我國所得稅係採年度申報自繳制度，具有大量、反覆之特性，因此稅捐稽徵機關在所得稅申報期間之前，即已進行各種課稅資訊之蒐集活動，除藉此定出各類所得、費用標準，以作為核課依據外，嗣人民申報其年度所得稅後，即將蒐集之課稅資料與申報資料互相勾稽，作為選定事後審查對象及釐正申報資料與核定所得額之依據；當年度之所得稅申報資料及核定情形復又成為次一年度之課稅基本資料來源及比較對象，二者環環相扣，互為因果關係，形成一個獨立體系，而得以單獨作為研究之對象。次為掌握稅務調查制度之全貌，必須對其作全面性之審視及檢討，故本文採用源自日本之行政法學研究方法「行政過程論」從實現稅務行政目的之過程，歸納、整理所得稅事前課稅資訊蒐集活動及事後審查階段之調查手段、程序、屬性、相關人之法律關係、調查效果及其救濟途徑，以宏觀角度檢視現行法制下之稅務調查制度，藉以發現問題並試圖提出解決方法或修法建議。 / Taiwan adopts an annual self-reporting system for income tax return. Such reporting system involves massive and recurrent information. Hence tax authorities would collect all kinds of tax information before the annual income tax reporting period and use such information to set out the norms for different types of income and expenses as basis for taxation. Upon receiving the annual income tax returns filed by taxpayers, tax officers would check the filed data against the collected tax information, and based on the results, determine the taxpayers to be audited and the assessed income tax. The information contained in an annual income tax return and the results of assessment become the source of basic tax information and comparison for following year’s return. Hence income tax returns of two successive years are interrelated and can form discrete units for research purpose. In order to grasp the full view of the tax investigation system, comprehensive examination of the system is necessary. Thus this study employs the methodology of the “theory of administrative process” originated in Japan to examine the tax investigation system under the prevailing law in a macroscopic manner, from the process of tax administration, pre-filing tax information collection, the means, procedure and attributes of post-filing investigation, legal relationship of the parties concerned, to the effect of investigation and remedies available. This study attempts to discover problems, and based on which, propose solutions or suggestions for regulatory amendment.

The aim of the labor is to review the difference of development in energy politics of each EU Member state, the different development of power and gas production and consumption. Between the aims of this dissertation thesis belongs checking of the power and gas market, detection of weak and strong sites, comparison of association with insufficient production capacities and problems with import of gas from the states outside of EU. The main objective is to describe some important aspects of the co-operation with Russia as a strong partner of today and into the future regarding the gas supplies to EU. Another objective is an answer to a question what does mean liberalization and which influence it has on the energy politics of EU in context of EK Directive with respect to solving of problems with shortage of power, price increase and insufficient investment into the new recourses of energy and cross-border capacities, also the unsatisfactory co-operation between the states of EU in this problem. The future of the European energetic originally set if possible on the highest autonomy of delivery strikes against the problem of fossil fuel recourses decreasing. At the same time the world recourses of a crude oil are decreasing and their rest is estimated for the next 60 years. Considering this situation is the change of the prime fuel recourses structure for Europe unavoidable and actual. It is necessary to count on that the import European independence in the next 50 years will increase rapidly and the import of fuels will be absolutely dominative. The package of solutions which could help to overcome the future crisis is not big enough. The market liberalization with energy recourses of EU should make possible the access and competitive business to the smaller companies on this market and provide the similar market conditions which have oligopolies. In case of EU Member states there is necessary an energy solidarity that is just often discussed. The basic problem is that there should exist the common policy not only of energy but foreign affairs as well. The real progress won't be achieved if we don't accept the clear rules of behavior in energetic by each Government of the EU Member states. The solution I can see in case that we have a Constitution to enable unity in foreign and energy policy, so that reliability, security and stability of power and gas supplies would be sure. In my opinion making of the common energy policy will take a big engagement of all EU Member states and some more time.

