In 2008 the Committee of Fiscal Affairs of OECD published its report on profit attributable to a permanent establishment. In 2010 article 7 of the OECD model tax convention was reformed, and the report was revised to better conform to the article. The authorised OECD approach is that a permanent establishment is a separate and independent entity, engaged in the same or similar activities under the same or similar conditions, taking into account the functions performed, assets used and risks assumed by the enterprise through the permanent establishment and through other parts of the enterprise. The approach is built on a two step analysis, the first is a functional and factual analysis and the second is determining the income of the permanent establishment. The authorised OECD approach is that the Transfer Pricing Guidelines should be applied by analogy in transactions between the permanent establishment and the rest of the enterprise. The Swedish Income Tax Law has the view that the permanent establishment is a separate and independent entity. The Swedish approach is a two step analysis; the basis is the accountings of the enterprise adjusted for internal dealings, and the second step is a functional analysis. The Swedish law does not allow allocation of “free” capital to a permanent establishment, nor does it allow a permanent establishment to deduct royalty payments to other parts of the enterprise. The Swedish provision regarding documentation of transactions between enterprises with economic interest in each other does not apply to permanent establishments. For reasons of certainty and predictability, the best thing would be for the legislator to reform the Swedish Income Tax Law. Seeing that a permanent establishment is obliged to have its own accounting, the burden and cost of obliging it to document internal dealings would not be that big.

The fashion industry has become an industry with high attention, and in recent years Swedish fashion has become a strong name internationally. At the same time, it is a competitive industry where smaller fashion companies are competing with big clothing chains. For these actors it is important to internationalise and enter foreign markets to be able to grow. This requires resources and capital that many of the smaller fashion companies today is missing; market knowledge, export knowledge and commercial knowledge.  This makes it interesting to see what factors are important for smaller Scandinavian fashion companies to succeed in establishing on the international market. The purpose of this dissertation is to evaluate and analyze conditions for three smaller Scandinavian fashion companies' internationalisation process. The study is based on case studies of these fashion companies. Theories have been chosen according to the background. These highlights the importance for companies to have knowledge of their market, and how internationalisation is a process of knowledge in which they learn something from each step. Furthermore, how companies in some cases follow a particular pattern and how the establishment can be done in specific steps. It may be important to develop relations with actors in their environment.  By different theories, the authors have designed an assumption about what is important for the smaller fashion companies.  In the dissertation we have found that the most significant and important factors are collaborations, available resources internally or externally, and to have knowledge of the market. The expansion of the business as a foreign establishment means that companies need to seek help outside their organization to succeed internationally.

The aim of this study is to describe and analyse the cooperation between the public employment service and the refugee reception in a medium-sized municipality in southern Sweden on basis of the establishment reform. The study examines how the collaborative process is regarded when it comes to implementation of the reform, and when it comes to the directives and resource allocation between the employment services and the refugee reception. The study also focuses on the deficiencies and the benefits that can be discerned with the establishment reform at local level. A qualitative data collection method has been used. It is semi-structured interviews with workers from the public employment service and the refugee reception. Information materials and evaluations that various authorities have made have also been investigated. The study concludes that it is important that the directives are clarified and that a new local and regional agreement will be established on paper. The study also concludes that because of the strong working line policy and the national workfare regime more responsibility is focused on the individual. This can discourage the establishment and integration process of the newly arrived when the concept of inclusion comes to be regarded as synonymous with employability.

Key establishment is the process whereby two or more parties derive a shared secret, typically used for subsequent confidential communication. However, identifying the exact security requirements for key establishment protocols is a non-trivial task. This thesis compares, extends and merges existing security definitions and models for key establishment protocols. The primary focus is on two-party key agreement schemes in the public-key setting. On one hand new protocols are proposed and analyzed in the existing Canetti-Krawzcyk model. On the other hand the thesis develops a security model and novel definition that capture the essential security attributes of the standardized Unified Model key agreement protocol. These analyses lead to the development of a new security model and related definitions that combine and extend the Canetti-Krawzcyk pre- and post- specified peer models in terms of provided security assurances. The thesis also provides a complete analysis of a one-pass key establishment scheme. There are security goals that no one-pass key establishment scheme can achieve, and hence the two-pass security models and definitions need to be adapted for one-pass protocols. The analysis provided here includes the description of the required modification to the underlying security model. Finally, a complete security argument meeting these altered conditions is presented as evidence supporting the security of the one-pass scheme. Lastly, validation and reusing short lived key pairs are related to efficiency, which is a major objective in practice. The thesis considers the formal implication of omitting validation steps and reusing short lived key pairs. The conclusions reached support the generally accepted cryptographic conventions that incoming messages should not be blindly trusted and extra care should be taken when key pairs are reused.

