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Legal Regulations of Transfer Pricing in Poland
LEGAL REGULATIONS OF TRANSFER PRICING IN POLAND ALEKSANDRA SULIK-GÓRECKA [email protected] Brno, June 2019 Aim of presentation . to present legal regulations concerning transfer pricing in Poland in 2019, . to compare them with previously applicable regulations: regulations in force until 2016, regulations in force in 2017-2018 Due to the right to control taxes up to 5 years back, groups capital in Poland must adapt to three different legal orders History . Poland became a member of the OECD on November 22, 1996 . The first provision on transfer prices was introduced into the Polish legal order in 1935 by amending the Law on state income tax . Post-war regulations to a certain extent regulated the issue of international trade and leveled the impact of differences in the tax systems of individual countries on the tax base of Polish enterprises. The income tax decree of 1946 provided for the possibility of estimating the taxpayer's income in a situation when one of the related parties of the transaction benefited from specific tax reliefs. Two years later, national entities were also subject to regulations limiting the transfer of income . Later, due to the functioning of the centrally controlled economy, the regulation of transfer prices lost their importance. Interest in this issue returned in the early 90s of the twentieth century along with the beginning of the market economy. The Law on Corporate Income Tax, in force since February 15, 1992, includes a provision regulating the issue of links between business entities . Since 1996, work has begun to adapt Polish law to international regulations in the field of transfer pricing. -
© E Ugenie Brink
© Eugenie Brinkema EVAN JOHNSON (*1980) 1 hyphen (2002) 01:51 1 Peter Neville, crotales 2 – 3 ELISION: Carl Rosman, bass clarinet Richard Haynes, bass clarinet 4 Graeme Jennings, violin Apostrophe 1 (All communication is a form of complaint) 5 Mieko Kanno, violin (2007 – 2008) EXAUDI: Juliet Fraser, soprano Amanda Morrison, soprano 2 I. 19:59 Christopher Field, countertenor Tom Williams, countertenor 3 II. 03:25 Stephen Jeffes, tenor Jonathan Bungard, tenor James Weeks, conductor 6 Mabel Kwan, toy pianos 4 clutch (2005) 01:32 5 Colophons (“That other that ich not whenne”) reflecting pool / monument (2006) 08:11 6 Positioning in Radiography (2007) 13:14 TT 48:16 2 3 A paradox lies at the heart of Evan Most of the notes in these two pieces on either side, which give it its function At first glance, Johnson appears tied to Johnson’s music. When composing he of- move at high speed, and long pauses are and meaning. Those words constitute a a heavy, European tradition of rich nota- ten begins with a structure of durational used to extend the music’s duration be- sort of white or negative space, whose tional determination, formal complexity containers, proportionally related. He then yond just a few seconds. In clutch these presence and influence can be inferred and hierarchy. His scores – almost always follows this by trying to squeeze in ma- pauses comprise two sustained notes of even if the words themselves are not spo- hand-engraved, in a beautiful, precise and terials that are too large for those spac- around 30 seconds’ duration each – played ken. -
Album of the Week: Deerhoof's La Isla Bonita
Album Of The Week: Deerhoof’s La Isla Bonita Believe it or not, there are a few bands that have been around for a while that I have yet to take a dive into. One of those bands are San Francisco noise pop punk act Deerhoof, and their new album La Isla Bonita has shown me exactly what I’ve been missing. One of those bands that have managed to stick around since the mid-90s, the variety of sounds and dimensions in each track off of the album is jaw dropping. One moment it sounds like a psychedelic j- pop song and then unpredictably these crunchy rigid guitars come in and obliterate everything. So many influences and styles being showcased in one sound, Deerhoof’s new release is simply amazing with its stunning originality. The album was produced by former music journalist & ex-Mr. Dream drummer Nick Sylvester. For a band that has gained acclaim for being extremely DIY for self-producing their previous albums and self- managing, at first glance it could sound like a risk to make a departure from the norm with a different producer. Sylvester excels with excellent quality, and I also can’t get enough of Greg Saunier’s skills on drums. For all of this polish you might be thinking of, don’t fret. There are a good amount of ear- splitting riff rockers on La Isla Bonita as well. It’s November, which means it’s getting cold and one of your friends is already complaining about it. One thing you shouldn’t complain about are the top tracks off of my Album Of The Week. -
