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Record W4396683877 · doi:10.59403/3g63k10009

Chapter 9 – Art. 4(2) of the OECD Model Convention: Practice and Case Law

2010· book-chapter· en· W4396683877 on OpenAlexaboutno aff
Ed Stuart

Bibliographic record

VenueEC and international tax law series. · 2010
Typebook-chapter
Languageen
FieldBusiness, Management and Accounting
TopicTaxation and Legal Issues
Canadian institutionsnot available
Fundersnot available
KeywordsConventionLawPolitical science

Abstract

fetched live from OpenAlex

Why this book? This book begins with an overview of residence of individuals in private international law, with a particular emphasis on general principles on residence and conflict of law rules. It then examines issues raised by residence of individuals in EC (non-tax) law. Individual country surveys provide in-depth analyses from a national viewpoint. The following countries are discussed: Australia, Austria, Belgium, Canada, France, Germany, Italy, Japan, Netherlands, Spain, Switzerland and United Kingdom. This book is essential reading for all those dealing with issues of taxation of individuals in an international context. Downloads Sample excerpt, including table of contents This book is part of the EC and International Tax Law Series View other titles in the series Editor(s) Guglielmo Maisto Contributors Asatsuma Akiyuki, John Avery Jones, Philip Baker, Aagje Bellens, Kim Brooks, Veronika Daurer, Luc De Broe, Michael Dirkis, Stefano Dorigo, Augusto Fantozzi, James J. Fawcett, Anna Gunn, Jean Pierre Le Gall, Marika Lemos, Nicolas Message, Angelo Nikolakakis, Mercedes Nuñez Grañon, Thierry Obrist, Roland A. Pfister, Alexander Rust, Jacques Sasseville, Jonathan Schwarz, María Teresa Soler Roch, Ed Stuart and Jan Wouters.

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)0.003
metaresearch head score (Gemma)0.007
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: Other · Consensus signal: Other
Teacher disagreement score0.025
Threshold uncertainty score0.085

Distilled classifier scores by category (both heads)

CategoryCodexGemma
Metaresearch0.0030.007
Meta-epidemiology (narrow)0.0010.000
Meta-epidemiology (broad)0.0000.001
Bibliometrics0.0020.003
Science and technology studies0.0030.006
Scholarly communication0.0100.005
Open science0.0010.002
Research integrity0.0050.005
Insufficient payload (model declined to judge)0.0250.012

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 head0.020
GPT teacher head0.237
Teacher spread0.218 · 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
GenreOther

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

Citations3
Published2010
Admission routes1
Has abstractyes

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Same venueEC and international tax law series.Same topicTaxation and Legal IssuesFrench-language works237,207