{"id":"W2139402243","doi":"10.19030/iber.v13i3.8591","title":"The Permanent Establishment Concept In Double Tax Agreements Between Developed And Developing Countries: Canada/South Africa As A Case In Point","year":2014,"lang":"en","type":"article","venue":"International Business & Economics Research Journal (IBER)","topic":"Taxation and Legal Issues","field":"Business, Management and Accounting","cited_by":2,"is_retracted":false,"has_abstract":true,"ca_institutions":"","funders":"","keywords":"Tax treaty; Double taxation; Treaty; Developing country; International taxation; International economics; International trade; Context (archaeology); Tax reform; Direct tax; Tax avoidance; Economics; Foreign direct investment; Order (exchange); Value-added tax; Tax policy; Business; Public economics; Political science; Economic growth; Law; Macroeconomics; Finance; Geography","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":"metacan-v3-hybrid-931329e0061c","candidate_categories":[],"consensus_categories":[],"category_scores_codex":[0.003812525,0.0003200361,0.0002867212,0.001889391,0.01231952,0.009363601,0.001300915,0.003106299,0.002008282],"category_scores_gemma":[0.005861566,0.0002372362,0.0004103858,0.003083175,0.01483852,0.00474187,0.004756014,0.00581596,0.0001279031],"about_ca_system_candidate":false,"about_ca_system_consensus":false,"about_ca_system_score_codex":0.03814995,"about_ca_system_score_gemma":0.09973183,"about_ca_topic_candidate":true,"about_ca_topic_consensus":true,"about_ca_topic_score_codex":0.8102531,"about_ca_topic_score_gemma":0.8842666,"domain_scores_codex":[0.9954366,0.0007200576,0.000109251,0.0002809216,0.001674297,0.00177883],"domain_scores_gemma":[0.996857,0.001055306,0.0003292997,0.0001954787,0.000944761,0.0006181842],"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":[0.00001127098,0.000008688745,0.000727146,0.00006772537,0.000003788569,0.0005203316,0.005403494,0.0002476273,0.000163214,0.9770106,0.003592973,0.01224298],"study_design_scores_gemma":[0.00003821693,0.00007317662,0.009508635,0.001852914,0.0000582322,0.001641696,0.04414325,0.001568197,0.001299806,0.1333693,0.8063074,0.0001391789],"study_design_candidate":"not_applicable","study_design_consensus":null,"genre_codex":"other","genre_gemma":"empirical","genre_scores_codex":[0.1172524,0.02909262,0.01916515,0.04492492,0.001334165,0.0004106194,0.0001399368,0.00005139558,0.7876288],"genre_scores_gemma":[0.9360282,0.00889727,0.005630296,0.005118607,0.00009251494,0.0001150853,0.00005083901,0.00002403529,0.04404311],"genre_candidate":"empirical","genre_consensus":null,"teacher_disagreement_score":0.1897469,"threshold_uncertainty_score":0.3817287,"prediction_status":"machine_predicted_unvalidated"},"machine_scores":{"provisional":true,"baseline":true,"maturity_gate_passed":false,"score_opus":0.05407349356414165,"score_gpt":0.3085640305596323,"score_spread":0.2544905369954907,"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."}}