Bibliographic record
Abstract
From the earliest days of tax treaties, it was agreed generally that business profits earned by a resident of one state in another state would be taxed in the source state only if the resident earned those profits through a permanent establishment (PE) in that source state. Until the 1970s, a PE generally meant an actual, physical, establishment. Starting in 1969, the United Nations started to consider the possibility of expanding the "permanent establishment" concept to include the mere provision of services for a certain length of time. In most (although not all) cases, treaties that contain such an expansion require that the services be provided in respect of a project or a "connected project." This article attempts to analyze the history, purpose, and meaning of the term "connected project." The article concludes that the connected project requirement serves two separate but related purposes: (1) to limit a source state's right to tax profits earned from the provision of services, and (2) to prevent foreign residents from splitting up and shortening service contracts artificially so as to avoid providing services for the period of time required under the treaty to create a PE.
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 distilled prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. Learned from the 10,348 direct Codex labels and 10,348 direct Gemma labels. Candidate is the union of thresholded teacher heads; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels or direct frontier model labels.
Codex and Gemma teacher scores by category
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.001 | 0.000 |
| Meta-epidemiology (narrow) | 0.001 | 0.001 |
| Meta-epidemiology (broad) | 0.001 | 0.000 |
| Bibliometrics | 0.001 | 0.001 |
| Science and technology studies | 0.000 | 0.000 |
| Scholarly communication | 0.003 | 0.001 |
| Open science | 0.004 | 0.000 |
| Research integrity | 0.001 | 0.003 |
| Insufficient payload (model declined to judge) | 0.000 | 0.000 |
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.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one teacher head, not a consensus.
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".