Suchergebnisse

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.

In recent years, the process of giving the heads of the constituent entities of the Russian Federation additional powers to overcome the consequences of emergency situations (such as the pandemic of the new coronavirus infection COVID‑19 or the introduction of illegal ("sanctions") restrictive economic measures against the Russian Federation) has been actively developing. This allotment, in particular, was carried out by Presidential Ukases No. 239 of April 2, 2020 and No. 121 of March 16, 2022. The author believes that the trend indicated by them is a new one in the development of Russian federalism. At the same time, it should be noted that the measures taken in 2022 to ensure socio-economic stability were not limited to expanding the rights of the heads of the subjects of the Russian Federation, but also provided for a number of other measures that change the design of the system of relations between the federal center and the subjects of the Russian Federation. The article analyzes the content of the above-mentioned measures and activities from the perspective of the theory of state functions, they are regarded as manifestations of the dynamics of the federal function of the state.

This article presents the analysis of implementation and interpretation of antitrust legislation in Russian courts, in the field of anti-competitive agreements cases. This article proceeds from the previous research which provided the analysis of the court decision database of litigations with the Russian competition authority (the FAS) initiated in 2008-2010. In this research (which covers court cases of 2011-2015) we provide the database of 646 court decisions and examine the tendencies of applying antitrust prohibitions and legislation in courts. We show how the database structure varies from the point of view of main markets and types of agreements, taking into account the standards of proof. The analysis reveals that the Rule of reason (ROR) approach was not actually applied in courts, despite legislative possibilities. Type 1 errors risks tends to decrease, especially in public procurement cases, cases of banks and insurance companies cooperation. Requirements in the field of market analysis in decisionmaking are also increasing.

The article based on an integrated approach to developed within the European Union mechanisms of preventing crimes, which affect the financial interests of the EU. In terms of specific examples the legal basis of anti-corruption interaction, especially the structural building of the basic institutions of the European Union, are analyzed. The article discusses the information potential to facilitate the implementation of effective cooperation among the competent authorities in the sphere of combating corruption, fraud, money laundering and other economic crimes. ; В статье с учетом комплексного подхода рассматриваются механизмы противодействия преступлениям, затрагивающим финансовые интересы Европейского Союза. На конкретных примерах анализируются правовые основы борьбы с коррупцией, легализацией преступных доходов и другими связанными с ними экономическими преступлениями. Автор раскрывает особенности структурного построения основных институтов и органов Европейского Союза и созданный межгосударственный информационный потенциал, способствующие эффективному взаимодействию компетентных органов в сфере противодействия преступлениям, затрагивающим финансовые интересы данной международной организации.

artykuł w: Wschód Europy : studia humanistyczno-społeczne Vol. 6, Nr 1 (2020), s. 91-111 ; streszcz. ang., pol., ros. ; artykuł w: Wschód Europy : studia humanistyczno-społeczne Vol. 6, Nr 1 (2020), s. 91-111 ; streszcz. ang., pol., ros.

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.

в статье проанализировано текущее состояние изучения института антикоррупционной экспертизы ; рассмотрены недостаточно урегулированные законодательством вопросы в этой сфере. Авторы отмечают ; что системная работа по совершенствованию нормативного и методического обеспечения антикоррупционной экспертизы в настоящее время должна стать одним из самых приоритетных направлений деятельности органов государственной власти. ; the current state of the study of the institute of anti-corruption expertise is analyzed in the article ; insufficiently regulated issues in the legislation in this area are considered. The authors note that systematic work to improve the normative and methodological support of anti-corruption expertise should now become one of the top priorities of the government.