{"id":"W2260959591","doi":"","title":"Downstream Loan Guarantees and Subsection 247(7.1) Transfer Pricing Relief","year":2013,"lang":"en","type":"article","venue":"SSRN Electronic Journal","topic":"Taxation and Legal Issues","field":"Business, Management and Accounting","cited_by":0,"is_retracted":false,"has_abstract":true,"ca_institutions":"","funders":"","keywords":"Transfer pricing; Business; Debt; Downstream (manufacturing); Obligation; Revenue; Loan; Finance; Corporation; Upstream (networking); Multinational corporation; Economics; Law; Marketing; Telecommunications","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":[0.005386529,0.0006013394,0.0005708051,0.002267179,0.009221939,0.01073624,0.005371276,0.01315932,0.008386788],"category_scores_gemma":[0.01888322,0.0008969218,0.001640085,0.001687666,0.006225545,0.002265516,0.003550945,0.008436144,0.001411223],"about_ca_system_candidate":false,"about_ca_system_consensus":false,"about_ca_system_score_codex":0.02415255,"about_ca_system_score_gemma":0.04249663,"about_ca_topic_candidate":true,"about_ca_topic_consensus":false,"about_ca_topic_score_codex":0.5753431,"about_ca_topic_score_gemma":0.7128126,"domain_scores_codex":[0.9731306,0.001709872,0.001026125,0.001728516,0.01558646,0.006818428],"domain_scores_gemma":[0.9896483,0.00281201,0.0009505692,0.0009312097,0.004964243,0.0006937535],"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":[0.00008225318,0.00009629705,0.009904786,0.0001110414,0.00003318736,0.001695468,0.003228436,0.001644809,0.002166142,0.9081939,0.05642522,0.01641862],"study_design_scores_gemma":[0.0002040903,0.0006001621,0.1086132,0.001268782,0.000528188,0.004227852,0.01002066,0.008578906,0.0177375,0.1196136,0.7276316,0.0009753695],"study_design_candidate":"not_applicable","study_design_consensus":null,"genre_codex":"other","genre_gemma":"empirical","genre_scores_codex":[0.1372281,0.0009937417,0.006448622,0.013768,0.0004928991,0.0005605257,0.0008660773,0.0003455134,0.8392966],"genre_scores_gemma":[0.8935841,0.0006014979,0.005730044,0.0129169,0.0002996643,0.0002238962,0.0003826568,0.00006521335,0.08619606],"genre_candidate":"empirical","genre_consensus":null,"teacher_disagreement_score":0.5753431,"threshold_uncertainty_score":0.8543155,"prediction_status":"machine_predicted_unvalidated"},"machine_scores":{"provisional":true,"baseline":true,"maturity_gate_passed":false,"score_opus":0.00559573061097964,"score_gpt":0.1924729203112854,"score_spread":0.1868771897003057,"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."}}