabilities of the Lithuanian armed forces to maintain defence against the enemy's heavy (mechanised) forces by making an analysis of the provisions enshrined in the statutes of Lithuania's army, the reflections on the experiences of military conflicts between 1935 and 1940 in the ranks of the leadership of the Lithuanian army, and actual capabilities to conduct defence against mechanised forces of the hostile armies.
A state of stalemate settled in on the frontlines of World War I, particularly on the Western Front, which was a result of defensive systems that had greatly improved at the beginning of the twentieth century. It was a trigger to develop new offensive techniques that would stir up the entrenched fronts of World War I. Mechanised corps, including tank units, was one of such newly introduced techniques. With the advent of a new type of weapon, the need had arisen to improve defence by reinforcing it with anti-tank systems. In the wake of the 1914–1918 war and with the mechanised forces rapidly developing in the interwar years, it became necessary to create motorised infantry mobility of which, in combination with mechanised units, had increased exponentially leading to an enhanced importance of anti-tank weapons in combat. The issue of anti-tank defence was also of major concern in the armed forces of interwar Lithuania. In view of the then geopolitical situation of Lithuania and taking into account the national defence plans, it was Poland, Germany and the Soviet Union that were deemed the key aggressors constituting a threat to Lithuania's sovereignty. An analysis of sources shows that the two latter states had highly developed concepts of mechanised armies, thereby making the issue of anti-tank defence even more important for the Lithuanian army. Hence, the aim of this research is to examine and estimate capabilities of the Lithuanian armed forces to maintain defence against the enemy's heavy (mechanised) forces by making an analysis of the provisions enshrined in the statutes of Lithuania's army, the reflections on the experiences of military conflicts between 1935 and 1940 in the ranks of the leadership of the Lithuanian army, and actual capabilities to conduct defence against mechanised forces of the hostile armies.
The main object of this article is Anti-Soviet Resistance of Lithuanian Academic Youth in the 1950s and 1960s of 20th century. The Anti-Soviet resistance movement showed that young people in Lithuania didn't accept soviet authority and regime. They defined it as occupation power and fought for Lithuanian independence. This battle for independence was unarmed, but organized and non-organized. The main forms of organized Anti-Soviet resistance in Lithuania were: the formation of Anti-Soviet organizations and groups, the distribution of patriotic leaflets, painting patriotic slogans on the walls, doors and etc., raising national flags, remarking national and religious celebrations. The non-organized resistance, as well as organized resistance, had moral issues. If you agreed with soviet lifestyle and system, you had to make a compromise with yourself. Youths couldn't cope with propaganda and moral limitations which were ignited by the soviet regime and they tried to rebel through reaching for new Western music, fashion and other art forms. The escalating symbols of Western culture in soviet Lithuania were also forbidden and persecuted. The forms of youth resistance in Lithuania showed youth's reluctance in supporting the soviet regime and lifestyle. The most active members of academic youth in Lithuania participated in Anti-Soviet actions and Soviet government treated them as nationalists, Anti-Soviet elements. Moreover youngsters who distributed patriotic leaflets or painted patriotic slogans on the walls frequently didn't get a punishment, but they and some times their parents were instructed and prevented verbally by Soviet activists, Komsomol members. Generally young people were being sentenced to concentration camps for attending anti-soviet organizations or groups. These punishments were strict and the mark of previous conviction existed in the file during all soviet occupation period. This black mark in the file granted complexity of your life in soviet Lithuania and often a conflict with society. Finally Anti-Soviet Resistance of Lithuanian Academic Youth during 1950s and 1960s was inherent from all Lithuanian people Anti-Soviet resistance. A lot of young people were sentenced for being Anti-Soviet, but the most rebellious part of them never refused their patriotism and fight for freedom. This unarmed fight for freedom during 1950s and 1960s made the largest influence for further struggles in 1970s and 1980s till the independence of Lithuania was re-established.
The main object of this article is Anti-Soviet Resistance of Lithuanian Academic Youth in the 1950s and 1960s of 20th century. The Anti-Soviet resistance movement showed that young people in Lithuania didn't accept soviet authority and regime. They defined it as occupation power and fought for Lithuanian independence. This battle for independence was unarmed, but organized and non-organized. The main forms of organized Anti-Soviet resistance in Lithuania were: the formation of Anti-Soviet organizations and groups, the distribution of patriotic leaflets, painting patriotic slogans on the walls, doors and etc., raising national flags, remarking national and religious celebrations. The non-organized resistance, as well as organized resistance, had moral issues. If you agreed with soviet lifestyle and system, you had to make a compromise with yourself. Youths couldn't cope with propaganda and moral limitations which were ignited by the soviet regime and they tried to rebel through reaching for new Western music, fashion and other art forms. The escalating symbols of Western culture in soviet Lithuania were also forbidden and persecuted. The forms of youth resistance in Lithuania showed youth's reluctance in supporting the soviet regime and lifestyle. The most active members of academic youth in Lithuania participated in Anti-Soviet actions and Soviet government treated them as nationalists, Anti-Soviet elements. Moreover youngsters who distributed patriotic leaflets or painted patriotic slogans on the walls frequently didn't get a punishment, but they and some times their parents were instructed and prevented verbally by Soviet activists, Komsomol members. Generally young people were being sentenced to concentration camps for attending anti-soviet organizations or groups. These punishments were strict and the mark of previous conviction existed in the file during all soviet occupation period. This black mark in the file granted complexity of your life in soviet Lithuania and often a conflict with society. Finally Anti-Soviet Resistance of Lithuanian Academic Youth during 1950s and 1960s was inherent from all Lithuanian people Anti-Soviet resistance. A lot of young people were sentenced for being Anti-Soviet, but the most rebellious part of them never refused their patriotism and fight for freedom. This unarmed fight for freedom during 1950s and 1960s made the largest influence for further struggles in 1970s and 1980s till the independence of Lithuania was re-established.
A higher education institution striving for excellence puts effort to render effective, transparent services, sparingly use financial resources provided by the state and customers, intellectual resources and property. Corruption prevention is part of quality in a higher education institution therefore creating an anti-corruption system and integrating it into the internal quality assurance system can be the first step of the institution towards better governance. Even if no corrupt practices have been identified in an institution an all-encompassing anti-corruption policy will reduce a corruption risk and will promote international cooperation. The paper presents the survey carried out in 2012-2013 in the university and the model of an anti-corruption system built on the findings. The survey showed that both, the decision-makers, surveyed online, and the interviewed experts, specialists in the field, are of the opinion that an anti-corruption system should be created and implemented in a higher education institution as it is a precondition for good governance.
The article examines the positive and negative aspects of political correctness. Using the case of Donald Trump and looking back at the origins of politics, the manifestations of political (in)correctness under democratic conditions are analysed. The question of political (in)correctness arises in a democratic environment for three reasons. 1. As rule of the majority, democracy requires a compensation mechanisms for minorities. 2. Political correctness should be applied to any holder of political freedoms who elects and is elected under democratic conditions. 3. The very consideration of political correctness arises in a sufficiently democratic environment of free speech. what is politically correct and incorrect depends on the country's social circumstances, cultural traditions and language characteristics. Democracy is an environment in which political incorrectness is unmasked and the very dogma of political correctness is falsified. It is shown that political correctness has also an ideological aspect.