{"id":"W1536268536","doi":"10.54648/taxi2011020","title":"Worrying Interpretation of Liable to Tax: OECD Clarification Would Be Welcome","year":2011,"lang":"en","type":"article","venue":"Intertax","topic":"Taxation and Legal Issues","field":"Business, Management and Accounting","cited_by":16,"is_retracted":false,"has_abstract":true,"ca_institutions":"","funders":"","keywords":"Treaty; Interpretation (philosophy); Tax treaty; Nexus (standard); Order (exchange); Law and economics; Supreme court; Political science; Law; Economics; State (computer science); Tax law; Double taxation; Business; Engineering; Finance","routes":{"ca_aff":false,"ca_fund":false,"ca_venue":false,"about_ca":true,"invisible_to_affiliation_only":true},"retraction":null,"screen":null,"direct_labels":[],"prediction":{"model_version":"codex-gemma-dda1882f352a","candidate_categories":["insufficient_payload"],"consensus_categories":["insufficient_payload"],"category_scores_codex":[0.0001549798,0.00009677296,0.0001267508,0.0002553544,0.00004332536,0.00008699989,0.0002031264,0.00008336243,0.001616788],"category_scores_gemma":[0.0001102816,0.00009118801,0.00005149725,0.00019143,0.00001970832,0.0007412026,0.0000655078,0.0001361608,0.0009024858],"about_ca_system_candidate":false,"about_ca_system_consensus":false,"about_ca_system_score_codex":0.00001831665,"about_ca_system_score_gemma":0.000005164533,"about_ca_topic_candidate":false,"about_ca_topic_consensus":false,"about_ca_topic_score_codex":0.003199107,"about_ca_topic_score_gemma":0.0002730251,"domain_scores_codex":[0.9993055,0.000007649189,0.0002677766,0.0001645943,0.0001263808,0.0001280985],"domain_scores_gemma":[0.9994271,0.00001267123,0.0002301563,0.0001870414,0.0001311458,0.00001188421],"domain_codex":null,"domain_gemma":null,"domain_candidate":null,"domain_consensus":null,"study_design_codex":"theoretical_or_conceptual","study_design_gemma":"not_applicable","study_design_scores_codex":[0.001474302,0.001089382,0.1265197,0.001100894,0.0002707675,0.00001763825,0.03643249,0.0003129044,0.06925819,0.4983525,0.08417358,0.1809976],"study_design_scores_gemma":[0.000645635,0.00008069543,0.05018797,0.0003919904,0.00008552233,0.000001324094,0.003470464,0.0113171,0.02083976,0.004424153,0.9079445,0.0006109026],"study_design_candidate":"not_applicable","study_design_consensus":null,"genre_codex":"empirical","genre_gemma":"empirical","genre_scores_codex":[0.6630083,0.00006338261,0.02744613,0.001976514,0.001452029,0.0004773206,0.000004033238,0.0002359124,0.3053364],"genre_scores_gemma":[0.9947505,9.732036e-7,0.0008127165,0.002502224,0.0001963689,0.0000209936,0.00001445615,0.00001502594,0.00168675],"genre_candidate":"empirical","genre_consensus":"empirical","teacher_disagreement_score":0.8237709,"threshold_uncertainty_score":0.9998754,"prediction_status":"machine_predicted_unvalidated"},"machine_scores":{"provisional":true,"baseline":true,"maturity_gate_passed":false,"score_opus":0.04665768955276208,"score_gpt":0.2563190491095632,"score_spread":0.2096613595568011,"validation_status":"score_only:v0-immature-baseline","note":"Baseline scores from an immature model (maturity gate not passed). Scores rank; they never assert a category."}}