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. 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. 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. 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. 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. 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. 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. 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.

In this thesis, a concept for a modular assembly direct drive permanent magnetgenerator is presented. The maximum forces that act on the different parts of thegenerator during normal operation have been calculated and used in solid mechanicsimulations in SolidWorks. The result is a rough first draft of a generator designwhere the stator has been divided into five modules and the rotor into six modules.This division is done in order to avoid symmetries in the generator that could lead toproblems with self-oscillation.The modulization of the stator brings about certain difficulties, both for the magneticcircuit and for the winding scheme. Different solutions for optimization of themagnetic circuit are analyzed from both a physical and a construction technicalperspective. A winding scheme is produced and the winding process tested in awinding dummy produced according to the conceptual generator design.

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.

<p>We develop algorithms to approximately count perfect matchings in bipartite graphs (or permanents of the corresponding adjacency matrices), perfect matchings in nonbipartite graphs (or hafnians), and general matchings in bipartite and nonbipartite graphs (or matching generating polynomials). </p><p>First, we study the problem of approximating the permanent and generating weighted perfect matchings in bipartite graphs from their correct distribution. We present a perfect sampling algorithm using self-reducible acceptance/rejection and an upper bound for the permanent. It has a polynomial expected running time for a class of dense problems, and it gives an improvement in running time by a factor of $n^3$ for matrices that are (.6)-dense. </p><p>Next, we apply the similar approach to study perfect matchings in nonbipartite graphs and also general matchings in general graphs. Our algorithms here have a subexponential expected running time for some classes of nontrivial graphs and are competitive with other Markov chain Monte Carlo methods.</p> / Dissertation

The purpose of this work was to investigate a permanent magnet synchronous machine which will be produced by an industry partner of the Institut für Stromrichtertechnik und Elektrische Antriebe (ISEA) an institute of the Rheinisch Westfälisch Technische Hochschule - Aachen, Germany (RWTH). The machine manufacturer noted certain abnormalities with the frequency spectrum produced by an electric machine that they were developing; this problem was brought to ISEA in order to be investigated. My work continues the work of my supervisor, Dipl.- Ing Matthias Bösing, and seeks to further examine the machine for a much wider range of operating points, determine the relationship between current amplitude, harmonics, control angle and rotor position on radial force components of the machine and therefore stresses on the stator; which are the primary causes of electrical machine noise. Rather than investigate acoustic issues in particular, the study was limited to the study of electromagnetically generated radial force ripple, which is the cause of stator deflection modes and therefore the emission of sound waves. The primary results of this thesis researched the operation of a permanent magnet synchronous machine and described its behavior with regards to force, torque, and force and torque ripple and their spectrums versus numerous parameters, including control angle, secant current and rotor position. Next, the work used provided data, literature and the simulation results for this thesis in order to deconstruct the operation regions of the particular machine and therefore link the causes of particular noise spectral components to the operation of the machine. From this it was possible to identify potential ways to eliminate these areas of noise. Following this, the thesis examined a particular abnormality in the torque and force waveforms produced by the machine and devised actions which could correct this abnormality. After identifying this asymmetry, the work explored how to choose an optimal control strategy for eliminating particular harmonics based on the simulated operating points and a desired command torque. Finally, the research built on the previous work by supplementing the method of current harmonic injection for eliminating radial force harmonics in this machine, with a method of determining an optimal operating point before the injection currents are calculated.

In the field of electric machine design, a trend in many applications has been to design machines with increasing torque density. When machines fail to meet torque density requirements or are simply incapable of matching load torque, gears are commonly used. Magnetic gears have been proposed as a means of increasing torque density within electromechanical systems, while avoiding problems associated with traditional mechanical gears. While the idea behind magnetic gears goes back to early patents, their study and use in industry has been very limited to date. This study looks into variations of the gear which could lead to more industrial use. The effect of pole count upon torque ripple is investigated with finite element analysis (FEA). The analysis is extended to new magnetic layouts which borrow from permanent magnet machine design. One of the most critical components of the gear, the stator pole pieces, are also investigated for variations which aid in construction while maintaining the performance of the gear. As a means of supplementing analysis of the gear, winding function theory (WFT) is used to analyze the gear. Winding function theory has enjoyed success with induction, synchronous, and even switched reluctance machines in the past. This study is the first of its kind to apply winding function theory to a device devoid of windings altogether. It is shown that this method is capable of generating the stall torque and steady-state torque ripple waveforms which have been commonly attempted with FEA. While magnetic gears enjoy distinct advantages over mechanical gears such as inherent overload protection, they are not as torsionally stiff as their mechanical counterparts. As such, the use of damper windings for the purpose of stiffening the gear against transient oscillations is also investigated. Several competing designs are investigated for their performance, and a final design is studied which is capable of arresting transient oscillations in less than a second. In addition, a prototype has been fabricated and will be used to verify the analysis undertaken. The prototype is used to verify variations of the stator pole pieces as well as the inner rotor magnetic layout. A dynamometer has been assembled to test the performance of the prototype. A new design is also proposed for future work.

Keynes (1936) first brought up the relationship between consumption and national income, but Kuznets¡¦observation about the U.S. data was not supported by the Keynes consumption function form. So there are many macroeconomic theories trying to explain the phenomenon observed by Kuznets. This paper uses the way developed by Campbell (1987) to test the permanent income hypothesis suggested by Friedman with Taiwan data. In addition, this paper uses the stochastic cointegration developed by Harris, McCabe, and Leybourne (2002) to re-examine the relationship between consum-ption and national income because the traditional non-stochastic cointegration assumes that the error term is linear and homogeneous, which may be too strong to fit the real world. Besides, this paper compares the nonstochastic cointegration with the stochastic cointegration, and the evidence founded is that the permanent income hypothesis is not supported by Taiwan data with these two methods.

No description available.

none

<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>