The target of this diploma work is to provide the view of up to now development and present condition of economy relations between EU and Brasil (consequently between Czech Republic and Brasil), to describe and sum up the status of these relations and to point out the agents complicating the given cooperation. From the point of view of content the work is sectionalized into 5 chapters. The first one characterizes the economy of Brasil, the basic economy markers trends and the Brasil's fortes and weaknesses. The following 2 chapters tackle the juridical ambit of billateral EU and Brasil co-operation, agreements to govern their relationship, the analysis of the goods and services barter, direct foreign investments and protective restrains complicating the business. The content of the chapter No. 4 is the mutual EU - Brasil relations decsription in regard of their acting in wider aggregations, specifically in WTO and Mercosure. The last chapter is focused on the mutual czech and brasilian trade relations characteristic.

Der vorliegende Sammelband beruht auf Vorträgen, die im Rahmen einer studentischen Fachtagung zum Thema „Grenzüberschreitende Zusammenarbeit in Europa“ am 21. Januar 2013 an der TU Chemnitz gehalten wurden. Die Studierenden sind in den Studiengang „Europa- Studien“ eingeschrieben und haben sich in einem vorbereitenden Seminar besondere Expertise in den von ihnen bearbeiteten Themen erworben, wobei vielfach eine rechtlich-institutionelle Perspektive eingenommen wurde. / This volume is based on a students' conference on "Crossborder-co-operation in Europe" on January 21, 2013. The students are enrolled in the European Studies course and have acquired particular expertise regarding their subject within a preparatory seminar which focused on a legal-institutional perspective.

隨著知識經濟之發展，無形資產對於企業價值之重要性因而提升。就跨國企業而言，其無形資產配置對利潤分配之影響遠遠超過有形資產之交易，故近年來無形資產已成為各國稅務機關查核跨國企業間移轉訂價之重點項目。 本研究以經濟合作暨發展組織 2013 年7 月30 日發布之「無形資產移轉訂價修訂討論稿」為根基，結合美國、中國及印度等國家之相關規範，分析我國目前對於無形資產移轉訂價規範之缺失，並以近三年來與無形資產移轉訂價相關之國內外訴訟案例為研究範疇，探討實務上徵納雙方常見爭議，進而提出個人建議，冀能做為我國無形資產移轉訂價規範修法方向及徵納實務之參考。 / The importance of intangibles for market capitalization of an enterprise has been rising with the development of knowledge economy. Distributions of intangibles have more impact on profit allocations than transactions of tangible assets for multinational enterprises. As a result, the transfer pricing of intangibles have become the focus of taxation for multinational enterprises. This study analyzes defects of the regulations of transfer pricing involving intangibles in Taiwan based on Revised Discussion Draft on Transfer Pricing Aspects of Intangibles which issued by Organization for Economic Co-operation and Development (OECD) on July 30, 2013 and based on the references of the related regulations in other countries, including United States, China and India. Furthermore, the study analyzes and classifies the controversies of transfer pricing of intangibles between taxpayers and tax authorities in practice for the past three years from the court cases.

This dissertation examines the manifestations of the development discourse in the context of a bilateral South-South program of educational assistance through scholarships provided by the Cuban government at the secondary and postsecondary levels to students from Ghana. The research assesses the meanings attached to this program on the basis of the observations, understandings and perceptions of a group of graduates, and of former administrators who were involved in the design, implementation and/or administration of the program. The study gives legitimacy to the perspectives of a distinct group of knowers in a country of the postcolonial Global South who were socialized into an educational model that differs from the educational context of their home country. The research aims to illuminate the links between the program graduates’ experiences with the Cuban program and their subsequent contributions to Ghanaian society, with particular emphasis on the process of their reintegration. Research questions focus on the study participants’ perceptions regarding the relevance of the Cuban education in regard to academic and practical preparation; the combination of liberal and utilitarian principles of education; access opportunities; and ways in which the Ghanaian government may have encouraged the graduates’ return to Ghana in the context of the global brain drain phenomenon. Upon their return to Ghana, the graduates encountered challenges with respect to cultural disorientation due to the partial adoption of Cuban norms and values. They experienced difficulties integrating into professional life based on a perceived lack of understanding of certain Cuban credentials among Ghanaian employers, and encountered discrimination based on their education in an Eastern Bloc country. Once they had overcome the initial challenges, the graduates felt that the technical and professional aspects of their education, in particular the strong applied focus of their study programs, were well aligned with the Ghanaian context. There was evidence that early recruitment at the secondary level and a defined recruitment strategy resulted in program participation across the 10 Regions of Ghana. A distinct subgroup of graduates currently residing in the Bahamas provided insights into the reasons for their non-return to Ghana or their decision to leave their home country again.

