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This title provides a clear introduction to international taxation and presents its material in a global context, explaining policy, legal issues and planning points central to taxation issues, primarily from the viewpoint of a multinational group of companies. It uses examples and diagrams throughout to aid the reader's understanding and offers more in-­depth material on many important areas of the subject. As well as practitioners who are less familiar with international taxation principles, this title is also used as a core text by many undergraduate and post graduate students studying business degrees. It is also widely used by those studying for the CIOT Advanced Diploma in International Taxation.Business is increasingly carried on a global scale and as such an understanding of how international taxation works is very useful for in house finance teams as well as their advisers. The 9th edition is again fully updated to cover important regulatory and legislative developments, including those in light of the ongoing OECD BEPS project implementation. Other key developments include:Progress towards a global minimum corporate tax rate to curb base erosion and tax competition (Pillar 2), eg OECD implementation framework and UK draft legislationNew crypto asset reporting framework released by OECD.Ongoing impact of Covid-19 on international taxationProgress in relation to tackling tax evasion now that country by country reporting is bedding in. Further developments in European direct taxation including the debt-equity bias reduction allowance (DEBRA) and new Directive to prevent the misuse of shell entities. The updating is done by Lynne Oats, Professor of Taxation and Accounting, University of Exeter Business School, and formerly Deputy Director of the Tax Administration Research. She has managed this project since it's inception.

In 1845 an expedition led by Sir John Franklin vanished in the Canadian Arctic. The enduring obsession with the Franklin mystery, and in particular Inuit information about its fate, is partly due to the ways in which information was circulated in these imperial spaces. This book examines how the Franklins and other explorer families engaged in science, exploration and the exchange of information in the early to mid-19th century. It follows the Franklins from the Arctic to Van Diemen's Land, charting how they worked with intermediaries, imperial humanitarians and scientists, and shows how they used these experiences to claim a moral right to information. Arctic Circles and Imperial Knowledge shows how the indigenous peoples, translators, fur traders, whalers, convicts and sailors who explorer families relied upon for information were both indispensable and inconvenient to the Franklins. It reveals a deep entanglement of polar expedition with British imperialism, and shows how geographical knowledge intertwined with convict policy, humanitarianism, genocide and authority. In these imperial spaces families such as the Franklins negotiated their tenuous authority over knowledge to engage with the politics of truth and question the credibility and trustworthiness of those they sought to silence.

In ancient Greek comedy, nothing is ever 'just a joke'. This book treats jokes with the seriousness they deserve, and shows that far from being mere surface-level phenomena, jokes in Greek comedy are in fact a site of poetic experimentation whose creative force expressly rivals that of serious literature.Focusing on the fragments of authors including Cratinus, Pherecrates, and Archippus alongside the extant plays of Aristophanes, Naomi Scott argues that jokes are critical to comedy's engagement with the language and convention of poetic representation. More than this, she suggests that jokes and poetry share a kind of kinship as two modes of utterance which specifically set out to flout the rules of ordinary speech. Starting with bad puns, and taking in crude slapstick, vulgar innuendo and frivolous absurdism, Jokes in Greek Comedy demonstrates that the apparently inconsequential jokes which pepper the surface of Greek comedy in fact amplify the impossible and defamiliarizing qualities of standard poetic practice, and reveal the fundamental ridiculousness of treating make-believe as a serious endeavour. In this way, jokes form a central part of Greek comedy's contestation of the role of language, and particularly poetic language, in the truthful representation of reality.

'Step-by-step guidance to crack the SQE.' The Commonwealth Lawyer Journal 'Relentlessly practical. all SQE students should invest in this book.' Christina Blacklaws, former President of the Law Society of England and Wales 'An Excellent book. Incredibly useful as a study aid' Sarah Grabham, Head of Bristol Law School (UWE)Skilfully Passing the Solicitors Qualifying Examination (SQE) helps qualified lawyers, aspiring solicitors and students prepare for and pass the exam. From start to finish it provides practical guidance, tips and tools; from choosing a course provider, through to how to be admitted to the Roll of Solicitors.The SQE is heavily based on the Qualified Lawyers Transfer Scheme (QLTS), now abolished, so already an established format. This essential title will help you understand the exam, how to prepare for it and ensure what you learn will also benefit you in practice. Complementing your academic study materials, it provides insight and understanding of what you can expect from doing the SQE. It offers practical solutions around questions and challenges when studying and practising for SQE Part 1 and Part 2, such as:- What strategies will help you with the multiple choice tests? - How do you deal with emotional/vulnerable clients? - What do you do when you cannot answer your client's or the judge's question?- How can you maximise your chances of scoring the highest marks?Skilfully Passing the Solicitors Qualifying Examination (SQE) is an essential textbook for universities, training providers, law firms, businesses and individuals. It teaches you how to explain the law and legal principles in a clear and concise manner which directly links to how you hone your communication skills to deliver a confident performance.

