Corporate income tax deductibility of interest after the implementation of ATAD Over the past few years, the media and the general public have focused heavily on tax avoidance of large corporations such as Apple and Google. OECD (2012) issued BEPS report in which it described tax base erosion and profit shifting methods. The tools described therein include also excessive use of foreign capital and the associated tax shield. The regulations and recommendations as set out in the BEPS report were implemented in the European ATAD Directive in 2016. This thesis focuses on the limitation of deductibility of interest, especially from the perspective of the analysis of the Czech implementation with regard to the regulation set out in the BEPS report and the ATAD Directive and fulfillment of their objectives. The main goal of the thesis is to assess the fulfillment of the objectives set out in the BEPS report and in the ATAD Directive within their Czech transposition, to analyze the Czech regulation and to point out possible shortcomings of the Czech regulation and problems related to the implementation of new rules limiting the deductibility of borrowing costs. The thesis is divided into four chapters. The first chapter focuses on the problematics of interest and other borrowing costs deductibility,...

Statute of limitations of a plea concerning the voidability of a will as part of inheritance proceedings Abstract This thesis deals with the possible statute of limitations of a plea concerning the voidability of a will as part of inheritance proceedings or, as the case may be, identification of the conditions under which such statute of limitations is possible, since this becomes a current issue in a situation when there is an increase in the number of drawn up wills and length of inheritance proceedings. The thesis describes related legal institutions, including an analysis of related case law, and is applied to a specific case, whereas the author concludes that the statute of limitations of a plea concerning the voidability of a will as part of inheritance proceedings is possible, when the limitation period commences on the day that a disinherited descendant provably learned of the existence of a will and not the drawing up of a will or death of the testate. The author's conclusion, to a considerable extent, contradicts the very latest judgement of the Supreme Court of the Czech Republic which is also analysed in the thesis. From the author's point of view, this judgement is a strongly law-making decision which is not entirely consistent with the previous decision-making of the Supreme Court of the Czech...

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During the latest decades, there have been indications that the limiting nutrient are changeable in the Bothnian Sea. The current national regulations for wastewater treatment plants which have coastland towards the Gulf of Bothnia have no regulations regarding nitrogen purification, as these basins traditionally has been seen to have phosphorus-limited conditions. The aim of this study was to investigate how the temporal change of phosphorus and nitrogen has developed during the years 1991-2021 in the Bothnian Sea and if there were any differences between coastal and offshore stations. The ultimate goal was to give an overview of the nutrient situation and develop a guideline whether the current regulations for wastewater treatment plants are sufficient. Three coastal and two offshore stations were studied at the depth 0-10 m by investigating data from national monitoring programs, using trend analysis and comparison of means. The result showed that phosphorus is increasing in all the sampling stations. Consequently, the limited nutrient has evolved towards being more nitrogen-limited. The nitrogen load has instead been larger at the coastal compared to the offshore stations, especially for locations affected by river inlets. However, the conclusion according to this study is that the current regulations are sufficiently. This is due to the more recent shift towards nitrogen-limited conditions at the stations affected by river inlets and the high contribution with phosphorus-rich water from the Baltic Proper, as at the same time wastewater treatment plants is not the greatest contributor to the nitrogen load in the Bothnian Sea.

Newspapers often report on the violation of learners’ rights. Many of these violations and critical incidents are related to the right to freedom of expression, which is internationally viewed as a core right in a democracy. My inquiry focused on grade 11 learners’ understanding of the right to freedom of expression. It is important to understand learners’ understanding of the right to freedom of expression, as they are the leaders of tomorrow and the right to freedom of expression is central to the survival of democracy. This inquiry was informed by an interpretivist paradigm. Atlas.ti™ was used to systematically analyse the data and categorise it into three hermeneutic units. This computer-aided qualitative data analysis software (CAQDAS) tool facilitated the process of analysis and enhanced the validity of the research. During the inductive process of analysis two patterns crystallised, viz. the absolutising of the right to freedom of expression by some learners and the lack of skills to implement the limitation to the right to freedom of expression in schools. The main findings indicated that some learners did not have knowledge regarding the right to freedom of expression, although most learners were aware that they could speak their minds under this right. Furthermore, learners didn’t seem to know how to exercise the right to freedom of expression. One of the factors disrupting the implementation of the right to freedom of expression in schools is the perpetuation of an authoritarian culture in schools. Theoretical and practical recommendations are suggested and avenues for future research are identified. / Thesis (PhD (Education Management))--University of Pretoria, 2005. / Education Management and Policy Studies / unrestricted

Magister Scientiae Dentium - MSc(Dent) / The objective of the study was to compare pain and functional limitation of temporomandibular myalgia patients, before and after low-level-laser treatment (LLLT).This was a prospective, randomized, placebo-controlled, triple-blinded clinical study. Patients diagnosed with temporomandibular myalgia according to the DC/TMD protocol were recruited from the TMD clinic of the Mitchell’s Plain Oral Health Centre. Treatment was performed using diode laser (Sirolaser, Dentsply Sirona). The 3 regions of the masseter and temporalis muscles were treated bilaterally with a dose of 8J/cm2 per region. Pain and function were assessed using pain-free opening, numeric rating scales (NRS), Characteristic Pain Intensity Scores (CPIS), Interference Score (IS), and Jaw Functional Limitation Scale (JFLS) at the first and last LLLT and at 4-week recall (intervals 1, 2, 3). Statistical analysis was done by means of explorative categorical principal and multivariate interdependent analysis.

