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Record W1601800967

Company Taxation, State Aid and Fundamental Freedoms: Is the Next Step Enhanced Cooperation?

2005· article· en· W1601800967 on OpenAlexaff
Martha O’Brien

Bibliographic record

VenueSSRN Electronic Journal · 2005
Typearticle
Languageen
FieldBusiness, Management and Accounting
TopicTaxation and Legal Issues
Canadian institutionsUniversity of Victoria
Fundersnot available
KeywordsUnanimityLaw and economicsState (computer science)Tax lawDirect taxTreatyDouble taxationBusinessSovereigntyEconomicsPolitical sciencePublic economicsLaw
DOInot available

Abstract

fetched live from OpenAlex

In recent years the European Court of Justice has, with increasing frequency, ruled that national taxation laws are incompatible with fundamental freedoms protected by the EC Treaty. The Commission has also focused its state aid review more intensively on direct tax incentives to business. This article reviews the current state of evolution of these two aspects of negative European tax law integration, showing how the principles of free movement and fair competition have combined to limit significantly the fiscal sovereignty of the Member States, but without easing the tax compliance burden on businesses with operations in more than one Member State. With the Constitutional Treaty confirming the requirement of unanimity for fiscal harmonisation measures, the enhanced co-operation process has been proposed as the best chance for further alignment of Member State tax laws, and specifically harmonisation of the corporate tax base.

Fetched live from OpenAlex and de-inverted. Abstracts are not stored in this database: the inverted indexes are 8.6 GB of the frame’s 9.3 GB of text, and the host has 13 GB free.

How this classification was reachedexpand

Full frame machine prediction

Teacher imitation

Not calibrated prevalence, not ground truth. Human validation pending. The Gemma side is a direct model label for every work in the frame, read from the title-only record. The Codex side is a classifier learned from the 10,348 direct Codex labels and calibrated to design-weighted sample rates; fields without enough sample support carry no Codex call. Candidate is the union of the two sides; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels.

metaresearch head score (Codex)0.009
metaresearch head score (Gemma)0.010
Version: metacan-v3-hybrid-931329e0061cValidation status: machine_predicted_unvalidated
Candidate categoriesnone
Consensus categoriesnone
DomainCandidate signal: none · Consensus signal: none
Study designCandidate signal: Not applicable · Consensus signal: none
GenreCandidate signal: Empirical · Consensus signal: none
Teacher disagreement score0.015
Threshold uncertainty score0.046

Distilled classifier scores by category (both heads)

CategoryCodexGemma
Metaresearch0.0090.010
Meta-epidemiology (narrow)0.0000.000
Meta-epidemiology (broad)0.0010.001
Bibliometrics0.0010.002
Science and technology studies0.0030.018
Scholarly communication0.0150.016
Open science0.0010.008
Research integrity0.0070.007
Insufficient payload (model declined to judge)0.0070.001

Machine scores (provisional)

The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.

Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.

Opus teacher head0.011
GPT teacher head0.231
Teacher spread0.220 · how far apart the two teachers sit on this one work
Validation statusscore_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from it

Classification

machine, unvalidated

Machine predicted; a candidate call from one source (direct Gemma or distilled Codex), not a consensus.

The models applied no category: nothing in the taxonomy fit this work.
Study designNot applicable
Domainnot available
GenreEmpirical

How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".

Quick stats

Citations9
Published2005
Admission routes1
Has abstractyes

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