Cinema of the Dark Side Atrocity and the Ethics of Film Spectatorship
Cinema of the Dark Side Atrocity and the Ethics of Film Spectatorship Shohini Chaudhuri CHAUDHURI 9780748642632 PRINT.indd 1 26/09/2014 16:33 © Shohini Chaudhuri, 2014 Edinburgh University Press Ltd The Tun – Holyrood Road 12 (2f) Jackson’s Entry Edinburgh EH8 8PJ www.euppublishing.com Typeset in Monotype Ehrhardt by Servis Filmsetting Ltd, Stockport, Cheshire, and printed and bound in Great Britain by CPI Group (UK) Ltd, Croydon CR0 4YY A CIP record for this book is available from the British Library ISBN 978 0 7486 4263 2 (hardback) ISBN 978 1 4744 0042 8 (paperback) ISBN 978 0 7486 9461 7 (webready PDF) ISBN 978 1 4744 0043 5 (epub) The right of Shohini Chaudhuri to be identified as author of this work has been asserted in accordance with the Copyright, Designs and Patents Act 1988 and the Copyright and Related Rights Regulations 2003 (SI No. 2498). CHAUDHURI 9780748642632 PRINT.indd 2 26/09/2014 16:33 Contents Acknowledgements iv List of Figures viii Introduction 1 1 Documenting the Dark Side: Fictional and Documentary Treatments of Torture and the ‘War On Terror’ 22 2 History Lessons: What Audiences (Could) Learn about Genocide from Historical Dramas 50 3 The Art of Disappearance: Remembering Political Violence in Argentina and Chile 84 4 Uninvited Visitors: Immigration, Detention and Deportation in Science Fiction 115 5 Architectures of Enmity: the Israeli–Palestinian Conflict through a Cinematic Lens 146 Conclusion 178 Bibliography 184 Index 197 CHAUDHURI 9780748642632 PRINT.indd 3 26/09/2014 16:33 Introduction n the science fiction film Children of Men (2006), set in a future dystopian IBritain, a propaganda film plays on a TV screen on a train. -
Propaganda, Cinema and the American Character in World War Ii Theodore Kornweibel, Jr
humphrey bogart's Sahara propaganda, cinema and the american character in world war ii theodore kornweibel, jr. How and why a people responds affirmatively to momentous events in the life of its nation is an intriguing question for the social historian. Part of the answer may be found in the degree to which a populace can connect such events to traditional (and often idealistic) themes in its culture, themes which have had wide currency and restatement. This kind of identification can be seen particularly in wartime; twice in this century large segments of the American population rallied around the call to preserve democracy under the guise of fighting a "war to end all wars" and another to preserve the "four freedoms." But popular perceptions of these global conflicts were not without both deliberate and unconscious manipulation in many areas of the culture, including commercial motion pictures. Hollywood produced hundreds of feature films during World War II which depicted facets of that conflict on the domestic homefront, the soil of friendly Allies and far-flung battlefields. Many of the films showed no more than a crude addition of the war theme to plots that would have been filmed anyway in peacetime, such as gangster stories and musical comedies. But other movies reached a deeper level in subtly linking the war to American traditions and ideals. Sahara,1 Columbia Pictures' biggest money-maker in 1943, starring Humphrey Bogart in a finely understated performance, is such a motion picture. Students of American culture will find Sahara and its never-filmed predecessor script, "Trans-Sahara," artifacts especially useful in ex amining two phenomena: the process of government pressure on 0026-3079/81/2201-0005S01.50/0 5 movie studios to ensure that the "approved" war. -
Deerhoof Ðлбуð¼
