Made available in DSpace on 2016-04-26T20:21:46Z (GMT). No. of bitstreams: 1 Lia Barsi Drezza.pdf: 1150610 bytes, checksum: 85917f53e22e468577ce238460179f2c (MD5) Previous issue date: 2013-06-03 / This study assesses the impact of the normative statement contained in Articles 24 and 25 of Law No. 12.249/2010 Brazil s "thin capitalization rules" in view of a series of other laws currently in effect that regulate the same issues, namely, the remittance of interest abroad by entities affiliated with enterprises headquartered in tax havens or in countries featuring low-tax regimes. The analysis seeks to highlight the conflicts that can arise from regulation by different laws of the same legal facts, as a means to prevent the occurrence of double taxation by the tax authorities / O presente estudo busca analisar a eficácia social do enunciado normativo contido nos artigos 24 e 25 da Lei nº 12.249/2010, chamado de regras de subcapitalização , tendo em vista a existência, no sistema atualmente vigente, de um conjunto de outros enunciados que acabam por regular o mesmo fato jurídico, qual seja, a remessa de juros ao exterior, para pessoas jurídicas vinculadas, sediadas em países com tributação favorecida ou com regime fiscal privilegiado. A partir dessa análise, buscou-se evidenciar os conflitos que podem surgir da regulamentação, por diferentes proposições normativas, de fatos jurídicos idênticos, como forma de evitar a ocorrência de uma dupla tributação por parte dos órgãos fiscais

A new paradigm is slowly making its way into society, affecting our material practice as designers. Materials selection in design and product development has for a long time been dominated by a purely technical approach, mainly focusing on properties and performance. With the increasing evidence of climate change, waste and pollution, environmental effects, we are slowly realizing that unsustainable consumption of materials is no longer an alternative. Previous studies of material practices, both within design educations and the design profession, has primarily dealt with the development of material related methods. This thesis has focused on gaining an in-depth understanding of material practices within design processes, in order to develop a pedagogical framework that facilitates the development of reflective material practices in design education. There are four primary aims of the research presented in this licentiate thesis: (1) ascertain obstacles in the traditional ways of teaching materials to design students, (2) to bridge the differences in language, research culture and pedagogic approaches in design education, (3) to investigate current professional material practices in industrial design, and (4) to develop a new material framework for teaching reflective material practices for design students. During the project, the material framework has been tested and evaluated in two mandatory material courses with first and second year bachelor students from Product Design education over a period of four academic years. A comparative case study was conducted with five design consultancies. The qualitative interviews were transcribed and analysed using category zooming. The outcomes of this research are: (1) a new pedagogic framework for teaching materials to Product Design students in higher education, and (2) insights into professional practices of selecting and designing with materials. The pedagogic model A Material Framework for Product Design is designed to facilitate the development of reflective material practices in design education. The Framework consist of four levels: (1) a pedagogical foundation based on Experiential Learning theory that provide a framework for how to approach teaching and learning, (2) designing and structuring learning activities, (3) creating learning environments that facilitate learning activities, and (4) defining learning objectives, assessment of learning outcomes and detecting signs of learning. The main insights from the study of professional practices suggest: (1) that risk management has a major influence on the material selection process, (2) that negotiations of project boundaries in the ‘fuzzy’ pre-design phase has crucial influence on the risk management aspect of the material criteria activities, and (3) a lack of awareness, that design briefs usually outline material criteria expressed as sensorial characteristics, which are later translated by engineering into final material criteria used for the material selection process. The findings implies that design students would benefit from developing reflective material practices in design education.