{"id":"W4390292084","doi":"10.59403/z7ga73","title":"Constructive Permanent Establishments: Canadian Comments on the Zimmer Case","year":2010,"lang":"en","type":"article","venue":"International Transfer Pricing Journal","topic":"Taxation and Legal Issues","field":"Business, Management and Accounting","cited_by":1,"is_retracted":false,"has_abstract":true,"ca_institutions":"","funders":"","keywords":"Supreme court; Political science; Law; Constructive; Transfer pricing; Multinational corporation","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":"codex-gemma-dda1882f352a","candidate_categories":["insufficient_payload"],"consensus_categories":[],"category_scores_codex":[0.0003518256,0.0001263167,0.00008415148,0.000319265,0.0004841338,0.0008270884,0.0003094567,0.00004353932,0.003183193],"category_scores_gemma":[0.00010016,0.00008753741,0.00007247797,0.0001254853,0.00005983462,0.0007660645,0.00001741405,0.0006305688,0.0002179864],"about_ca_system_candidate":false,"about_ca_system_consensus":false,"about_ca_system_score_codex":0.0000772327,"about_ca_system_score_gemma":0.00004764277,"about_ca_topic_candidate":true,"about_ca_topic_consensus":true,"about_ca_topic_score_codex":0.0344466,"about_ca_topic_score_gemma":0.02698665,"domain_scores_codex":[0.999073,0.00001388635,0.0002298753,0.0001270905,0.0003495757,0.0002065696],"domain_scores_gemma":[0.9994506,0.00005965995,0.00006802172,0.00009972363,0.0002798878,0.00004208265],"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":[0.0001159492,0.0002807148,0.05366907,0.00001798386,0.0004582969,0.003108335,0.002234172,0.0002047323,0.002036794,0.8845569,0.03490197,0.01841509],"study_design_scores_gemma":[0.001154022,0.00001530644,0.01035653,0.00007749955,0.00004959334,0.00257016,0.001763831,0.001174219,0.000344728,0.002467333,0.9797359,0.0002908845],"study_design_candidate":"not_applicable","study_design_consensus":null,"genre_codex":"empirical","genre_gemma":"empirical","genre_scores_codex":[0.8252357,0.000006205095,0.0004685205,0.02136819,0.004833503,0.0001545549,0.00001185239,0.00002583333,0.1478957],"genre_scores_gemma":[0.9865112,0.000003134574,0.00005820053,0.01130317,0.001831674,0.00000541689,0.000009691007,0.00001428662,0.0002631775],"genre_candidate":"empirical","genre_consensus":"empirical","teacher_disagreement_score":0.9448339,"threshold_uncertainty_score":0.997728,"prediction_status":"machine_predicted_unvalidated"},"machine_scores":{"provisional":true,"baseline":true,"maturity_gate_passed":false,"score_opus":0.01779332320423296,"score_gpt":0.2402548100851591,"score_spread":0.2224614868809261,"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."}}