Hasil untuk "Revenue. Taxation. Internal revenue"

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S2 Open Access 2026
Egészségösztönző adónem az EU-jog árnyékában

Róbert Zsolt Faránki-Szalay

Finland adopted the New Soft Drink Tax Act prescribing the progressive taxation of soft drinks. The tax band which a particular soft drink pertains to is defined by the sugar content of each product, progressively increasing directly proportionally to it. However, the products included in the scope of the taxable items, the definition of soft drink and the special exemptions from such taxation cast a shadow of a seemingly arbitrary composition. Finland invoked two arguments, the protection of public health and the increase of budgetary revenues in defence of such punitive taxation. The Commission analysed the scope of the taxation and the exemptions from it, with special regard to its potentially selective nature. As a result of its scrutiny, the Commission cleared the new tax as not constituting state aid, whereby the decision may be a glaring example to other Member States seeking health reforms in taxation. The decision, however, still leaves a covert cliff hanging regarding the tax measure's compliance with the free movement of goods (internal market law), even though its clearance under state aid law has been granted.

arXiv Open Access 2025
Homogeneous coupled cell systems with high-dimensional internal dynamics

Sören von der Gracht, Eddie Nijholt, Bob Rink

The analysis of network dynamics is oftentimes restricted to networks with one-dimensional internal dynamics. Here, we show how symmetry explains the relation between behavior of systems with one-dimensional internal dynamics and with higher dimensional internal dynamics, when the network topology is the same. Fundamental networks of homogeneous coupled cell systems (B. Rink, J. Sanders. Coupled Cell Networks and Their Hidden Symmetries. SIAM J. Math. Anal. 46.2 (2014)) can be expressed in terms of monoid representations, which uniquely decompose into indecomposable subrepresentations. In the high-dimensional internal dynamics case, these subrepresentations are isomorphic to multiple copies of those one computes in the one-dimensional case. We describe the implications of this observation on steady state and Hopf bifurcations in $l$-parameter families of network vector fields. The main results are that (1) generic one-parameter steady state bifurcations are qualitatively independent of the dimension of the internal dynamics and that, (2) in order to observe all generic $l$-parameter bifurcations that may occur for internal dynamics of any dimension, the internal dynamics has to be at least $l$-dimensional for steady state bifurcations and $2l$-dimensional for Hopf bifurcations. Furthermore, we illustrate how additional structure in the network can be exploited to obtain understanding beyond qualitative statements about the collective dynamics. One-parameter steady state bifurcations in feedforward networks exhibit an unusual amplification in the asymptotic growth rates of individual cells, when these are one-dimensional (S. von der Gracht, E. Nijholt, B. Rink. Amplified steady state bifurcations in feedforward networks. Nonlinearity 35.4 (2022)). We prove that (3) the same cells exhibit this amplifying effect with the same growth rates when the internal dynamics is high-dimensional.

S2 Open Access 2024
The Realization Rule as a Legal Standard

Sloan G. Speck

The realization “rule” in tax law is better characterized as a legal standard. This characterization matters after the Supreme Court’s decision in Moore v. United States, which sets the stage for future courts to decide that the Constitution mandates realization—an identifiable event before accrued income is reportable by taxpayers. The stakes of a constitutional realization requirement are underappreciated. Because current statutory law embeds realization as a background principle, a constitutional realization requirement would operate as a taxpayer-initiated antiabuse doctrine—a sword that taxpayers could use selectively to invalidate parts of the Internal Revenue Code and Treasury Regulations. This novel constitutional tool has adverse, and underappreciated, implications for the U.S. tax system’s structure and complexity.      Through the lens of the longstanding academic literature on legal rules and standards, the dangers of a constitutional realization requirement extend beyond top-down risks to individual Internal Revenue Code provisions or, as the Moore majority posited, entire taxing regimes. Instead, a constitutional realization requirement threatens to erode federal income tax law from the bottom up, through incremental public and private challenges to the fundamental mechanics of taxation. Realization and nonrealization permeate business entity taxation in deeply technical ways. In these areas, a constitutional realization requirement may facilitate aggressive private planning, undermine the law’s coherence, and dampen reform efforts. Even Moore’s whisper of a constitutional realization requirement ventures into poorly charted territory, with potentially detrimental consequences that may prove difficult to unwind.     Moreover, a constitutional realization requirement portends increased complexity in tax law. Government-asserted antiabuse doctrines constrain complexity by allowing lawmakers to write simpler rules that cover high-frequency transactions. Low-frequency transactions, including those that reflect inappropriate tax planning, are addressed through (and discouraged by) open-ended standards in the enforcement process. As a taxpayer-initiated antiabuse doctrine, a constitutional realization requirement would have the reverse effect, increasing complexity by increasing the frequency of tax-planned transactions, encouraging more costly government responses to taxpayer abuse, and changing the dynamics of enforcement. The resulting complexity would be systemic—and could increase over time.

