Edited by Mathieu Winand and Christos Anagnostopoulos
Edited by Joseph Sarkis
The perspective of the country of destination of the investment reveals important aspects of the BEPS impact on tax treaties, and notably that there are now new limitations to the avoidance of the PE status. Before 2017 one of the planning techniques was in fact for non-resident investors to carry out activities in the SC to avoid the so-called ‘PE status’, that of avoiding the payment of taxes in the SC. This chapter focuses on the new aspect of operating through a PE in the SC, by looking at the tax PE threshold, the tests to determine the existence of PE, and by discussing BEPS changes in respect to preparatory/auxiliary activities, the anti-fragmentation rule, to the agency-PE, and to structures in shipping and air transport (section I). The chapter also look at more traditional treaty approaches to problems such as the force of attraction of the PE and the separate treatment of isolated classes of income, also discussing how to protect. the PE operation through the non-discrimination clause (sections II–III).
The chapter explores the origins of climate change adaptation as a research discipline and as an issue for public policy more broadly. The chapter seeks to articulate the linkages delineations between adaptation and other policy areas. For example, where does adaptation policy end and where does development and/or disaster risk management begin? Are there limitations associated with framing adaptation in the context of development? The chapter also assesses whether adaptation is occurring, and if so why, where and in what form (that is, differences between coping and adapting as well as between autonomous and planned adaptation).
This chapter provides an introduction into the need and overview of study in sustainable supply chains. The introduction includes some issues with the term ‘sustainability’ and the focus on natural environmental issues or environmental sustainability in this Handbook. A brief history of sustainable supply chains, and a multi-level analysis sets the stage for introduction to the Handbook.The Handbook structure and content are broadly defined in this chapter.