The main goal of cryptography is to enable secure communication over a public channel; often a secret shared among the communicating parties is used to achieve this. The process by which these parties agree on such a shared secret is called key agreement. In this thesis, we focus on two-party key agreement protocols in the public-key setting and study the various methods used to establish and validate public keys. We pay particular attention to certificateless key agreement schemes and attempt to formalize a relevant notion of security. To that end, we give a possible extension of the existing extended Canetti-Krawzcyk security model applicable to the certificateless setting. We observe that none of the certificateless protocols we have seen in the literature are secure in this model; it is an open question whether such schemes exist. We analyze several published certificateless key agreement protocols, demonstrating the existence of key compromise impersonation attacks and even a man-in-the-middle attack in one case, contrary to the claims of the authors. We also briefly describe weaknesses exhibited by these protocols in the context of our suggested security model.

Inom EU upprätthålls en inre marknad där fri rörlighet för varor, personer, tjänster och kapital säkerställs. Friheterna innebär att all diskriminering på grund av nationalitet i med-lemsstaternas nationella lagstiftning ska avskaffas, vilket följer av EU-rättens företräde framför nationell lagstiftning när regelverken kolliderar. Om en lagstiftning verkar begränsande för någon av dessa friheter måste reglerna rättfärdi-gas eller ändras. Rättfärdigande kan ske genom de fördragsstadgade undantagen eller ge-nom ett undantag som accepterats i EU-domstolens rule of reason-doktrin. De svenska reglerna för uttagsbeskattning har under de senaste åren utvecklats efter EU-rättens praxis. Senast i november i fjol meddelade EU-domstolen ett avgörande som änd-rade förutsättningarna för rättfärdigandet av begränsningar av etableringsfriheten. Den 1 januari i år uppdaterades anståndsreglerna för inbetalningen av uttagsskatten. Frågan är nu huruvida den svenska uttagsbeskattningen är förenlig med etableringsfriheten. Enligt min bedömning verkar den svenska uttagsbeskattningen begränsande för utövandet av etableringsfriheten. Det beror på att det finns en diskrepans för hur bolag beskattas be-roende på om de flyttar eller behåller sin hemvist inom Sverige. Begränsningen kan dock motiveras enligt rule of reason-doktrinens rättfärdigandegrund om fördelningen av be-skattningsrätten mellan medlemsstaterna i enlighet med territorialitetsprincipen. I stort kan jag inte anse annat än att lagstiftningen även är proportionerlig mot detta syfte, men det finns situationer som aktualiserar ett krav på att den skattskyldige ska ställa säkerhet för in-betalningen av skatten, vilket jag anser är ett strängare krav på den skattskyldige än vad som kan anses vara motiverat. / Within EU an internal market is maintained where free movement of goods, people, ser-vices and capital are ensured. These freedoms mean that all discrimination on grounds of nationality in domestic laws should be abolished, which is a result of EU’s superiority which cannot be overridden by domestic law. If a law seems limiting of any of these freedoms, the rules must be justified or changed. The limitation can be justified by either the exceptions enacted in the Treaty or by the prin-ciple of rule of reason. The Swedish rules of exit-taxation have during the last years been developed after EU law practice. In November last year the Court of Justice of the European Union announced a preliminary ruling which changed the conditions for justifications of restrictions on the freedom of establishment. On January first this year, the domestic rules of granting of de-ferment of the payment of the exit-tax were renewed. The question now is whether the Swedish exit-taxation is compatible with the freedom of establishment. In my opinion the Swedish exit-taxation can have a restricting effect for the use of the freedom of establishment. This is because there is an inconsistency on how companies are taxed, depending on whether they move or keep their habitual residence in Sweden. The restriction may however be justified by the principle rule of reason by the purpose of en-suring the balanced allocation of powers of taxation between the Member States, in accor-dance with the principle of fiscal territoriality. Generally I cannot consider otherwise than that the legislation also is proportionate to that purpose, but there are situations when the taxpayer is required to provide a bank guarantee to secure the payment of the tax, which I think is a more stringent requirement on the taxpayer than can be justified.

