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This study evaluates the implementation of capacity adjustment using the transactional net margin method (TNMM) on two appeal decisions of transfer pricing dispute based on the tax consultant’s point of view. Capacity adjustment is one of the techniques described in the OECD transfer pricing guidelines...

The measurement of the investment decision is studied by applying the fuzzy analysis method, through fuzzy number arithmetic and sorting method, gives the fuzzy analysis method of net present value (rate) under the condition of risk investment decision, thus solves the risk investment decision problem...

Although faster image decoding method is more important and useful, in some special applications, the controllable decoding process may be required. In the case of making fixed point unchanged, the paper made the fixed parameters of compression mapping into variable parameters, adjusted these parameters...

Conception of literacy, traditionally defined as the ability to read and write with printed texts, has grown beyond its narrowed views towards new understandings of multiliteracy due to the advancement of technology. Despite a plethora of study on general conception of literacy, little is known about...

As a language phenomenon, illocutionary acts can be found in any situations of human life and it has been investigated from John Searle’s performative acts. This study aims at examining how all types of Searlian illocutionary acts are enacted in EFL contexts seen from the dimension of teaching experiences....

Skin cancer is a critical global health issue that requires early and accurate detection for effective treatment. This project introduces Skin Guard, an AI-powered cancer detection system designed to classify skin conditions into seven categories, including malignant melanoma, basal cell carcinoma, and...

From International analysis, India has secured the fifth number in the world’s most E-waste generating countries list. Annually, about 2 million tons of waste is generated. It comprises roughly 70 percent of overall waste including 12 percent from the telecom industry, 8 percent waste from medical business,...

The objectives of the study were to find, construct new theories: (1) direct influence of classroom learning modes on graduates' capabilities, (2) direct influence of control locus types on graduate capability, (3) direct influence of learning ethos on graduate capability, (4) direct influence (5) direct...

This study discuss the implementation of Child-friendly School policy, it is a school that guarantee and fulfill children’s rights in every aspect of life on a well-planed and responsibly way and also the obstacle on the implementation of Child-friendly School at SD Ummul Quro Semarang Regency. It is...

The results show that efforts to recover assets are a difficult process, even under ideal circumstances, asset recovery efforts are complex and multidisciplinary processes, including differences in legal systems; banking secrecy system; unwillingness of developed countries to assist in asset recovery...

Problems in the study is the reduced ability of the basic techniques of soccer player SSB Ripan’s U-14 Lubuk Buaya Padang. The aim of research to determine the ability of the basic techniques of passing, dribbling, shooting and heading. Type of research is descriptive, This type of research is descriptive,...

Asphalt modification with nanotechnology materials can be in the form of nanoclay, carbon nanotubes and nanosilica. Recent research found that nanosilica has been proven to improve rutting performance and fatigue resistance in asphalt mixtures. Nanosilica that will be used in this research is nanosilica...

This research aims to examine the factors that influence perceptions about the ethics of tax evasion in accounting students. The population in this study were active students of Bachelor degree (S1) 2016 semester 8 of Accounting Studies Program at the Faculty of Business, Law and Social Sciences, Muhammadiyah...

This study aims to produce mathematical literacy tasks in multiplication and division of algebra expression which is valid and practical for grade 7. This product was developed through development research with formative evaluation from Tessmer. The formative evaluation involves two stages, preliminary...

Accelerated loading test is a common method to study the performance of asphalt pavement, in the process of previous research, there is no conclusion yet on the design of the loading times plan before the test is carried out. For this study proposes a method for determining the expected number of loading...

Fish cultivation in tarpaulin ponds or Biofloc Technology (BFT) has been widely practiced by the community. Net fish production at BFT is 45% higher than at others. Tarpaulin ponds with a diameter of 1-2 meters (m) can be filled with 1,000-3,000 catfish seeds. The problem is that when fish farming runs...

This paper presents the results of research aimed at comparing the levels of manual skills of pupils with a mild intellectual disability (MID) with those of intact children. More importantly, it aims at the changes which should occur during attendance of the first grade of primary school. A simple disassembly...

Initial literacy ability is one of the abilities that become the obligation to begin to teach to early childhood. This program is very important as a trigger in predicting children's abilities in the future. Even recently, there are many children who do not have an interest in early literacy, besides...

This study aims to describe the learning outcomes of multiple intelligences (visual-spatial and linguistic intelligence) of students who are raised with inquiry learning model that is guided on the reaction rate material at SMAN 1 Krian Sidoarjo. This type of research is pre-experimental with One group...

The study was conducted to explain the counseling playing method through Boy-boyan game for self-regulation development in children aged 6-8 years. The counseling playing method is a derivation in guidance and counseling studies. The counseling playing method is based on theoretical construct of child...

This research aims to determine the contribution of push-up training and Box Jump training to the accuracy of the results of the Putri Club Volleyball smash Dispapora Binjai. The sampling technique used is Purposive Sumpling. The number of female athletes as many as 8 people. This research was conducted...

This study aims to determine the application of participatory leadership of CLC heads to tutors’ performance in Kurma CLC. This research used a qualitative phenomenology approach with descriptive research type. The subject of the research was the head of the Kurma CLC in Alor Regency, East Nusa Tenggara...

The ration is an important factor in determining the success of a business in raising broilers. The provision of appropriate rations will have an impact on feed use and meat quality. This study aims to determine the effect of ration fortification on feed consumption, feed conversion and organoleptic...

A number of Islamic boarding schools are growing rapidly. However, living in Islamic Boarding School give a high risk of Covid-19 transmission because of the intensive interraction of the students and teachers within the same isolated environment while doing activities together. There is no research...