Examines how fannish and feminist modes of cultural consumption, production, and critique are converging and opening up informal spaces for young people to engage with feminism. Adopting an interdisciplinary theoretical framework and bringing together media and communications, feminist cultural studies, sociology, internet studies and fan studies, Hannell locates media fandom at the intersection of the multi-directional and co-constitutive relationship between popular feminisms, popular culture and participatory networked digital cultures. Feminist Fandom functions as an ethnographic account of how feminist identities are constructed, lived and felt through digital fannish spaces on the micro-blogging and social networking platform, Tumblr.

Provides the first critical overview of acting, stardom, and performance in post-war Italian film (1945-54), with special attention to the figure of the non-professional actor, who looms large in neorealist filmmaking. Italian post-war cinema has been widely celebrated by critics and scholars: films such as Bicycle Thieves (De Sica, 1948) and Paisan (Rossellini, 1946) remain globally influential, particularly for their use of non-professional actors. This period of regeneration of Italian cinema initiated the boom in cinemagoing that made cinema an important vector of national and gender identity for audiences.The book addresses the casting, performance, and labour of non-professional actors, particularly children, their cultural and economic value to cinema, and how their use brought ideas of the ordinary into the discourse of stars as extraordinary. Relatedly, O'Rawe discusses critical and press discourses around acting, performance, and stardom, often focused on the 'crisis' of acting connected to the rise of non-professionals and the girls (like Sophia Loren) who found sudden cinematic fame via beauty contests.

With a particular emphasis on definitions, continuities, and change, this edited volume examines the historical role and function of haya' - or feelings of shame, modesty, and honor - in Islamic theology and law, as well as exploring contemporary Muslims' engagements with the concept.Divided into three parts, the book explores various conceptions of haya' and the practises associated with the concept in both Muslim majority and minority context.The contributors reveal how haya' is socially constructed in varying social and cultural contexts. They consider how conceptions of haya' are built and re-produced through processes where the naming, idea, and meanings of haya' shift across different regions.From medieval Islam to the modern day, this book demonstrates that the concept of haya' has undergone profound transformations both temporally and spatially, and furthers our understanding of the human and social mechanisms behind the phenomenon.

We inhabit a world not only full of natural dispositions independent of human design, but also artificial dispositions created by our technological prowess. How do these dispositions, found in automation, computation, and artificial intelligence applications, differ metaphysically from their natural counterparts? This collection investigates artificial dispositions: what they are, the roles they play in artificial systems, and how they impact our understanding of the nature of reality, the structure of minds, and the ethics of emerging technologies. It is divided into four parts covering the following interconnected themes: (i) Artificial and Natural Dispositions, (ii) Artificial Systems and Their Dispositions, (iii) Agency, Mind, and Artificial Dispositions, and (iv) Artificial Moral Dispositions. This is a groundbreaking and thought-provoking resource for any student or scholar of philosophy of science, contemporary metaphysics, applied ethics, philosophy of mind, and philosophy of technology.

Details, and offers vignettes to illustrate, how patriarchy and white supremacy have restricted Black women at work, both historically and currently.Around water coolers and over glasses of wine, Black women come together and process the ways in which their labor is taken for granted and their excellence called into question. Black Women at Work: On Refusal and Recovery makes the direct connection between these contemporary experiences and the long legacy of Black labor exploitation. Through the trafficking and enslavement of Africans, European Americans laid the inhumane foundation of their present-day wealth and privilege and established oppressive labor dynamics for workers that persist to this day. In Black Women at Work, Wendi S. Williams moves the conversation beyond the stubborn audacity of inequity, focusing instead on the powerful history and example of Black women's labor and refusal practices and on the potent role that choice and voice can play in dismantling seemingly impenetrable systems of unfairness. Through the interweaving of personal narratives and social media reflections, Williams crafts a larger narrative of recovery and refusal that articulates a liberatory path toward recovery and reclamation through refusal-a path that will ultimately help to bring us all closer to freedom.

