Bibliographic record
Abstract
The concept ‘place of effective management’ (POEM) is used in many States around the world. Yet the meaning of this concept remains somewhat ambiguous. It is important to establish where an entity is effectively managed, since many States still use The POEM as one of the criteria to determine residence in terms of their domestic legislation. Furthermore, The POEM is still relevant in several double taxation treaties (DTTs), even after the changes to the OECD Model Tax Convention and the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting. This article critically analyses significant judgments from the United Kingdom, South Africa, Canada and Australia. From these judgments, a set of guidelines to determine an entity’s POEM is compiled. These guidelines may assist both taxpayers and tax administrators in the application of the concept of the POEM to a new set of facts. Place of effective management, Central management and control, Residence, Taxation. Company, Board of directors, Trust, Trustees
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 imitationNot 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.
Distilled classifier scores by category (both heads)
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.169 | 0.287 |
| Meta-epidemiology (narrow) | 0.001 | 0.002 |
| Meta-epidemiology (broad) | 0.002 | 0.001 |
| Bibliometrics | 0.014 | 0.010 |
| Science and technology studies | 0.015 | 0.044 |
| Scholarly communication | 0.027 | 0.038 |
| Open science | 0.008 | 0.011 |
| Research integrity | 0.021 | 0.014 |
| Insufficient payload (model declined to judge) | 0.004 | 0.001 |
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.
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 source (direct Gemma or distilled Codex), 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".