Deerhoof ÐÐ »Ð±ÑƒÐ¼ ÑÐ ¿Ð¸ÑÑ ŠÐº (Ð ´Ð¸ÑÐ ºÐ¾Ð³Ñ€Ð°Ñ„иÑÑ ‚а & график) Reveille https://bg.listvote.com/lists/music/albums/reveille-7317783/songs The Runners Four https://bg.listvote.com/lists/music/albums/the-runners-four-6145642/songs The Magic https://bg.listvote.com/lists/music/albums/the-magic-24877481/songs The Man, the King, the Girl https://bg.listvote.com/lists/music/albums/the-man%2C-the-king%2C-the-girl-6144854/songs Mountain Moves https://bg.listvote.com/lists/music/albums/mountain-moves-39057997/songs Holdypaws https://bg.listvote.com/lists/music/albums/holdypaws-5879908/songs Halfbird https://bg.listvote.com/lists/music/albums/halfbird-5641849/songs Future Teenage Cave https://bg.listvote.com/lists/music/albums/future-teenage-cave-artists-95949506/songs Artists Fever 121614 https://bg.listvote.com/lists/music/albums/fever-121614-24877484/songs Bibidi Babidi Boo https://bg.listvote.com/lists/music/albums/bibidi-babidi-boo-4903048/songs Balter/Saunier https://bg.listvote.com/lists/music/albums/balter%2Fsaunier-24877486/songs Friend Opportunity https://bg.listvote.com/lists/music/albums/friend-opportunity-5504015/songs Breakup Song https://bg.listvote.com/lists/music/albums/breakup-song-4959691/songs La Isla Bonita https://bg.listvote.com/lists/music/albums/la-isla-bonita-18344574/songs Deerhoof vs. Evil https://bg.listvote.com/lists/music/albums/deerhoof-vs.-evil-5250942/songs Apple O' https://bg.listvote.com/lists/music/albums/apple-o%27-4781204/songs Milk Man https://bg.listvote.com/lists/music/albums/milk-man-6857998/songs Offend Maggie https://bg.listvote.com/lists/music/albums/offend-maggie-7079052/songs Koalamagic https://bg.listvote.com/lists/music/albums/koalamagic-6424210/songs. -
Spillers Records New Release List 22Nd November 2019
NEW RELEASE CDs 22/11/19 ANNA MEREDITH Fibs [Moshi Moshi] £9.99 BECK Hyperspace [Digipak CD] £10.99 CHRISTY MOORE Magic Nights [2CD] £9.99 CHRISTY MOORE Magic Nights on the Road [Expanded Deluxe 4CD Set] £19.99 Over two dozen tracks that have either never before been released commercially or have been newly pressed and newly remixed COLDPLAY Everyday Life £11.99 GIRL RAY Girl [Moshi Moshi] £9.99 JIMI HENDRIX Songs For Groovy Children: The Fillmore East Concerts [5CD Box Set] £54.99 Assembles all four historic debut concerts by the legendary guitarist in their original chronological order LEONARD COHEN Thanks For The Dance £12.99 MEN OF GWENT (Jon Langford) President Of Wales [Country Mile] £9.99 ANDRE RIEU Happy Days [CD / DVD Set] £10.99 AVATARIUM (Candlemass) The Fire I Long For [Nuclear Blast] £11.99 BANG BANG ROMEO A Heartbreaker’s Guide To The Galaxy £9.99 Feat Example! BIG BAND OF BROTHERS A Jazz Celebration Of The Allman Brothers Band [New West] £9.99 BOMBUS Vulture Culture £10.99 CAOIMHIN O RAGALLAIGH & THOMAS BARTLETT S/T [Real World] £9.99 COMA Voyage Voyage [City Slang] £9.99 DANNY BROWN Uknowhatimsayin¿ [Warp] £9.99 Feat. Run The Jewels, Jpegmafia, Blood Orange & More EL WALI Tiris [Sahel Sounds] £9.99 EMILY CAPELL Combat Frock £9.99 EMILY JANE WHITE Immanent Fire £10.99 ERIK SATIE Vexations £11.99 FLEUR DE LYS O Mi Awn Ni Am Dro £9.99 GRAND SLAM Hit The Ground £9.99 GRATEFUL DEAD Ready Or Not £10.99 Feat Tracks From Their Final Years, Mastered From The Soundboard! LIVE DEAD '69 Phantom Ships With Phantom Sails [2CD] £21.99 Featuring Original Grateful Dead Member Tom Constanten KARYN CRISIS' GOSPEL OF THE WITCHES Covenant £11.99 KILLING JOKE Live In Berlin [2CD] £11.99 LEWIS CAPALDI Divinely Uninspired To A Hellish Extent [CD w/ Bonus Tracks] £10.99 LINDEMANN (Rammstein) F & M [Deluxe CD on Spinefarm] £16.99 MAX RICHTER Ad Astra OST [Deutsche Grammophon] £10.99 NO-MAN (Steven Wilson & Tim Bowness) Love You To Bits [Caroline] £9.99 ROD STEWART You're In My Heart: Rod Stewart with the Royal Philharmonic Orchestra [2CD w/ 7 Bonus Tracks] £12.99 SCOTT H. -
02Bodyetd.Pdf (193.2Kb)