This book analyses the transformation of consumer law and policy in Europe from 4 perspectives: first, the temporal transformation, i.e., changes that can be tracked from the turn of the millennium; secondly, the substantive dimension, i.e., changes in the scope of the rights and remedies provided by consumer law, as well as the underpinning values; thirdly, the institutional dimension, i.e., changes in the role of national courts, national Parliaments, consumer agencies, and consumer organisations; and fourth, the procedural element, i.e., the shift from individual enforcement via courts to enforcement by public regulators, consumer associations, alternative dispute resolution, and the development of collective enforcement exercised by consumer agencies and/or consumer organisations.With contributions by leading consumer law scholars from across Europe, this book is a fascinating account of how consumer law has often been shaped by national as much as European interests.

This is the only book of its kind to explore biblical epics from an LGBT perspective, studying films from the silent era, to the postwar major studio era, to the present day.In spite of restrictive Hollywood censorship regulations, filmmakers throughout history have pushed the boundaries of sex and violence when making religious films. In this unrivaled text, author and educator Richard Lindsay analyzes the relationship between bible-based epics and "camp"-films with overwrought acting, casts of thousands, and exotic sexuality. Lindsay presents the ways in which camp style identifies films as "biblical" in the mainstream imagination, while undermining their traditional religious messages through the inclusion of sexually diverse subtexts.Viewed through this lens, this provocative book explores topics like the Jazz Age excesses of The King of Kings, the pre-code decadence of The Sign of the Cross, the horror movie tropes of The Passion of the Christ, and comparisons between Ben-Hur and the gay male fantasies of 1960s beefcake magazines. Additional content features the history of biblical epics and a comparison of the pious expectations of filmgoers against the real content of the films.

This book provides a broad perspective of the functioning, evolution, and dynamics of the rule of law in Brazil. It stresses not only how the rule of law has developed in the legal system, but also how the political institutions and extra-legal organisations have transformed its foundations. The rule of law is not a simple concept when it comes to defining the political, economic, and legal developments of a country like Brazil. Similar to many other Latin American countries, Brazil is a young democracy struggling with its longstanding extractive institutions and entrenched interests. It features, however, one of Latin America's richest constitutional moments, when civil society actively participated in drafting the most democratic constitution in the country's history. Brazil has since strengthened its institutions and the rule of law, but the road toward consolidating them has been challenged by inequality and the legacies of that authoritarian past. The book explores how Brazilian democracy has dealt with the high levels of social inequality and the authoritarian mindset that still play a big role in its fate, and asks whether the country's democratic achievements and institutional framework are sufficiently strong to enforce the rule of law as an imperative for Brazil's development, especially in times when the country is most in need of them.

Constitutionalism is in crisis. And the crisis unfolds not only on a national or a regional level. It is a global phenomenon: Democracy is no longer on the rise, the Rule of Law appears weakened, political cohesion seems to erode. Human Rights Protection finds itself questioned, International Criminal Law struggles for broad recognition, international trade may have lost some of its appeal. Institutional actors find their authority questioned, established political parties are threatened by ever-changing popular movements. But where to does the charted road lead? How will the "Crisis of Constitutionalism" unfold in the years to come? Nobody knows, of course. But at the same time: Nobody is too keen to make an educated guess either. This volume remedies that. By giving nine eminent scholars in law and political science the opportunity to make their predictions, where the constitutionalist project will stand ten years from now, it creates a forum of deliberation that will not only aim at anticipating the developments in question but at the same time shape academic discourse on constitutionalism alongside it.

This book provides an in-depth analysis of 4 economically significant Asian jurisdictions: Mainland China, India, Hong Kong and Singapore. These jurisdictions have recently either reformed - or are considering reforming - their corporate restructuring laws to promote regimes conducive to restructuring financially distressed, but otherwise economically viable, companies. Mainland China, India, Hong Kong and Singapore continue to adhere to a framework that requires the court's final approval but draw references from Chapter 11 of the Bankruptcy Code 1978 in the United States and/or the schemes of arrangement in the United Kingdom. However, the institutional and market structures are very different in Asia; in particular, Asia has a far higher concentration in shareholdings among listed firms, including holdings by families and the state, and a different composition of creditors. The book explains how, notwithstanding the legal transplantation, corporate restructuring laws in these Asian jurisdictions have adapted and evolved due to the frictions in shareholder-creditor and creditor-creditor relationships, and the role of the state in resolving non-performing loans and financial distress of state-owned enterprises which are listed, or which issue public debt. The study argues that any reforms must go beyond professionalising the insolvency professionals and the judiciary but must be designed to address fundamental issues of corporate governance, bank regulation and enforcing non-bankruptcy rules. It offers invaluable insights for academics and policy makers alike.