© 2019 The Authors. New Phytologist © 2019 New Phytologist Trust The role of pollination in the success of invasive plants needs to be understood because invasives have substantial effects on species interactions and ecosystem functions. Previous research has shown both that reproduction of invasive plants is often pollen limited and that invasive plants can have high seed production, motivating the questions: How do invasive populations maintain reproductive success in spite of pollen limitation? What species traits moderate pollen limitation for invaders? We conducted a phylogenetic meta-analysis with 68 invasive, 50 introduced noninvasive and 1931 native plant populations, across 1249 species. We found that invasive populations with generalist pollination or pollinator dependence were less pollen limited than natives, but invasives and introduced noninvasives did not differ. Invasive species produced 3× fewer ovules/flower and >250× more flowers per plant, compared with their native relatives. While these traits were negatively correlated, consistent with a tradeoff, this did not differ with invasion status. Invasive plants that produce many flowers and have floral generalisation are able to compensate for or avoid pollen limitation, potentially helping to explain the invaders’ reproductive successes.

Syftet med denna studie är att undersöka hur den fria leken på svenska förskolor är begränsad för att gå i linje med förskolans uppdrag som det är presenterat i läroplanen. För att uppnå detta har vi intervjuat sju förskollärare på två svenska förskolor angående deras syn på den fria leken och hur den är begränsad. Det insamlade materialet är sedan analyserat med hjälp av Michel Foucaults teorier samt Jennifer M. Gores mikro-praktiker om makt för att synliggöra hur den fria leken är begränsad och varför. De tre centrala teman som presenteras i läroplanen är: säkerhet och välmående; grundläggande och demokratiska värderingar samt lärande, utveckling och livslångt lärande. En hierarki bland dessa teman blev uppenbar där säkerhet ses som viktigast följt av de grundläggande och demokratiska värdena och sist lärande, utveckling och livslångt lärande. Vi fann även att förskollärarna hellre reglerar leken så att den stämmer överens med läroplanen än att bryta den samt att läroplanens tolkningsbarhet leder till olika strategier bland förskollärarna för att uppnå deras önskade resultat.

Natural microbial communities are the ultimate drivers of change in any ecosystem. Through chemical contamination of natural environments, these communities are exposed to many different types of chemical stressors; however, research on whole genome responses to this contaminant stress is limited. This research examined the stress response of a common soil bacterium, <i>Pseudomonas aeruginosa</i>, to a common environmental pollutant, pentachlorophenol (PCP). In the first part of the research, it was revealed that nutrient-limited <i>P. aeruginosa</i> is able to respond to PCP with minimal physiological damage due to the upregulation of multidrug efflux pumps. Further study of this PCP-mediated induction of efflux pumps revealed a simultaneous increase in antibiotic resistance. It was discovered that the resistance nodulation-cell division (RND) efflux pump, MexAB-OprM, in particular is responsible for the PCP-induced increase in antibiotic resistance. Both whole cell physiological indicators and whole genome analysis were used to examine the stress response of <i>P. aeruginosa</i> to PCP. Cells were grown in a chemostat at a low growth rate to simulate nutrient-limiting growth in the natural environment. Whole cell acetate uptake rates (WAUR) and viable cell counts as colony forming units (CFU) were determined as cells were exposed to increasing concentration of PCP. At the same time, changes in gene expression were examined by Affymetrix microarray technology. Results showed little change in whole-cell physiology, with no difference in WAUR and only a slight reduction in CFU. However, the microarrays revealed that over 100 genes either increased or decreased expression greater than two-fold due to the PCP exposure. In particular, multiple multidrug efflux genes were upregulated in response to the PCP. The results were validated by real time reverse transcription polymerase chain reaction (RT-PCR) for one of these genes. Further analysis of the effects of MexAB-OprM showed that this particular efflux pump is essential for the response of <i>P. aeruginosa</i> to the toxin PCP. Induction of multidrug efflux pumps is responsible for the development of antibiotic resistance in strains of <i>P. aeruginosa</i>. Therefore, it was investigated whether PCP might induce resistance to a variety of antibiotics. The research was further extended to examine the effect of a variety of organic contaminants on MexAB-OprM efflux and antibiotic resistance development. PCP, 2,4-dinitrophenol, benzoate and Roundup® all induced antibiotic resistance. However, although MexAB-OprM is required for optimal growth in the presence of all chemicals, this particular efflux pump is only involved in increased resistance with PCP. This was confirmed using RT-PCR as <i>mexB</i> expression was induced by PCP, but not by the other three chemicals. A long term generational study on the effects of PCP did not result in a stable antibiotic-resistant phenotype; however, RT-PCR showed that <i>mexB</i> induction is a direct result of PCP exposure and can be reversed by removal of PCP. Together, these results demonstrate the necessity to understand functional responses to contaminant stress. Discovery of direct induction of multidrug efflux pumps and the resulting increase in antibiotic resistance has significant implications for environmental microbiology and public health. This research suggests that organic contamination may result in antibiotic resistance and that antibiotic resistant strains may have a survival advantage in contaminated environments. / Ph. D.

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