Limitations of the concept of permanent establishment and e-commerce

The concept of permanent establishment introduced over a century ago became obsolete in the XXI age. It is completely irrelevant in terms of modern online business. Recent OECD initiatives are only a late reaction to the internationally observed legal loophole in taxing profits of e-commerce companies. Steps taken by the international community over the last few years reveal considerable diversity in approaches towards the concept of permanent establishment. Even the key principles to be followed in the development of the new concept of permanent establishment have not been agreed so far. The present article is an attempt to propose the major principles to be followed in updated interpretations of the concept of permanent establishment equally effective in terms of both big multinationals and SMEs.

Modeling and Observer-Based Monitoring of RAFT Homopolymerization Reactions

Reversible addition–fragmentation chain–transfer (RAFT) polymerization of methyl methacrylate (MMA) is modeled and monitored using a multi-rate multi-delay observer in this work. First, to fit the RAFT reaction rate coefficients and the initiator efficiency in the model, in situ 1 H nuclear magnetic resonance (NMR) experimental data from small-scale (<2 mL) NMR tube reactions is obtained and a least squares optimization is performed. 1 H NMR and size exclusion chromatography (SEC) experimental data from large-scale (>400 mL) reflux reactions is then used to validate the fitted model. The fitted model accurately predicts the polymer properties of the large-scale reactions with slight discordance at late reaction times. Based on the fitted model, a multi-rate multi-delay observer coupled with an inter-sample predictor and dead time compensator is designed, to account for the asynchronous multi-rate measurements with non-constant delays. The multi-rate multi-delay observer shows perfect convergence after a few sampling times when tested against the fitted model, and is in fair agreement with the real data at late reaction times when implemented based on the experimental measurements.

Operationalization of Competency-Based Approach: From Competency-Based Education to Integration Pedagogy

Advocates of integration pedagogy such as Peyser et al. (2006) and Roegiers (2010) consider this instructional approach as a distinct pedagogical trend, while opponents of this view such as Hirtt (2009) regard integration pedagogy and competency-based education (CBE) as two sides of the same coin. In the view of this inconsistency and in order to help teachers and scholars have a well-informed idea on the essence of these educational movements, this article attempts to explore their similarities and differences and show how integration pedagogy has attempted to interpret the principles of competency-based approach (CBA). In so doing, the study traces back the origins of integration pedagogy in relation to CBE. This analysis of the historical and theoretical background of integration pedagogy indicates that this instructional approach is relatively different from CBE in that it has emerged in the 1980s as a late reaction to objective-based pedagogy, but as a concrete attempt to operationalize and simplify the broad principles of CBE, which evolved earlier in the US in the 1970s. Also, the results spell out the theoretical similarities and differences relating to these teaching approaches. Accordingly, teachers, researchers, and program evaluators are advised to approach integration pedagogy as a fairly different realization of CBA with distinct teaching guidelines.

A confessing church at war with itself: The significance of the relationship between the concepts “Gospel and law”

The confessing movement of Germany has influenced the South African confessional movement. Although the confessing movement of Germany was successful in alerting some Christians of the ills of nationalism and the concoction of nationalism with theology, this movement was not without its own challenges. One major challenge was revealed in terms of how the concepts Gospel and Law were related with one another. Being constituted by different ecclesial traditions, it lacked a clear consensus of how to deal with secular law, which was considered to be of concern by the state. A separation between gospel and law, which is sometimes insisted upon especially in some theological traditions is seen in this article as one contributing factor to the German church’s late reaction to the Jewish question.