New Directions in Print Culture Studies features new methods and approaches to cultural and literary history that draw on periodicals, print culture, and material culture, thus revising and rewriting what we think we know about the aesthetic, cultural, and social history of transnational America. The unifying questions posed and answered in this book are methodological: How can we make material, archival objects meaningful? How can we engage and contest dominant conceptions of aesthetic, historical, and literary periods? How can we present archival material in ways that make it accessible to other scholars and students? What theoretical commitments does a focus on material objects entail? New Directions in Print Culture Studies brings together leading scholars to address the methodological, historical, and theoretical commitments that emerge from studying how periodicals, books, images, and ideas circulated from the 19th century to the present. Reaching beyond national boundaries, the essays in this book focus on the different materials and archives we can use to rewrite literary history in ways that highlight not a canon of "major" literary works, but instead the networks, dialogues, and tensions that define print cultures in various moments and movements.

This is a detailed examination of vigilantism in 1970s American film, from its humble niche beginnings as a response to relaxing censorship laws to its growth into a unique subgenre of its own. Cary Edwards explores the contextual factors leading to this new cycle of films ranging from Joe (1970) and The French Connection (1971) to Dirty Harry (1971) and Taxi Driver (1976), all of which have been challenged by contemporary critics for their gratuitous, copycat-inspiring violence. Yet close analysis of these films reveals a recurring focus on the emerging moral panic of the 1970s, a problematisation of Law and Order's role in contemporary society, and an increasing awareness of the impossibility of American myths of identity.

Breaking with linearity - the ruling narrative model in the Jewish-Christian tradition since the ancient world - many 20th-century European writers adopted circular narrative forms. Juan Luis Toribio Vazquez shows this trend was not a unified nor conscious movement, but rather a series of works arising sporadically in different countries at different times, using a variety of circular structures to express similar concerns and ideas about the world. This study also shows how the renewed understanding of narrative form leading to this circular trend was anticipated by Nietzsche's critiques of truth, knowledge, language and metaphysics, and especially by his related discussions of nihilism and the eternal recurrence.Starting with an analysis of the theory and genealogy of linear narrative, the author charts the emergence of Nietzsche's idea of eternal return, before then turning to the history of the circular narrative trend. This history is explored from its inception, in the works of August Strindberg, Gertrude Stein and Azorín; through its development in the interwar years, by writers such as Raymond Queneau and Vladimir Nabokov; to its full flowering in the work of authors James Joyce or Samuel Beckett, among others; and its later employment by post-war writers, including Alain Robbe-Grillet, Italo Calvino and Maurice Blanchot. Through a series of close readings, the book aims to highlight the various ways in which narrative circularity serves to break with an essentially teleological and theological thinking. Finally, Toribio Vazquez concludes by proposing a new typology of non-linear narratives, which builds on the work of recent narratologists.

Since 2006, leading opera companies have beamed their shows to thousands of cinema screens all over the world - live. 'Opera cinema' is the most successful marriage of this elaborate, esoteric art form and the silver screen. In the twenty-first century, more people watch opera on cinema screens than the stage. But what is different about watching Massenet at the multiplex, compared to a traditional stage performance? Is opera cinema a new, hybrid art form in its own right, or merely a new way of engaging with an old one? Is it bringing new opera fans into the fold? Is there a danger it could one day eclipse the stage altogether? This book deals with these questions by charting the history of opera transmissions, exploring how digital media changes our relationship with culture and inviting a group of 'opera virgins' to give their impressions on this developing cultural experience.

In Pentecostal Insight in a Segregated U.S. City, Frederick Klaits compares how members of one majority white and two African American churches in Buffalo, New York receive knowledge from God about their own and others' life circumstances. In the Pentecostal Christian faith, believers say that they acquire divinely inspired insights by developing a "relationship with God." But what makes these insights appear necessary? This book offers a novel approach to this question, arguing that the inspirations believers receive from God lead them to take critical stances on what they regard as ordinary understandings of space, time, care, and personal value. Using a shared Pentecostal language, believers occupying different positions within racial, class, and gender formations reflect in divergent ways on God's designs. In the process, they engage critically with late liberal imaginaries of eventfulness and vitality to envision possibilities of life in a highly unequal society. This text incorporates commentaries on Klaits' ethnography by LaShekia Chatman and Michael Richbart, junior scholars who have also studied and been part of Pentecostal communities in Buffalo.

