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EVOLUTION OF THE BENEFICIAL OWNERSHIP CONCEPT： MORE THAN HALF OF CENTURY OF UNCERTAINTY AND WHAT HISTORY CAN TELL US

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Frontiers of Law in China-Selected Publications from Chinese Universities 2017年第4期12卷 501-523页

作者： bruno da silva Ph.D. in International Tax Law Faculty of Law University of Amsterdam Amsterdam

The beneficial ownership concept has constituted for more than half a century one of the most fundamental and debated issues in the application of tax treaties. This article goes back to routes of this term explaining the reason of its original inclusion in the OECD Model Tax Convention and why ultimately such inclusion may have not been necessary. Then it analyses the historical developments of beneficial ownership in the OECD Model Tax Convention. For that purpose it considers different interpretations adopted by jurisdictions （particularly in China） and local courts delving into some of the landmark cases on the subject. Finally it provides a detailed analysis of the current meaning of beneficial ownership considering the most recent developments in the Commentary to the OECD Model Tax Convention.

关键词： beneficial ownership OECD Model Tax Convention Commentary,interpretation case-law China

Peripheral clonal selection shapes the human γδ T-cell repertoire

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Cellular & Molecular Immunology 2017年第9期14卷 733-735页

作者： Biagio Di Lorenzo Julie Déchanet-Merville bruno silva-Santos Instituto de Medicina Molecular Faculdade de MedicinaUniversidade de Lisboa1649-028 LisbonPortugal Instituto Superior Tecnico Universidade de Lisboa1649-028 LisbonPortugal ImmunoConcept CNRS UMR 5164Equipe Labelisée Ligue Contre le CancerUniversity of BordeauxF-33000 BordeauxFrance

γδT cells are often placed at the interface between innate and adaptive *** cells share T-cell receptor(TCR)rearrangements and memory functions1 in common with theirαβT-cell counterparts but differ in terms of the... 详细信息

关键词： Figure kinetics selection

Monkeypox:A looming concern for children?

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Asian Pacific Journal of Tropical Medicine 2022年第8期15卷 335-336页

作者： Claudio bruno silva de Oliveira Joelma Maria de Araújo Andrade Jonas Ivan Nobre Oliveira Pediatric Hospital Maria Alice Fernandes NatalRio Grande do NorteBrazil Blood Center Dalton Cunha NatalRio Grande do NorteBrazil Federal University of Rio Grande do Norte Department of Biophysics and PharmacologyNatalRio Grande do NorteBrazil

Several countries around the world have followed the growing number of monkeypox(MPX) cases with concern, as they are still very sensitive to fears of a new tragic pandemic, as was the case with COVID-19. This alarm has been prolonged since May 2022[1,2], when the current outbreaks of the disease were observed in several countries outside the area normally associated with the circulation of the causative virus, monkeypox virus(MPXV).

关键词： outside cases monkey

Ecological intensification of cropping systems enhances soil functions,mitigates soil erosion,and promotes crop resilience to dry spells in the Brazilian Cerrado

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International Soil and Water Conservation Research 2021年第4期9卷 591-604页

作者： Lucas de Castro Moreira da silva Junior Cesar Avanzi Devison Souza Peixoto Marina Neves Merlo Emerson Borghi Alvaro Vilela de Resende Salvador Francisco Acuna-Guzman bruno Montoani silva Department of Soil Science Federal University of Lavras(UFLA)37200-900LavrasMGBrazil Department of Water Resources Federal University of Lavras(UFLA)37200-900LavrasMGBrazil Embrapa Maize and Sorghum Brazilian Agricultural Research Corporation(EMBRAPA)PO Box:28535701-970Sete LagoasMGBrazil Department of Physics Federal University of Lavras(UFLA)37200-900LavrasMGBrazil Center for Engineering and Industrial Development(CIDESI) Pie de la Cuesta 702Desarrollo San PabloQuerétaroQro.76125Mexico

Water scarcity threatens global food security and agricultural systems are challenged to achieve high yields while optimizing water *** deficit can be accentuated by soil physical degradation,which also triggers water losses through runoff and consequently soil *** soil health in cropping systems within the Brazilian Cerrado biome have been surveyed throughout the years,information about soil erosion impacts and its mitigation are still not well understood;especially concerning the role of cropping system diversification and its effects on crop ***,the aim of this study was to assess whether ecological intensification of cropping systems-inclusion of a consorted perennial grass and crop rotation-could promote soil coverage and consequently decrease water erosion and soil,water,and nutrient *** work studied the effects of crop rotation and consorted Brachiaria,along with different levels of investment in fertilization on soil physical quality and on soil,water,and nutrient losses,and crop *** proved that soybean monoculture(SS)is a system of low sustainability even under no-till in the Brazilian Cerrado *** exhibited high susceptibility to soil,water,and nutrient losses,causing low crop *** results showed that water losses in SS cropping system were approximately 10%of the total annual rainfall,and total K losses would require an additional 35%of K ***,ecological intensification of cropping systems resulted in enhanced soil environmental and agronomic functions,increased grain yield,and promoted soil and water conservation:high soil cover rate,and low soil,water and nutrient *** intensification proved to be an adequate practice to boost crop resilience to water deficit in the Brazilian Cerrado.

关键词： Crop rotation Grain production Nutrient losses Soil physical quality Tropical region

Enhancing Tax Administration Capacity Building: Macao SAR Experience

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Belt and Road Initiative Tax Journal 2022年第1期3卷 37-42页

作者： bruno Aniceto da silva Financial Services Bureau Macao SAR China

The fast pace of development in the international tax matters requires enhancement of tax administration capacity *** outcomes of the Final Report of the Enhancing Tax Administration Capacity Task Force released in September 2021 confirmed the increasing demand of the BRI jurisdictions for capacity building in international *** article reflects on possible areas and approaches for capacity building *** proposes some initiatives that may be developed to help address the gaps among the BRI jurisdictions and contribute to building the capacities of their tax *** reflection is made with a view drawn from the experience of the Macao SAR as one of the first Belt and Road Initiative tax academies.

