{"id":"W7146448693","doi":"","title":"国際租税法における受益者要件 (beneficial ownership) : OECDモデル租税条約第一二条 (ロイヤルティ) を検討して","year":2025,"lang":"ja","type":"article","venue":"Institutional Repositories DataBase (IRDB)","topic":"Taxation and Legal Issues","field":"Business, Management and Accounting","cited_by":0,"is_retracted":false,"has_abstract":true,"ca_institutions":"","funders":"","keywords":"Identification (biology); Process (computing); Work (physics)","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":[0.004164191,0.0002342088,0.0002272495,0.001310732,0.002047689,0.006554592,0.000502352,0.0009988962,0.01281046],"category_scores_gemma":[0.01325131,0.0003014492,0.0002851472,0.001129315,0.007698623,0.007550316,0.002204415,0.00142755,0.0007579055],"about_ca_system_candidate":false,"about_ca_system_consensus":false,"about_ca_system_score_codex":0.0030883,"about_ca_system_score_gemma":0.004213061,"about_ca_topic_candidate":false,"about_ca_topic_consensus":false,"about_ca_topic_score_codex":0.00549471,"about_ca_topic_score_gemma":0.006922062,"domain_scores_codex":[0.997133,0.001070244,0.0001912664,0.0003770191,0.0008549397,0.0003735367],"domain_scores_gemma":[0.9902197,0.004812722,0.001392014,0.0008321471,0.001966846,0.0007766331],"domain_codex":null,"domain_gemma":null,"domain_candidate":null,"domain_consensus":null,"study_design_codex":"theoretical_or_conceptual","study_design_gemma":"theoretical_or_conceptual","study_design_scores_codex":[0.00005355303,0.0000798751,0.01768808,0.00008504769,0.00002835814,0.0002207219,0.004983751,0.0004449927,0.0007232563,0.9363049,0.0031367,0.03625078],"study_design_scores_gemma":[0.00007015432,0.000164396,0.0551603,0.0003229691,0.0002006463,0.0007313534,0.01892478,0.002740687,0.004526684,0.8314803,0.08561581,0.00006203284],"study_design_candidate":"theoretical_or_conceptual","study_design_consensus":"theoretical_or_conceptual","genre_codex":"other","genre_gemma":"empirical","genre_scores_codex":[0.265686,0.0009482193,0.02047606,0.01206117,0.0001991726,0.0001486517,0.0002582172,0.00007973727,0.7001427],"genre_scores_gemma":[0.9831097,0.0002951482,0.003225905,0.0003842179,0.00006412499,0.00004748356,0.00004229196,0.00001498796,0.01281606],"genre_candidate":"empirical","genre_consensus":null,"teacher_disagreement_score":0.01281046,"threshold_uncertainty_score":0.04285526,"prediction_status":"machine_predicted_unvalidated"},"machine_scores":{"provisional":true,"baseline":true,"maturity_gate_passed":false,"score_opus":0.0182346883903794,"score_gpt":0.2598323617622119,"score_spread":0.2415976733718325,"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."}}