S2 Open Access 2024
Understanding of Tax Directorate General Employees on Taxpayer Compliance Behavior

I. Arisanti, I. K. Sujana

Revenue from the taxation sector is the main pillar of state revenue in the State Budget (APBN). However, the Tax ratio, tax capacity, tax effort and tax bouyancy are still very low in Indonesia, indicating that taxpayer compliance behavior in Indonesia is also still very low. Policy is a challenge in efforts to optimize state revenue, especially tax revenue to improve compliance. By understanding the factors that influence compliance behavior, policy makers can develop stronger and more effective ways of dealing with compliance risks. Based on the problems studied, the study uses a qualitative research type. The qualitative approach concentrates more on interpretation and understanding. In terms of data collection and analysis, this approach is sensitive to the context that aims to holistically understand the problems being studied. Qualitative research aims to obtain and understand the meaning of a context in its natural setting and does not prioritize generalization. The results of the analysis show that all informants agree and agree that taxpayers have non-compliant behavior in carrying out their tax obligations. Informants interpret that being compliant can only be obtained from the character of taxpayers, internal factors. Then followed by the influence of external factors in the form of economic factors and the environment of Taxpayers. According to informants, most taxpayers are not compliant due to ignorance, it is very important to ensure that the right tax information according to taxpayers' needs is conveyed clearly by the tax authorities. Supervision from the tax authorities and law enforcement efforts from the tax authorities can encourage taxpayers to behave compliantly. Taxpayers who are already compliant expect service and convenience. Meanwhile, taxpayers who decide not to comply require extra supervision according to tax regulations. Compliance or non-compliance with tax regulations is the result of ongoing interaction between the tax authorities and taxpayers.

1 sitasi en
arXiv Open Access 2024
STEGR in Internal-Space Formulation: Formalisms, Primary Constraints, and Possible Internal Symmetries

Kyosuke Tomonari

We establish the theories of Symmetric Teleparallel Equivalent to General Relativity (STEGR) in the internal-space and investigate possible internal-space symmetries among primary constraint densities in the theories. First of all, we revisit STEGR in terms of the gauge approach to gravity and formulate it in the internal-space set-up. We find three possible formalisms according to the vanishing-torsion property. Then, we investigate possible internal-space symmetries in each formalism. We find that in our formulation there are two possible symmetries. One satisfies the translation symmetry but broken in the local symmetry provided by the general linear group which contains the local Lorentz symmetry. The other satisfies the latter symmetry but is absent in the former symmetry. Finally, we conclude this work and show future perspectives.

en gr-qc, hep-th
arXiv Open Access 2024
The internal languages of univalent categories

Niels van der Weide

Internal language theorems are fundamental in categorical logic, since they express an equivalence between syntax and semantics. One of such theorems was proven by Clairambault and Dybjer, who corrected the result originally by Seely. More specifically, they constructed a biequivalence between the bicategory of locally Cartesian closed categories and the bicategory of democratic categories with families with extensional identity types, $\sum$-types, and $\prod$-types. This theorem expresses that the internal language of locally Cartesian closed categories is extensional Martin-Löf type theory with dependent sums and products. In this paper, we study the theorem by Clairambault and Dybjer for univalent categories, and we extend it to various classes of toposes, among which are $\prod$-pretoposes, elementary toposes, and elementary toposes with a universe. The results in this paper have been formalized using the proof assistant Rocq and the UniMath library.

en math.CT, cs.LO
arXiv Open Access 2024
RecMind: Japanese Movie Recommendation Dialogue with Seeker's Internal State

Takashi Kodama, Hirokazu Kiyomaru, Yin Jou Huang et al.