Recently, scholarship has paid increasing attention to the Soviet dissident movement that emerged in the mid-20th century; but what, Petr A. Druzhinin asks, happened to those academics who did not form part of this circle? Through its intimate portrayal of the persecution of non-dissident literary scholar Konstantin Azadovsky, The Soviet Suppression of Academia sheds new light on the relationship between power and culture in Soviet Russia. Based on rare access to KGB materials and other sources, this book traces Azadovsky's persecution from the 1960s, when he refused to become a KGB informant, to his arrest on trumped-up drug charges and imprisonment in a labour camp in the 1980s, to his struggle for rehabilitation through the early 1990s. Here, for the first time in English, one of the KGB's secret operations against a prominent intellectual is revealed in full, horrific detail. By telling the fascinating story of an individual's struggle with the powerful state machine, this book provides much-needed insight into the experience of life under KGB monitoring and repression and adds nuance to ongoing debates about the relationship between Soviet intellectuals and the state.

Most living forms in nature display various cognitive abilities in their behaviour. However, except for humans, no other animal builds fires and wheels, navigates with maps and tells stories to other conspecifics. We can witness this unique feature of the human mind in almost everything humans do, such as painting, singing and cooking; there is an underlying sense of unity in the generative part of these systems despite wide differences in what they are about.This book introduces, defends and develops a novel philosophical approach to the study of the generative mind. Nirmalangshu Mukherji argues for a single, species-specific generative principle that accounts for the human ability to combine symbolic forms without bound in each domain that falls under the generative mind.

The Distance of Irish Modernism interrogates the paradox through which Irish modernist fictions have become containers for national and transnational histories while such texts are often oblique and perverse in terms of their times and geographies. John Greaney explores this paradox to launch a metacritical study of the modes of inquiry used to define Irish modernism in the 21st century. Focused on works by Samuel Beckett, Elizabeth Bowen, John McGahern, Flann O'Brien and Kate O'Brien, this book analyses how and if the complex representational strategies of modernist fictions provide a window on historical events and realities. Greaney deploys close reading, formal analysis, narratology and philosophical accounts of literature alongside historicist and materialist approaches, as well as postcolonial and world literature paradigms, to examine how modernist texts engage the cultural memories they supposedly transmit. Emphasizing the proximities and the distances between modernist aesthetic practice and the history of modernity in Ireland and beyond, this book enables a new model for narrating Irish modernism.

Colonialism and the Jews in German History brings together new and path-breaking studies on the historical relationship between colonialism and the Jews in Germany. The book considers the mutual influences on the situation of the Jews in Germany, including attitudes towards Jews and anti-Semitism but also Jewish self-conceptions, and the ideology and politics of German colonialism. The contributors discuss the ways in which colonial ideology and practice have affected the position of the Jews in Germany, and the relationship between anti-Semitism and colonial racism. In doing so, the volume introduces German colonialism as a relevant context for German-Jewish history, and it expands the perspective on German colonial history significantly by considering Jews both as distinct objects and also as agents within the field of German colonialism. The volume includes studies on the pre-colonial era, the phase of active German colonialism since the 1880s, and the time after Germany lost its colonies in the First World War. All these studies testify to the fact that German-Jewish history takes on additional significance if seen as part of a global history of collective relationships.

Through expert guidance on understanding, interpreting, and writing about Shakespeare's language, this book makes The Winter's Tale accessible and exciting for students. It demonstrates that careful attention to Shakespeare's complex dramatic language can clarify the structure and concerns of the play, as well as provide deep and satisfying engagement with the social, political and ethical questions Shakespeare raises. Each chapter features a 'Writing Matters' section designed to connect analysis of Shakespeare's language to students' development of their own writing strategies. The book examines topics in the play such as tragicomic genre; women's assertion of social and political agency; obedience and resistance to rulers; the virtues and risks of following festivity, and disputes over the proper forms of religious devotion.

Central to Niccolò Machiavelli's writing is the argument that a successful state is one that prefers to lose with its own arms (arma propriis) than to win with the arms of others (arma alienis). This book sheds light on Machiavelli's critiques of military force and provides an important reinterpretation of his military theory. Sean Erwin argues that the distinction between arma propriis and arma alienis poses a central problem to Machiavelli's case for why modern political institutions offer modes of political existence that ancient ones did not. Starting from the influence of Lucretius and Aelianus Tacticus on the Dell'arte della guerra, Erwin examines Machiavelli's criticism of mercenary, auxiliary, and mixed forces. Giving due consideration to an overlooked conceptual distinction in Machiavelli studies, this book is a valuable and original contribution to the field.