Thesis (MA)--University of Stellenbosch, 2002. / ENGLISH ABSTRACT: In October 1999 South Africa and the European Union (EU) signed a free trade agreement, the Trade Development and Co-operation Agreement (TDCA), which came into effect on 1 January 2000. The TDCA was developed to enhance bilateral trade, economic-, political- and social cooperation and consists of three components - the creation of a Free Trade Area between South-Africa and the EU, EU financial aid to South Africa through the European Programme for Reconstruction and Development (EPRD), and project aid. However, the EU, in an effort to secure the best possible deal for itself, often behave in its own interests (through the manipulation of the Wine and Spirits Agreement) during the negotiations for the TDCA. The goal of this study was to establish what exactly trademarks are, and what implications the EU's protection of intellectual property rights on wine and spirits trademarks will have on i) the South African wine industry, ii) whether South Africa could have exercised another option, iii) whether this action has created a precedent with which the EU can, in future, again force South Africa or any of its other developing trade partners to make concessions, and iv) who gains the most from the TDCA. The concludes that the EU, through the manipulation of the Wine and Spirits Agreement, left South Africa with no choice by to concede the use of the contested trademarks - something that has already taken its toll on the South African wine industry - in order to save the TDCA. This action created a precedent that the EU will, in future, again be in a position to threaten developing countries with the termination of an agreement should they fail to comply with its demands. Finally, the conclusion is made that even though the TDCA was created to assist South Africa with its reintegration into the world market, it will ultimately be the EU that benefits most from the agreement. / AFRIKAANSE OPSOMMING: Suid-Afrika en die Europese Unie (EU) het in Oktober 1999 In vryehandelsooreenkoms, die Trade Development and Co-operation Agreement (TDCA) onderteken, wat op 1 Januarie 2000 in werking getree het. Die TDCA is ontwerp om bilaterale handel-, ekonomiese-, politieke- en sosiale samewerking te bevorder en bestaan uit drie komponente, naamlik die skep van 'n vryehandelgebied tussen die EU en Suid-Afrika; finansiele steun deur die EU aan Suid-Afrika onder die European Programme for Reconstruction and Development (EPRD) en projekhulp. Die EU het egter dikwels in eiebelang opgetree (deur middel van die manipulasie van die Wyn- en Spiritus Ooreenkoms) tydens die onderhandelingsproses in 'n poging om die beste moontlike ooreenkoms vir homself te beding. Die doel van hierdie studie was om te bepaal wat presies handelsmerke is, en watter implikasies die EU se beskerming van intellektuele eiendomsregte aangaande wyn- en spiritushandelsmerke op i) die Suid-Afrikaanse wynbedryf sal he, ii) of Suid-Afrika 'n ander opsie kon uitoefen, iii) of hierdie aksie In presedent geskep het waarmee die EU Suid-Afrika of enige van sy ander ontwikkelende handelsvennote in die toekoms weer sal kan dwing om toegewings te maak, en iv) wie die meeste baat vind by die TDCA. Die studie het tot die gevolgtrekking gekom dat die EU deur die manipulasie van die Wyn- en Spiritus Ooreenkoms aan Suid-Afrika geen keuse gegee het nie as om die gebruik van die betwiste handelsmerke op te se - iets wat reeds die Suid-Afrikaanse wynbedryf geknou het - in 'n poging om die TDCA te behou. Hierdie optrede skep 'n presedent dat die EU voortaan in onderhandelings met ander ontwikkelende state weer kan dreig om die hele ooreenkoms te verongeluk indien daar nie aan sy eise voldoen word nie. In die laaste instansie is daar tot die gevolgtrekking gekom dat, alhoewel die TDCA daarop gemik was om Suid-Afrika te help met sy herintegrasie tot die wereldmark, dit uiteindelik die EU is wat die meeste daarby gaan baat.