Humans pay careful attention to the interlocutor's internal state in dialogues. For example, in recommendation dialogues, we make recommendations while estimating the seeker's internal state, such as his/her level of knowledge and interest. Since there are no existing annotated resources for the analysis, we constructed RecMind, a Japanese movie recommendation dialogue dataset with annotations of the seeker's internal state at the entity level. Each entity has a subjective label annotated by the seeker and an objective label annotated by the recommender. RecMind also features engaging dialogues with long seeker's utterances, enabling a detailed analysis of the seeker's internal state. Our analysis based on RecMind reveals that entities that the seeker has no knowledge about but has an interest in contribute to recommendation success. We also propose a response generation framework that explicitly considers the seeker's internal state, utilizing the chain-of-thought prompting. The human evaluation results show that our proposed method outperforms the baseline method in both consistency and the success of recommendations.

en cs.CL
S2 Open Access 2024
Facing the Pandemic in the Savoyard Heartlands: Local Communities and the Comital Administration, 1348–1356

I. Epurescu-Pascovici

ABSTRACT Through an examination of the detailed accounts of three castellanies, this article assesses the Black Death’s socioeconomic impact on central Savoy, focusing on the administration and local communities’ response. By complementing the demographic data from the occasional accounts of direct taxation (subsidia) with the regular castellany accounts’ figures on revenues, grain prices and wages, the article highlights the resilience of the lands directly under the comital administration during and in the aftermath of the plague. A key role in the recovery was played by social mobility, with the comital domains, and in particular the castellany seats, attracting the lion’s share of internal migration at the expense of local seigneuries. Some notable failures notwithstanding, the comital administration’s response was rooted in its experiments with institutional accountability over several decades, complemented by a novel flexibility in negotiating matters of economic governance with the local notables.

arXiv Open Access 2023
Internal gravity waves in stratified flows with and without vortical modes

Vincent Labarre, Pierre Augier, Giorgio Krstulovic et al.

The comprehension of stratified flows is important for geophysical and astrophysical applications. The Weak Wave Turbulence theory aims to provide a statistical description of internal gravity waves propagating in the bulk of such flows. However, internal gravity waves are usually perturbed by other structures present in stratified flow, namely the shear modes and the vortical modes. In order to check whether a weak internal gravity wave turbulence regime can occur, we perform direct numerical simulations of stratified turbulence without shear modes, and with or without vortical modes at various Froude and buoyancy Reynolds numbers. We observe that removing vortical modes naturally helps to have a better overall balance between poloidal kinetic energy, involved in internal gravity waves, and potential energy. However, conversion between kinetic energy and potential energy does not necessarily show fluctuations around zero in our simulations, as we would expect for a system of weak waves. A spatiotemporal analysis reveals that removing vortical modes helps to concentrate the energy around the wave frequency, but it is not enough to observe a weak wave turbulence regime. Yet, we observe that internal gravity waves whose frequency are large compared to the eddy turnover time are present, and we also find evidences for slow internal gravity waves interacting by Triadic Resonance Instabilities in our strongly stratified flows simulations. Finally, we propose conditions that should be fulfilled in order to observe a weak internal gravity waves turbulence regime in real flows.

en physics.flu-dyn
arXiv Open Access 2023
Minimum Entropy Production by Microswimmers with Internal Dissipation

Abdallah Daddi-Moussa-Ider, Ramin Golestanian, Andrej Vilfan

The energy dissipation and entropy production by self-propelled microswimmers differ profoundly from passive particles pulled by external forces. The difference extends both to the shape of the flow around the swimmer, as well as to the internal dissipation of the propulsion mechanism. Here we derive a general theorem that provides an exact lower bound on the total, external and internal, dissipation by a microswimmer. The problems that can be solved include an active surface-propelled droplet, swimmers with an extended propulsive layer and swimmers with an effective internal dissipation. We apply the theorem to determine the swimmer shapes that minimize the total dissipation while keeping the volume constant. Our results show that the entropy production by active microswimmers is subject to different fundamental limits than the entropy production by externally driven particles.

en cond-mat.soft, physics.flu-dyn
arXiv Open Access 2023
Constructing nonstandard hulls and Loeb measures in internal set theories

Karel Hrbacek, Mikhail G. Katz

Currently the two popular ways to practice Robinson's nonstandard analysis are the model-theoretic approach and the axiomatic/syntactic approach. It is sometimes claimed that the internal axiomatic approach is unable to handle constructions relying on external sets. We show that internal frameworks provide successful accounts of nonstandard hulls and Loeb measures. The basic fact this work relies on is that the ultrapower of the standard universe by a standard ultrafilter is naturally isomorphic to a subuniverse of the internal universe.

en math.LO, math.CA
arXiv Open Access 2022
The role of internal variability in global climate projections of extreme events

