Bibliographic record
Abstract
Abstract This chapter illustrates the emerging consensus on value creation in international tax law. It begins with a brief review of the emergence of value creation as a part of the lexicon of international taxation, examining its quick take-up and causes for intrigue. The chapter then examines three features that simultaneously make value creation an intuitively compelling concept yet ultimately render it an incomplete tax principle, namely that in tax terms, value is a legislated construct rather than a science; that value is inconsistently identifiable and quantifiable; and that value and its causes of origin often defy geo-location, even though this is the express purpose of using the term in the first place. These features all point to interesting problems of tax cooperation that will almost certainly remain unresolved in the current iteration of global tax policymaking. The chapter therefore concludes that the concept of value creation is likely to continue to intrigue and frustrate scholars while serving as a useful rhetorical flourish for advocates of various policy preferences across the worldwide tax community.
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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 | 0.017 | 0.015 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.001 | 0.001 |
| Bibliometrics | 0.003 | 0.004 |
| Science and technology studies | 0.005 | 0.034 |
| Scholarly communication | 0.019 | 0.022 |
| Open science | 0.002 | 0.008 |
| Research integrity | 0.008 | 0.017 |
| Insufficient payload (model declined to judge) | 0.007 | 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".