{"id":"W4362576453","doi":"10.1080/17449480.2023.2192356","title":"Arm's Length Principle vs. Formulary Apportionment in BEPS Action 13: Stakeholders’ Perspectives","year":2023,"lang":"en","type":"article","venue":"Accounting in Europe","topic":"Corporate Taxation and Avoidance","field":"Business, Management and Accounting","cited_by":1,"is_retracted":false,"has_abstract":true,"ca_institutions":"York University","funders":"Social Sciences and Humanities Research Council of Canada; Escola Brasileira de Administração Pública e de Empresas","keywords":"Apportionment; Action (physics); Formulary; Business; Precautionary principle; Accounting; Political science; Law; Medicine; Pharmacology","routes":{"ca_aff":true,"ca_fund":true,"ca_venue":false,"about_ca":false,"invisible_to_affiliation_only":false},"retraction":null,"screen":null,"direct_labels":[],"prediction":{"model_version":"codex-gemma-dda1882f352a","candidate_categories":["insufficient_payload"],"consensus_categories":[],"category_scores_codex":[0.0008863744,0.0001883698,0.0001861331,0.0006396401,0.0001428894,0.0002634646,0.0002165164,0.00005147267,0.0001886122],"category_scores_gemma":[0.0003692904,0.0001969319,0.000042264,0.002383812,0.00003365565,0.001761257,0.0002093232,0.0002571661,0.0009971936],"about_ca_system_candidate":false,"about_ca_system_consensus":false,"about_ca_system_score_codex":0.0000950192,"about_ca_system_score_gemma":0.00003563751,"about_ca_topic_candidate":false,"about_ca_topic_consensus":false,"about_ca_topic_score_codex":0.0003219963,"about_ca_topic_score_gemma":0.0006167922,"domain_scores_codex":[0.9984232,0.00002043754,0.0004116304,0.0004313008,0.0003245111,0.0003889411],"domain_scores_gemma":[0.999185,0.00003731949,0.000380538,0.000243077,0.0001433479,0.00001069057],"domain_codex":null,"domain_gemma":null,"domain_candidate":null,"domain_consensus":null,"study_design_codex":"observational","study_design_gemma":"observational","study_design_scores_codex":[0.00007550355,0.0004065708,0.9605218,0.0002438495,0.0000171069,0.0001435981,0.001041707,0.005580341,0.002606316,0.01259742,0.004491701,0.01227412],"study_design_scores_gemma":[0.0007042971,0.000008133011,0.8559315,0.00009323553,0.000008030326,0.000001296707,0.00248949,0.01259452,0.0000742273,0.0005653296,0.1272353,0.0002946689],"study_design_candidate":"observational","study_design_consensus":"observational","genre_codex":"empirical","genre_gemma":"empirical","genre_scores_codex":[0.9839563,0.0000350952,0.00008918349,0.001074708,0.0003441807,0.0003108289,0.000001666793,0.0003045181,0.01388348],"genre_scores_gemma":[0.9976309,0.00008597074,0.00004208416,0.0006827594,0.0004016832,0.0000337915,0.00005348589,0.00004410959,0.001025196],"genre_candidate":"empirical","genre_consensus":"empirical","teacher_disagreement_score":0.1227436,"threshold_uncertainty_score":0.9997807,"prediction_status":"machine_predicted_unvalidated"},"machine_scores":{"provisional":true,"baseline":true,"maturity_gate_passed":false,"score_opus":0.08571465106028622,"score_gpt":0.2737931330776615,"score_spread":0.1880784820173753,"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."}}