International police co-operation is a recipe for success in the fight against transnational organised crime. Such cooperation has never been without challenges, especially in the light of disharmonious national laws. SARPCCO has made promising advances towards the elimination of blockages which hamper police cooperation. The joint, bilateral, simultaneous operations which are continuously carried out and the transferring of skills through training are exemplary to the rest of the world. SARPCCO is, however, struggling to make serious inroads into the organised motor vehicle theft because of the problems in returning them to their lawful owners. The objective of this study is to analyse the laws used by the SARPCCO member countries in fighting motor vehicle theft, transnational organised crime, recoveries, repatriation, prosecution and extradition of offenders. The SARPCCO member countries on which the analysis is done are Lesotho, South Africa, Swaziland and Zambia. / Jurisprudence / LL. M.

Text in Afrikaans / Dit is belangrik vir 'n inligtingsdiens wat inligting aan die gemeenskap beskikbaar wil stel, om sekere faktore in ag te neem. 'n Belangrike aspek is of die instansie in staat is om 'n bepaalde diens te lewer wat betref voorraad, fasiliteite en personeel. 'n Vraag wat gevra moet word, is of hierdie diens teen betaling gelewer, of as 'n gratis diens aangebied moet word. 'n Belangrike aspek is die bemarking van dienste wat vroeer nie as deel van 'n ondememing sander winsoogmerke gesien is nie, maar deesdae deel van die bestuursproses uitmaak. Daar behoort ook 'n goeie verstandhouding en 'n vennootskap tussen die inligtingsdiens en die gebruiker in die gemeenskap te bestaan en samewerking tussen die partye behoort op hierdie wyse bewerkstellig te word. Om 'n pro-aktiewe inligtingsdiens aan te hied, is dit belangrik dat kennis geneem word van die inligtingsbehoeftes van die bestuurder in die handel en nywerheid. / Certain factors should be taken into consideration when an information service wishes to provide information to the community. An important matter is whether the institution is able to provide certain services as far as the collection, facilities and personnel are concerned. A question that should also be asked, is whether this should be a fee-based service, or a free service. Another important matter is the marketing of services, which in earlier times did not form part of a non-profit organization, but is nowadays regarded as part of normal management practice. There should also exist a good understanding and a partnership between the information service and the user in the community, and in this way co­ operation between both parties should be established. In order to provide a pro-active information service, it is important to have knowledge of the information needs of the manager in industry and commerce. / Information Science / M.Bibl. (Inligtingkunde)

International water law has been unable to translate its principles into effective institutions for the management of shared water resources. National interest has often override any real commitment to the principles of international water law as reflected by the draft Articles of the ILC. Based on the theory of sovereignty, it emphasises a discretionary power to co-operate. However, the community of interest's theory is rather recommended as basis for co-operation. The draft Articles does not take sufficient account of the role domestic water policies, international relations and economics play in the co-operation of states. An integrated approach that considers social and economic effects within an environmental context is proposetL The political economy of water includes the potential of 'virtual water' through the importation of staple grains. A holistic approach, taking global trade in agriculture into account, is recommended. The SADC countries should also consider the potential of regional trade in 'virtual water'. / Law / LL. M. (Law)