{"id":"W4389431387","doi":"10.18601/16926722.n24.08","title":"Back-to-Back withholding loan rules and their anti-treaty shopping effect in Canada","year":2023,"lang":"es","type":"article","venue":"Revista de Derecho Fiscal","topic":"Corporate Taxation and Avoidance","field":"Business, Management and Accounting","cited_by":0,"is_retracted":false,"has_abstract":true,"ca_institutions":"York University","funders":"","keywords":"Humanities; Political science; Philosophy","routes":{"ca_aff":true,"ca_fund":false,"ca_venue":false,"about_ca":true,"invisible_to_affiliation_only":false},"retraction":null,"screen":null,"direct_labels":[],"prediction":{"model_version":"metacan-v3-hybrid-931329e0061c","candidate_categories":[],"consensus_categories":[],"category_scores_codex":[0.001425745,0.0002439817,0.0006636989,0.001383686,0.007475064,0.006114413,0.001611957,0.001506572,0.01191982],"category_scores_gemma":[0.008222749,0.0003008403,0.0005007297,0.002483931,0.003064162,0.0009941601,0.001802296,0.002209328,0.0004114717],"about_ca_system_candidate":false,"about_ca_system_consensus":false,"about_ca_system_score_codex":0.0786671,"about_ca_system_score_gemma":0.1301788,"about_ca_topic_candidate":true,"about_ca_topic_consensus":true,"about_ca_topic_score_codex":0.9960299,"about_ca_topic_score_gemma":0.9982249,"domain_scores_codex":[0.9971415,0.0002151889,0.00005900305,0.0001724563,0.0008493559,0.001562488],"domain_scores_gemma":[0.9924165,0.00120266,0.0008467116,0.000247331,0.003103091,0.002183589],"domain_codex":null,"domain_gemma":null,"domain_candidate":null,"domain_consensus":null,"study_design_codex":"observational","study_design_gemma":"not_applicable","study_design_scores_codex":[0.001216375,0.0007364064,0.527466,0.0002716186,0.0003390256,0.001580574,0.01102094,0.008463582,0.001778727,0.253873,0.0852664,0.1079873],"study_design_scores_gemma":[0.0003086004,0.0002715431,0.7900149,0.0003411899,0.0004896038,0.0001867595,0.02767939,0.01058521,0.001813952,0.01386546,0.1542343,0.0002090401],"study_design_candidate":"not_applicable","study_design_consensus":null,"genre_codex":"empirical","genre_gemma":"empirical","genre_scores_codex":[0.8642647,0.001910698,0.0004372811,0.01376219,0.00009085375,0.000103155,0.001523035,0.00006181693,0.1178463],"genre_scores_gemma":[0.9761376,0.0007349144,0.0001217746,0.0008616312,0.00001581465,0.0000104048,0.0001985165,0.00001702041,0.02190238],"genre_candidate":"empirical","genre_consensus":"empirical","teacher_disagreement_score":0.0786671,"threshold_uncertainty_score":0.5707725,"prediction_status":"machine_predicted_unvalidated"},"machine_scores":{"provisional":true,"baseline":true,"maturity_gate_passed":false,"score_opus":0.01605930771182163,"score_gpt":0.2242874523535216,"score_spread":0.2082281446417,"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."}}