Mackenzie L. Blanusa, Carla J. López-Zurita, Stephan Rasp

Climate projection uncertainty can be partitioned into model uncertainty, scenario uncertainty and internal variability. Here, we investigate the different sources of uncertainty in the projected frequencies of daily maximum temperature and precipitation extremes, which are defined as events that exceed the 99.97th percentile. This is done globally using initial-condition large ensembles. For maximum temperature extremes, internal variability dominates in the next two decades. Around the middle of the 21st century model and scenario uncertainty become the dominant contribution in the tropics but internal variability remains dominant in the extra-tropics. Towards the end of the century, model and scenario uncertainty increase to near equal contributions of ~40% each globally with large regional fluctuations. For precipitation extremes, internal variability dominates throughout the 21st century, except for some tropical regions, for example, West Africa. In regions where internal variability constitutes the major source of uncertainty, the potential impact of reducing model uncertainty on the signal-to-noise ratio of the climate projection is estimated to be small. We discuss the caveats of the methodology used and impact of our findings for the design of future climate models. The importance of internal variability found here emphasizes that large ensembles are a vital tool for understanding climate projections.

en physics.ao-ph
CrossRef Open Access 2022
Mineral Resource Taxation in Poland as Environmental Revenue

Artur Ochot

The purpose of the article/hypothesis. The statistics on environmental taxes in Poland lack a very specific resource taxation in form of the tax on extraction of certain minerals and the exploitation levy, which is the subject of this article. This paper aims to provide a proof that these taxes should be considered environmental in nature and as such are required to be reported by the European law. Thus, the article suggests and recommends that national environmental tax revenues data should be corrected. Methodology. First, the law and literatue overview is presented, taking view on the characteristics of environmental taxes and placing those taxes that are subject of this article into this category. Next, fiscal importance of those taxes is measured within budgets of its receivers. Additionally, the article provides the information on how much environmental tax statistics would have changed after taking into consideration the taxes discussed in this article. The research period of this study is 2012–2020. It is dictated by the introduction of tax on certain mineral extraction and the latest budget reports available. The research is limited by the accessibility of public data which does not provide separate accounts of hydrocarbon taxes (which should be excluded from environmental data) and taxes on other minerals. Results of the research. The overview of the literature provides some evidence that the exploitation levy should be treated as a tax and, together with the tax on certain mineral extraction, should be treated as environmental in nature. Thus, they should be implemented in national environmental tax statistics. Although majority of environmental tax revenues is made by taxes on energy, the result of this implementation would significantly change values of taxes on pollution and resources, making it second (out of three) most important category within environmental taxes in Poland.

arXiv Open Access 2020
Internal natural transformations and Frobenius algebras in the Drinfeld center

Jürgen Fuchs, Christoph Schweigert

For M and N finite module categories over a finite tensor category C, the category Rex_C(M,N) of right exact module functors is a finite module category over the Drinfeld center Z(C). We study the internal Homs of this module category, which we call internal natural transformations. With the help of certain integration functors that map C-C-bimodule functors to objects of Z(C), we express them as ends over internal Homs and define horizontal and vertical compositions. We show that if M and N are exact C-modules and C is pivotal, then the Z(C)-module Rex_C(M,N) is exact. We compute its relative Serre functor and show that if M and N are even pivotal module categories, then Rex_C(M,N) is pivotal as well. Its internal Ends are then a rich source for Frobenius algebras in Z(C).

en math.CT, hep-th
arXiv Open Access 2020
Intertemporal Price Discrimination with Time-Varying Valuations

Araman Victor, Fayad Bassam

A firm that sells a non perishable product considers intertemporal price discrimination in the objective of maximizing its long-run average revenue. We consider a general model of patient customers with changing valuations. Arriving customers wait for a random but bounded length of time and purchase the product when its price falls below their valuation, which varies following a stochastic process. We show the optimality of a class of cyclic strategies and obtain an algorithm that yields them. When the pace of intertemporal pricing is constrained to be comparable to the upper bound on customers patience levels, we have a good control on the cycle length and on the structure of the optimizing cyclic policies. The results also hold for forward looking strategic customers as well as under an alternative objective of maximizing infinite horizon discounted revenue. We cast our results in a general framework of optimizing the long-run average revenue for a class of revenue functions that we denote {\it weakly coupled}, in which the revenue per period depends on a finite number of neighboring prices. We analyze in detail the case of Markovian valuations where we can obtain closed form formulations of the revenue function and some refinements of our main results. We also extend our results to the case of patience levels that are bounded only in expectation.

en math.OC, math.PR

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