Climatic changes have induced striking altitudinal and latitudinal vegetation shifts throughout history. These shifts will almost certainly recur in the future; threatening other flora and fauna, and influencing climate feedback loops. Changes in the spatial distribution of vegetation are most conspicuous at physiognomically distinct ecotones, particularly between the subalpine forest and alpine tundra. Traditionally, ecological research has linked abiotic variables with the position of this ecotone (e.g., cold temperatures inhibit tree survival at high elevations). Thus, the prevailing assumption states that this ecotone is in equilibrium or quasi-equilibrium with the surrounding physical environment and that any dynamic shifts express direct linkages with the physical environment. This dissertation employs a landscape ecology approach to examine the abiotic and biotic ecological mechanisms most important in controlling tree establishment at this ecotone. The study site is on the western slopes of Mount Rainier, which was severely burned by a slash fire in 1930. Therefore, a crucial underlying assumption is that the ecological mechanisms controlling tree establishment are similar at disturbed and undisturbed sites. I exploited the use of 1970 CORONA satellite imagery and 2003 aerial photography to map 33 years of changes in arboreal vegetation. I created detailed maps of abiotic variables from a LIDAR-based DEM and biotic variables from classified remotely sensed data. I linked tree establishment patterns with abiotic and biotic variables in a GIS, and analyzed the correlations with standard logistic regression and logistic regression in the hierarchical partitioning framework at multiple spatial resolutions. A biotic factor (proximity to previously existing trees) was found to exert a strong influence on tree establishment patterns; equaling and in most cases exceeding the significance of the abiotic factors. The abiotic setting was more important at restricted spatial extents near the extreme upper limits of the ecotone and when analyzing coarse resolution data, but even in these cases proximity to existing trees remained significant. The strong overall influence of proximity to existing trees on patterns of tree establishment is unequivocal. If the underlying assumption of this dissertation is true, it challenges the long-held ecological assumption that vegetation in mountainous terrain is in equilibrium with and most strongly influenced by the surrounding physical environment.

Mobile phones have become a necessity that is used by people everyday. Enterprise wants to take advantage of this new channel to deliver their advertising messages to the consumer, while the consumers are interested in obtaining new product information. A mobile advertisement platform can bring the enterprise advertiser and the consumer needs together. The main purpose of this research is to explore the current status of mobile advertisement platform and how this kind of platform can be designed. The study includes several major parts: (1) review of literature related to mobile advertising platforms, (2) adopt design science method to analyze system requirements and design a prototype system, (3) use experts to review the system and provide suggestions for improvement. The course of planning and prototype development in a case company are described and evaluated by a group of experts. The contributions of this research are as follows: 1. Understand the current status of mobile advertising to help managers and system developers if they are interested in building such a system. 2. Explore feasible platform implementation through a real prototype development in our case company to show the value and potential of such a platform.

The main contention of this thesis is about the development of relations between Thailand and China. Several-thousands of years ago, Thailand and China were having long-term interactions. After World War II, however, why did the two countries fall into what is now known as the Cold War? Why did the policies of both countries change the way they did, and why did the national diplomatic relations between the two countries become affable once again in 1975? It is my belief that due to China¡¦s unique ability as a world superpower on the international stage, and due to the co-operation between both Thailand and China to have in-depth discussions, they have therefore been able to maintain good relations. Even though relations between the two countries are quite good today, however, they still do have some minor problems that may potentially affect their relations. Overcoming these potential problems is the test that both of these countries face in the future.

<p>Business profits constitute the main part of income derived through international business and these profits are only to be taxed in the home state of the enterprise. However, if the enterprise conducts business in a host state through a PE, the profits attributable to the PE are taxable in the host state. Article 7 of the OECD Model Tax determines the profits attributable to the PE.</p><p>Nevertheless, Member States have interpreted Article 7 of the OECD Model Tax Convention in various ways. In order to provide consensus the OECD adopted an authorised OECD approach for attributing profits to PEs.</p><p>The first part of the purpose of this thesis is to study the Swedish approach for attributing profits to dependent agent PEs in relation to the authorised OECD approach. An enterprise from the home state can be considered to have a dependent agent PE in the host state if it conducts business in the host state through a dependent agent located therein. This is provided that the agent has the authority to conclude contracts in the name of the enterprise and exercises this authority regularly.</p><p>Under the authorised OECD approach for profit attribution to dependent agent PEs it is possible to allocate profits to the PE in excess of the arm’s length remuneration paid to the dependent agent. Thereby, the OECD has adopted the dual taxpayer approach as the authorised OECD approach.</p><p>According to the author’s opinion the Swedish perspective regarding profit attribution to dependent agent PEs differs from the authorised OECD approach as the dual taxpayer approach so far has not been applied in Sweden. Furthermore, it differs as the attribution of capital to PEs is not allowed according to case law and as far as the recognition of internal dealings is concerned.</p><p>When the OECD adopted the dual taxpayer approach as the authorised OECD approach another method was available; the single taxpayer approach. In line with this approach no further profits in excess of the arm’s length remuneration to the dependent agent can be attributed to the dependent agent PE. However, the single taxpayer approach was rejected as the authorised OECD approach, which has lead to disagreement within the international tax community.</p><p>Therefore, the second part of the purpose of this thesis is to study to what extent the authorised OECD approach is sustained. This is done by analysing reactions to the single and dual taxpayer approach among business and academic circles.</p><p>The author believes that reactions against the dual taxpayer approach mainly arise in situations when an enterprise in the host state gives rise to a dependent agent PE. Therefore, the authorised OECD approach should have recognised that different types of dependent agent PEs might arise and the approach is only sustained to the extent that a person belonging to the foreign enterprise leads to the existence of a dependent agent PE.</p>