Is Cloud Computing a Challenge to the Traditional Concept of a Permanent Establishment?

2013 ◽  
Author(s):  
Maria Cecilia Rossi
Keyword(s):  
Cloud Computing ◽  
Traditional Concept ◽  
Permanent Establishment

scholarly journals Cloud computing concept in education systems

2020 ◽  
Vol 5 (2) ◽  
pp. 25-32
Author(s):  
Brankica Pažun ◽  
Zlatko Langović
Keyword(s):  
Cloud Computing ◽  
New Technology ◽  
Educational Systems ◽  
Capital Investments ◽  
Data Systems ◽  
Late 20Th Century ◽  
Traditional Concept ◽  
Capacity Data ◽  
The Impact ◽  
The Given

Cloud technology is a system that enables the use of IT resources more efficiently, simply and cheaply. The cost-effectiveness of applying this technology is reflected in the optimization of operating costs, the optimization of capital investments, as well as the reduction of costs. Electronic education as a system began to "live" in the late 20th century in the form of IT applications. Nowadays, these applications are in a new environment - Cloud Computing. The amount of data that needs to be processed grows and has a tendency to accelerate. This huge amount of data is necessary to store, transfer and process in a unit of time this requires the development of certain systems. The given systems that enable the management of the given resources are big data systems, internet of things, cloud platforms, virtualization, artificial intelligence, 5g, etc. The platform structure that carries these systems is cloud computing. The use of cloud computing as a new technology for the realization of e-learning enhances educational and research systems, in terms of storage and flow capacity, data processing speed and availability of information with the aim of a better educational environment with greater controllability, is more economical, efficient and safer in relation to the traditional concept. The paper presents the impact of ICT and cloud computing on educational systems, which should be part of new trends due to the advantages that given technology brings.

scholarly journals PERMANENT ESTABLISHMENT. THE CRISIS OF THE ARTICLE 5 OECD MC IN THE DIGITAL ECONOMY

2021 ◽  
Vol 180 (3) ◽  
pp. 97-131
Author(s):  
Montserrat Hermosín Álvarez
Keyword(s):  
Business Models ◽  
Digital Economy ◽  
Legal Regime ◽  
Traditional Concept ◽  
Permanent Establishment ◽  
Physical Presence ◽  
The Moment ◽  
Article 5 ◽  
Economic Capacity

The rise of the digital economy, breaking with business models that require a physical presence to develop their activities, has dislodged the traditional concept of permanent establishment set out in Article 5 OECD MC. In the light of the precept’s loopholes, large multinationals have engaged in abusive practices to relocate their profits, thus avoiding contributing in the States where the income is generated in accordance with their economic capacity. In this paper, we examine the concept of permanent establishment included in art. 5 OECD MC, its typology following the BEPS Project’s modifications and the different scenarios that do not constitute a permanent establishment. We also explore whether its legal regime continues to be useful in today’s context or whether, on the contrary, the moment has come to abandon the concept of permanent establishment entirely due to the problems generated by today’s article 5 OECD MC, unable to respond to the challenges posed by the digital economy.

scholarly journals A New Nexus Based on the Concept of Significant Economic Presence: The Digital Permanent Establishment

2019 ◽  
pp. 377-390
Author(s):  
Soraya Rodríguez Losada
Keyword(s):  
Foreign Market ◽  
Corporate Taxation ◽  
Final Report ◽  
Traditional Concept ◽  
Permanent Establishment ◽  
Physical Presence

The traditional concept of EP status is obsolete and enables digital companies to enter a foreign market jurisdiction without having a minimal physical presence. These companies usually do not reach the threshold required to establish the necessary taxable nexus to attribute the profits to that jurisdiction. For the purpose of realigning corporate taxation with the location of actual business activities, Action 1 Final Report relaunches the debate of a new nexus based on the concept of significant economic presence.

