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The purpose of the article is to determine whether tax authorities were entitled to recharacterise and omit legal transactions made by taxpayers in the legal state before 1 January 2019. In particular, the article concerns the examination whether the legal basis in this respect could be derived from the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. The authors come to the conclusion that there was no legal basis for type of action due to Article 11(1) of the Corporate Income Tax Act and lack of possibility to refer to the OECD Guidelines. It is a non-binding document and does not constitute a source of law generally applicable in Poland. Celem artykułu jest ustalenie, czy organy podatkowe były uprawnione do recharakteryzacji i pominięcia czynności prawnych dokonanych przez podatników w stanie prawnym przed 1 stycznia 2019 r. W szczególności zaś zbadanie, czy podstawą prawną w tym zakresie mogły być Wytyczne OECD w sprawie cen transferowych dla przedsiębiorstw wielonarodowych oraz administracji podatkowych. Autorzy dochodzą do wniosku, że tego rodzaju działanie było pozbawione podstaw prawnych ze względu na treść art. 11 ust. 1 ustawy o podatku dochodowym od osób prawnych oraz brak możliwości odwołania się do Wytycznych OECD. Jest to dokument o niewiążącym charakterze i nie stanowi źródła prawa powszechnie obowiązującego w Polsce.

International audience; Until now, the Draize test on rabbits has been the only test performed to anticipate ocular toxicity of pharmaceutical compounds, mainly irritation. The OECD is urging the scientific community to develop and validate alternative methods to reduce the need for animal testing. Since the models and tests used cannot reflect the entire biologic response, it is necessary to combine them into integrated approaches to testing and assessment (IATA) to obtain robust data. IATAs, along with adverse outcome pathways (AOP) that encompass molecular cascades and key events, require the best combinations of tests. This commentary manuscript describes these OECD tools and proposes original approaches for ocular surface AOP and an IATA for toxicity-induced dry eye (TIDE).

Highlights • Evaluated standardized 40% Garcinol in Wistar rats for its safety. • Acute, sub-acute sub-chronic and reproductive/developmental toxicity study conducted. • 40% Garcinol safe up to 2000 mg/kg at single dose. • NOAEL of 40% Garcinol at sub acute, sub-chronic and reproductive/developmental study is 100 mg/kg/day., The present study was taken up to evaluate the single dose acute toxicity, 28 days and 90 days repeated dose toxicity and reproductive/developmental toxicity of standardized 40% Garcinol in experimental rodents. The studies were conducted in compliance with OECD principles of good laboratory practice, guidelines for testing of chemicals no.420, 407, 408 and 421 respectively. Single dose acute oral toxicity was conducted on female Wistar rats as sighting study step-I (300 mg/kg) & sighting study step-II (2000 mg/kg) and main study (2000 mg/kg). Sub-acute, sub-chronic and reproductive/developmental studies were conducted in Wistar rats divided equally in vehicle control, 20, 50 and 100 mg/kg dose group along with recovery groups for vehicle control and high dose. Reproductive/developmental study was carried out for minimum of 28 days and in females during pregnancy and 4 days post partum. There were no abnormal clinical signs/behavioural changes, reproductive and developmental parameters, gross and histopathological changes as well as no alteration in the body weight, body temperature, haematology and other biochemical parameters in all the four studies. 40% Garcinol has a low toxicity profile in rodents and had no observed effects under experimental conditions used.

Nanosponges (NS) show promising results in different fields such as medicine, agriculture, water purification, fire engineering and so on. The present study was designed to evaluate toxicity of different NS formulations (namely, S1-S6) synthesized with different cross-linking agents such as carbonyl diimidazole, pyromellitic dianhydride and hexamethylene diisocynate; and preparation methods in experimental animals. Acute and repeated dose toxicity studies of formulations were carried out as per OECD guidelines 423 and 407, respectively. For acute toxicity study, formulations were administered to female rats at doses of 300 and 2000 mg/kg orally. The general behaviour of the rats was continuously monitored for 1 h after dosing, periodically during the first 24 h and daily thereafter for a total of 14 days. On day 14, animals were fasted overnight, weighed, and sacrificed. After sacrification, animals were subjected to necropsy. For repeated dose toxicity study, rats of either sex were orally administered with formulations at the dose of 300 mg/kg per day for a period of 28 days. The maximally tolerated dose of all formulations was found to be 2000 mg/kg. Repeated administration of formulations for 28 days did not show any significant changes in haematological and biochemical parameters in experimental animals. These results indicate that the formulations are safe, when tested in experimental animals.

We study the impact of transfer pricing rules on sales prices, firms’ organizational structure, and consumers’ utility within a two-country monopolistic competition model featuring source-based profit taxes that differ across countries. Firms can either become multinationals, i.e., they serve the foreign market through a fully controlled affiliate; or they can become exporters, i.e., they serve the foreign market by contracting with an independent distributor. Compared to the benchmark cases, where tax authorities are either unable to audit firms or where they are able to audit them perfectly, the use of the OECD’s Comparable Uncontrolled Price (CUP) or Cost-Plus (CP) rule distorts firms’ output and pricing decisions. The reason is that the comparable arm’s length transactions between exporters and distributors, which serve as benchmarks, are not efficient. We show that implementing the CUP or CP rules is detrimental to consumers in the low tax country, yet benefits consumers in the high tax country.