Chapter I: Introduction Throughout history, there have been sporadic pockets or concentrations of intense intellectual activity around the globe. From Athens to Vienna, cities have often been associated with the historical eras in which they excelled. For example, the 5th century BC dramatists in Greece such as Aeschylus, Sophocles and Euripides helped to make Athens a leader in artistic creation during its prime. Vienna, the European capital of the music world during the 18th century, was a center of artistic creativity that included composers such as Mozart and Haydn. During the 1920s, the Weimar Republic held the distinction of being the epicenter of human thought and art, with Berlin firmly at the heart of this activity. A few of the familiar names connected to this era in German history are Thomas Mann, Albert Einstein, Theodor Adorno, Wassily Kandinsky, Lyonel Feininger, Fritz Lang, and F.W. Murnau. In addition to these individuals, many artistic and intellectual schools such as German Expressionism, the Frankfurt School, the Bauhaus, and “Der Sturm” are associated with the Weimar Republic. Socially, the period represents an equally intense atmosphere. The Weimar Republic thrived on entertainment, clubs, and night-life in general. Berlin was at the forefront of urban entertainment in Germany, rivaling the other major cities of the Western world. The nightscape of Berlin was marked by lighted signs advertising small cabaret clubs and lavish musicals. However, the streets were also lined with disabled war veterans, prostitutes, and businessmen alike, reflecting an increase of prostitution, debauchery and crime of which all are in some way connected to the unbelievable inflation that permeated all layers of social, cultural and political life in Weimar Germany during the Republic’s first few years. -
PROPAGANDA FILMS DURING the THIRD REICH by ASHLEY
PROPAGANDA FILMS DURING THE THIRD REICH by ASHLEY SCHRENK (Under the Direction of Christine Haase) ABSTRACT Films produced during the Third Reich generally fall into two categories: blatant propaganda films, which this paper terms hard-core propaganda films, or subtler, soft- core propaganda films. The first category frequently features vilification of Jews, as well as glorification of the German Volk, Heimat and of Hitler. Third Reich hard-core propaganda films portray Aryan Germans in opposition to other races, resulting in the extreme exclusion of the Other. The soft-core propaganda films are a toned down version of the hard-core propaganda films. This thesis proposes an inverse relationship between the level of inherent inconsistencies and contradictions within Third Reich films and the categorization of a film as hard-core propaganda. The greater the inconsistencies in relation to Nazi ideology, the more a film becomes soft-core propaganda and vice versa. A variety of hard and soft-core propaganda films are analyzed, and the overall effectiveness of such propaganda is examined. INDEX WORDS: Third Reich, Propaganda Ministry, Nazi film, Nazi cinema, Goebbels, Riefenstahl, Hitler, Nazi propaganda, Fascism, Fascist aesthetics, Nazi popular film, Triumph des Willens, Jud Süß, Der ewige Jude, Zu neuen Ufern, Die große Liebe, Die goldene Stadt PROPAGANDA FILMS DURING THE THIRD REICH by ASHLEY SCHRENK B.A., The University of Georgia, 2004 B.B.A., The University of Georgia, 2004 A thesis Submitted to the Graduate Faculty of The University -
Desired Ground Zeroes: Nuclear Imagination and the Death Drive Calum Lister Matheson a Dissertation Submitted to the Faculty At
View metadata, citation and similar papers at core.ac.uk brought to you by CORE provided by Carolina Digital Repository Desired Ground Zeroes: Nuclear Imagination and the Death Drive Calum Lister Matheson A dissertation submitted to the faculty at the University of North Carolina at Chapel Hill in partial fulfillment of the requirements for the degree of Doctor of Philosophy in the Department of Communication Studies. Chapel Hill 2015 Approved by: Carole Blair Ken Hillis Chris Lundberg Todd Ochoa Sarah Sharma © 2015 Calum Lister Matheson ALL RIGHTS RESERVED ii ABSTRACT Calum Lister Matheson: Desired Ground Zeroes: Nuclear Imagination and the Death Drive (Under the direction of Chris Lundberg and Sarah Sharma) A wide variety of cultural artefacts related to nuclear warfare are examined to highlight continuity in the sublime’s mix of horror and fascination. Schemes to use nuclear explosions for peaceful purposes embody the godlike structural positions of the Bomb for Americans in the early Cold War. Efforts to mediate the Real