The Concepts of Legal Status of the Permanent Establishment in the Era of Digital Economy

2019 ◽  
pp. 2079-2090
Author(s):  
Karina A. Ponomareva
Keyword(s):  
Comparative Analysis ◽  
Legal Status ◽  
Digital Economy ◽  
Tax Law ◽  
Traditional Concept ◽  
Tax Legislation ◽  
Permanent Establishment ◽  
Physical Presence ◽  
The Subject ◽  
Traditional Approaches

The purpose of the article is to identify the key features of the proposals to modify the concept of permanent establishment in digital economy, as well as their differences from the traditional concept of permanent establishment. The subject of the study is a comparative analysis of the concepts of digital presence, aimed at finding new factors for the distribution of tax revenues between the states in which digital enterprises operate. The development of the digital economy necessitates the revision of traditional approaches to the taxation of permanent establishment in the doctrine of tax law and in tax legislation. The article considers doctrinal approaches to the concept of permanent establishment in the digital economy, as well as the proposals of the OECD and the European Commission. The core of the debate is the question of whether the classical concept of permanent establishment remains a basis for source taxation for multinational digital enterprises. A comparative analysis of international and European practice shows that the concept of permanent establishment is based on the minimum level of presence of a non-resident in the country required for taxation. This is due to the fact that the main feature of the functioning of digital enterprises, important for tax law, is the absence of the need for their physical presence in the state

Cloud-Computing: eHealth aus der Wolke

2018 ◽  
Vol 23 (11) ◽  
pp. 38-41
Author(s):  
Sebastian Krolop ◽  
Florian Benthin ◽  
Constanze Knahl
Keyword(s):  
Cloud Computing ◽  
Point Of Care

Cloud-Computing gewinnt auch in Kliniken zunehmend an Bedeutung. Über das Internet bereitgestellte Lösungen verändern nicht nur Verwaltung und Logistik – im klinischen Bereich geht es zum Beispiel um die Nutzung elektronischer Patientenakten am Point-of-Care.

How to Correct for Chance Agreement in the Estimation of Sensitivity and Specificity of Diagnostic Tests

1994 ◽  
Vol 33 (02) ◽  
pp. 180-186 ◽  
Author(s):  
H. Brenner ◽  
O. Gefeller
Keyword(s):  
Sensitivity And Specificity ◽  
Disease Status ◽  
Disease Prevalence ◽  
Small Sample ◽  
Small Samples ◽  
Interval Estimate ◽  
Traditional Concept ◽  
Interval Estimates ◽  
Major Disadvantage ◽  
Test Result

Abstract:The traditional concept of describing the validity of a diagnostic test neglects the presence of chance agreement between test result and true (disease) status. Sensitivity and specificity, as the fundamental measures of validity, can thus only be considered in conjunction with each other to provide an appropriate basis for the evaluation of the capacity of the test to discriminate truly diseased from truly undiseased subjects. In this paper, chance-corrected analogues of sensitivity and specificity are presented as supplemental measures of validity, which pay attention to the problem of chance agreement and offer the opportunity to be interpreted separately. While recent proposals of chance-correction techniques, suggested by several authors in this context, lead to measures which are dependent on disease prevalence, our method does not share this major disadvantage. We discuss the extension of the conventional ROC-curve approach to chance-corrected measures of sensitivity and specificity. Furthermore, point and asymptotic interval estimates of the parameters of interest are derived under different sampling frameworks for validation studies. The small sample behavior of the estimates is investigated in a simulation study, leading to a logarithmic modification of the interval estimate in order to hold the nominal confidence level for small samples.

Challenges and Cloud Computing Environments Towards Big Data

2014 ◽  
pp. 203-208
Author(s):  
Kiran Kumar S V N Madupu
Keyword(s):  
Data Mining ◽  
Cloud Computing ◽  
Big Data ◽  
Technology Development ◽  
Computing Environments ◽  
Modern Technologies

Big Data has terrific influence on scientific discoveries and also value development. This paper presents approaches in data mining and modern technologies in Big Data. Difficulties of data mining as well as data mining with big data are discussed. Some technology development of data mining as well as data mining with big data are additionally presented.

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