关键词： Capacity building Tax administration International tax BRITA

Recent and Emerging Trends in Raising Tax Certainty on Cross-Border Transactions

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Belt and Road Initiative Tax Journal 2023年第1期4卷 104-112页

作者： bruno Aniceto da silva Financial Services Bureau Macao SAR China BRITA·Macao

Raising tax certainty constitutes a fundamental for investment de-cisions by multinational enterprises(MNEs)while it is highly valuable also for tax ***,it has been considered as one of the core areas by the BRITACOM *** the past few years,considerable attention has been devoted to improving tax certainty while new challenges *** article analyses some of the recent advances and emerging initiatives in terms of raising tax *** mechanisms for cross-border transactions in areas such as dispute prevention and resolution,transfer pricing,General Anti-Avoidance Rules(GAARs)and the taxation of digital economy.

关键词： Tax certainty Dispute resolution Transfer pricing GAARs Taxing digital economy

Plectranthus amboinicus(Lour.)*** oil as a natural alternative for the conservation of beef patties stored under refrigeration

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Food Bioscience 2022年第5期49卷 397-405页

作者： bruno Dutra da silva Patricia Campos Bernardes Patrícia Fontes Pinheiro Juliana Di Giorgio Giannotti Consuelo Domenici Roberto Department of Food Engineering Center for Agrarian Sciences and EngineeringUniversidade Federal do Espírito SantoAlegreEspírito SantoBrazil Department of Chemistry and Physics Center for ExactNatural and Health SciencesUniversidade Federal do Espírito SantoAlegreEspírito SantoBrazil Department of Rural Engineering Center for ExactNatural and Health SciencesUniversidade Federal do Espírito SantoAlegreEspírito SantoBrazil

Plectranthus amboinicus essential oil(PAEO)has the potential to be used by the food industry as a natural antimicrobial *** study aimed to evaluate the antibacterial activity of PAEO in vitro against pathogenic bacteria contaminating food and its potential for action when added to intentionally contaminated beef *** composition was determined by GC-MS and GC-FID,and thymol(45.64%)was the main compound present in the *** minimum inhibitory(MIC)and minimum bactericidal(MBC)concentration of the PAEO was evaluated against five pathogenic bacteria(Staphylococcus aureus,Listeria monocytogenes,Escherichia coli,Pseudomonas aeruginosa and Salmonella Typhimurium).The MIC of PAEO was the concentration ranges between 0.25 and 2 mg mL^(-1),and the MBC ranged from 1 to 4 mg mL^(-1).The anti-adhesion and removal of adhered cell assays indicated significant reductions(P<0.05)even at concentrations 8x lower than the MIC of *** patties samples were prepared with PAEO concentrations at MIC(2 mg mL^(-1))and sub-MIC(1 mg mL^(-1)).*** and *** were inoculated individually into the beef *** reductions were observed with a greater reduction in the 12th day of storage for ***(1.52 log CFU.g^(-1))and ***(0.93 log CFU.g^(-1))for beef patties with the MIC of *** has the potential to be applied in meat ***,the application and interactions of the oil in the food matrix need to be better elucidated.

关键词： Thymol Natural antimicrobial Anti-adhesion activity Minimum inhibitory concentration Antimicrobial activity

New insights on murineγδT cells from single-cell multi-omics

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Science Bulletin 2022年第11期67卷 1102-1104页

作者： Likai Tan Daniel Inácio Immo Prinz bruno silva-Santos Institute of Systems Immunology University Medical Center Hamburg EppendorfHamburg 20251Germany Instituto de Medicina Molecular João Lobo Antunes Faculdade de MedicinaUniversidade de LisboaLisbon 1649-028Portugal

γδT cells are a second T cell lineage conserved throughout evolution and across animal species that express aγδT-cell receptor(TCR)consisting of a TCRγand a TCRδchain.γδT cells develop in the murine thymus into various subsets with distinct functional potential that preferentially home to specific peripheral tissues,rather than lymphoid organs[1].

关键词： organs γδT细胞多组学研究

An Updated Mini Review of Acute and Chronic Responses to Exercise Training-induced Irisin in Browning of White Fat

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Journal of Endocrinology Research 2019年第1期1卷 1-7页

作者： Sílvia Rocha-Rodrigues bruno silva Polytechnic Institute of Viana do Castelo School of Sport and LeisureMelgacoPortugal Laboratory of Metabolism and Exercise Research Centre in Physical ActivityHealth and Leisure(CIAFEL)Faculty of Sport SciencesUniversity of PortoPortugal Research Center in Sports Sciences Health and Human Development(CIDESD)Vila RealPortugal

Nowadays,is well established that the benefits induced by exercise training(ET)affects not only skeletal muscle,but also other non-contractile organs over *** potential mechanism underlying this crosstalk is the synthesis and secretion of several biological active factors,such as irisin,by muscle contractile *** hormone has been described to be able to induce a brown adipocyte-like phenotype in white adipose(WAT),increase whole-body metabolic rate,and therefore prevent and/or treat obesity-related metabolic ***,the modulatory impact of ET on WAT may also occur through skeletal muscle-adipose organ *** this review,we summarize the acute and chronic adaptations to ET-induced irisin synthesis and secretion on the development of browning of white fat and,thus,providing an overview of the potential preventive and therapeutic role of ET on the obesity-related underlying pathways.

关键词： Hormones Exercise PGC-1α UCP1