of the Bomb include nuclear simulations used in wargames and their civilian offshoots in videogames and other media. Control over absence is examined through the spatial distribution of populations that would be sacrificed in a nuclear war and appeals to overarching rationality to justify urban inequality. Control over presence manifests in survivalism, from Cold War shelter construction to contemporary “doomsday prepping” and survivalist novels. The longstanding cultural ambivalence towards nuclear war, coupled with the manifest desire to experience the Real, has implications for nuclear activist strategies that rely on democratically-engaged publics to resist nuclear violence once the “truth” is made clear. -
Anti-Monumentalism Through an Augmented Reality Based Mobile App
The Democratization of Public Space: Anti-Monumentalism Through an Augmented Reality Based Mobile App Pooyan Alizadeh A Thesis in The Department of Design and Computation Arts Presented in Partial Fulfillment of the Requirements For the Degree of Master of Design at Concordia University Montreal, Québec, Canada August 2020 © Pooyan Alizadeh, 2020 CONCORDIA UNIVERSITY School of Graduate Studies This is to certify that the thesis prepared By: Pooyan Alizadeh Entitled: The Democratization of Public Space: Anti-Monumentalism Through an Augmented Reality Based Mobile App and submitted in partial fulfillment of the requirements for the degree of Master of Design complies with the regulations of the University and meets the accepted standards with respect to originality and quality. Signed by the final examining committee: ______________________________________ Examiner M. Wright ______________________________________ Examiner Dr. Martin Racine ______________________________________ Thesis Supervisor Dr. Carmela Cucuzzella Approved by ___________________________________________________ Dr. Martin Racine, Graduate Program Director ___________________________________________________ Annie Gérin, Dean, Faculty of fine arts Date: 25 August, 2020 ABSTRACT The Democratization of Public Space: Anti-Monumentalism Through an Augmented Reality Based Mobile App Pooyan Alizadeh Nowadays, the role of monuments in public space is a matter of controversy around the world. While public space is being reshaped by social movements worldwide, digital rights to the city raise questions about physical spaces and address them through the digital realm. The purpose of this research-creation project is to examine the possibilities of Augmented Reality (AR) as a platform made for expression and speculation in public space. Critical and speculative design methods are used to foster engagement by examining the capacity of social and cultural movements to produce democracy in public space. -
Hero for History
C M Y K SPLASHING As the weather warms up and you start to enjoy days SAFELY in the pool, remember safety comes first B1 s Art Uncorked offers EWS UN watercolor class B3 NHighlands County’s Hometown Newspaper-S Since 1927 75¢ The News-Sun s supports Child Abuse HCSO warning of Blue Streaks race to Prevention Month, which spring scams A5 win at home A10 starts April 1 www.newssun.com Sunday, March 30, 2014 SFSC Suspects softball linked to player ero for history 2nd home killed in H invasion crash BY PHIL ATTINGER Staff Writer Freshman Lauren Phillips one of 4 killed AVON PARK — Four people as- in head-on collision sociated with a home invasion in Lake Placid last December have News-Sun staff report been linked to a similar robbery in Avon Park at that same time, and AVON PARK — “She was an additional man has been iden- an angel that we didn’t tified as affiliated with them, ac- even know we had un- cording to arrest reports. til now. We took her for The Highlands County Sher- granted,” South Flori- iff’s Office has charged Victor Lee da State College softball Johnson, 20, of 164 Watson Ave. in player Kala Thompson West Orange, N.J., with robbery said about with a firearm, armed burglary of a her team- mate, Lau- SEE SUSPECTS | A9 ren Phil- Katara Simmons/News-Sun lips, who Carole Goad has been Sebring’s historian for 13 years. Her dedication to preserving the history of Se- was one of bring has earned her the News-Sun Unsung Hero award for March.