{"id":"W3211998322","doi":"","title":"海外重要租税判例 親会社による債務保証料の徴収金額が独立企業間価格として適正であるとされた事例 : G.E Capital Canada Inc. v. The Queen(2009 TCC 563 2010 FCA 344)","year":2020,"lang":"ja","type":"article","venue":"月刊税務事例","topic":"International Arbitration and Investment Law","field":"Business, Management and Accounting","cited_by":0,"is_retracted":false,"has_abstract":false,"ca_institutions":"","funders":"","keywords":"Queen (butterfly); Business","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":[0.003752935,0.0004408525,0.0002808422,0.0009706634,0.005572596,0.007941446,0.001208926,0.005681746,0.01182233],"category_scores_gemma":[0.006189581,0.0005018746,0.000470039,0.0006780605,0.007775086,0.003203283,0.001565722,0.006078718,0.004418299],"about_ca_system_candidate":false,"about_ca_system_consensus":false,"about_ca_system_score_codex":0.006876274,"about_ca_system_score_gemma":0.009750325,"about_ca_topic_candidate":true,"about_ca_topic_consensus":false,"about_ca_topic_score_codex":0.1055455,"about_ca_topic_score_gemma":0.1763217,"domain_scores_codex":[0.99598,0.0004368287,0.0002279507,0.0006456135,0.002001482,0.000708076],"domain_scores_gemma":[0.997148,0.0009312055,0.0002396977,0.0002221169,0.001292471,0.0001666526],"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":[0.00005447993,0.00003320197,0.0015281,0.0001134188,0.00001917727,0.0003956386,0.004057588,0.0001372651,0.001859683,0.8871568,0.08444913,0.02019545],"study_design_scores_gemma":[0.00004173539,0.00007915094,0.006653429,0.0003287051,0.00008421869,0.0005887102,0.003325857,0.0004823036,0.008471999,0.1734399,0.8063774,0.0001266657],"study_design_candidate":"not_applicable","study_design_consensus":null,"genre_codex":"other","genre_gemma":"other","genre_scores_codex":[0.01796564,0.002839576,0.004542444,0.02761947,0.0008627858,0.0001015195,0.0004556263,0.0001081798,0.9455047],"genre_scores_gemma":[0.6232796,0.00332717,0.007573952,0.04150346,0.0008869937,0.0001718499,0.0003266089,0.0001010987,0.3228292],"genre_candidate":"other","genre_consensus":"other","teacher_disagreement_score":0.8944545,"threshold_uncertainty_score":0.2098622,"prediction_status":"machine_predicted_unvalidated"},"machine_scores":{"provisional":true,"baseline":true,"maturity_gate_passed":false,"score_opus":0.01239733177198347,"score_gpt":0.1881838146345376,"score_spread":0.1757864828625541,"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."}}