This research aims to find out how Principled engagement the helixes involved in the process of implementing Palembang Mayor Regulation Number 72 of 2018 concerning waste management. The informants for this research were 17 people consisting of 8 government elements, 2 private elements, 2 community elements,...

The research objective is to identify the coastal community participation model for the development of infrastructure that has been built with a slum-free city program (KOTAKU). The participation model smart city indicator is smart people. Research location Coastal village two areas in Sedati. Both villages...

One of the topics that always appear and attract attention is the news of corruption on television. This topic alwaysappears to be headline news. This happens because corruption almost always occurs in Indonesia even it has been entrenched. Corruption has become the lifestyle of our officials. This research...

The purpose of this research is to identify the students’ perception about teacher belief in English as general subject at Universitas Negeri Padang. This is ex-post facto research. The students of English as general subject in 2019 academic year were the population of this study. The sample was chosen...

This research approach is carried out qualitatively, meaning that research procedures produce descriptive data in the form of words from people or observed behavior. The subjects of the study were Physical Education teachers in SLB Binjai City and several Tunagrahita class students. This is because Physical...

The need of people’s animal protein increases every year. One of the alternative sources of animal protein that can be easily obtained is Jowo Super chicken (Gallus domesticus), a hybrid resulting from Kampong chicken and laying hens. However, the high cost of the chicken food causes hardships for breeders...

The introduction of electronic commerce allows consumers collecting multiple and complete product information to induce the purchase motivation. In addition, the electronic commerce appears multiple and efficient product delivery from manufacturer-retailer channels to consumers and largely reduce transportation...

Dental implant treatment is an alternative to tooth replacement with high success and survival rates. Evaluation of implant treatment is useful for predicting a treatment protocol that can determine the best surgical and implant systems. The purpose of this study was to evaluate implant treatments by...

COVID-19 is an infectious disease caused by severe acute respiratory syndrome (SARS)-CoV-2 virus. So far, more than 20 million people have been infected. With the rapid spread of COVID-19 in the world, most countries are facing the shortage of medical resources. As the most extensive detection technology...

Against the backdrop of ICAO’s long-term goal of achieving net-zero carbon emissions in international aviation by 2050, mandatory sustainable aviation fuel (SAF) blending policies and carbon trading mechanisms serve as vital tools for airlines’ low-carbon transformation. This paper establishes a duopoly...

The paper analyzes the need of complex system modeling. According to the advantage and shortage of UML and Petri net, comprehensive usage of Petri net and UML can efficiently improve the comprehensiveness, consistency, accuracy and completeness of the model describing. The translation rules from Petri...

An UHV n-channel LDMOS transistor is usually used for the power management AC-DC convertor that need to enhance the ESD robustness to resist external transient noises. In the cost saving consideration, an UHV nLDMOS unit should be both acted as a circuit element and anti-ESD device because of its large...

The TC4 titanium alloy were deformed at 800 , 2mm/s with various extrusion loops by a new sever plastic deformation method-Continuous Various Cross-section Recycled Extrusion, then the microstructure and microhardness of the specimen along the radial, the maximum deformation force in each extrusion procedure...

This paper aimed at finding out whether tax avoidance differed across firm life cycle (FLC). We used cash flows pattern as a proxy to identify FLC into 4 phases, namely introduction, growth, mature, and decline. Tax avoidance was measured using effective tax rate (ETR) to show the impact of this practice...

To determine the prevalence of glaucoma in obstructive sleep apnea (OSA) patients and compare it with that of patients without OSA. Patients investigated for OSA using polysomnography at the sleep center of King Abdulaziz University Hospital were invited to participate in this cross-sectional case series...

The purpose of this study was to determine: (1) the differences of influence between part training methods and whole training methods on improving basketball skills, (2) the differences in influence between high and low eye-hand coordination on basketball skills, and (3) interactions between training...

The article provides the results of studying magnetic and magnetostrictive properties of alloys in multi component systems (Tb1-хYх)0.8Sm0.2Fe2 with the substitution parameter х = 0, 0.2, 0.4, 0.6, 0.8, 1. Magnetization and magnetostriction studies are given in a wide temperature range. Compensation...

The English for Academic Purposes (EAP) learning is shifting where some tend to lead to the English for General Academic Purpose (EGAP) and others lead to English for Specific Academic Purposes (ESAP). This shift towards two different poles is often due to the highly dynamic and numerous needs of the...

Manova found that there were significantly different between career decided college students and career undecided college students both on the total level of career decision-making difficulty and 8 types of career decision-making difficulties, after controlling the democratic and naturally mature factors....

Chronic ankle sprain causes ankle instability, which is accompanied by a decreased reaction of gluteus muscle strength due to changes in muscle activation and proprioceptive disorders. The purpose of this study is to prove whether the addition of glute exercise to basic exercise therapy further increases...

While the philanthropic foundation has made great contributions to social development, some scandals has jeopardized their credibility, which makes research on information disclosure of foundation necessary. From the perspectives of internal and external stakeholders, a foundation transparency model...

This study addresses the urgent demand for high-level application-oriented talents in the integrated circuit industry of the Guangdong-Hong Kong-Macao Greater Bay Area by proposing an innovative talent cultivation model centered on “industry orientation, school-enterprise collaboration, and multi-dimensional...

Manufacturing is central to the development of China’s real economy, while fiscal policy serves as a key tool for macroeconomic regulation by central and local governments. Adjustments in fiscal revenues and expenditures play a critical role in driving the transformation and upgrading of the manufacturing...

Children’s potential can be discovered by their interests and talents, which are often called multiple intelligences. The piano is an instrument that is predominantly liked by the public. Piano learning is divided into two types, namely pop piano and classical piano by reading block notation. Classical...

This study aims to determine the production performance and output estimation of Madura cattle in Sumenep Regency. The study was conducted in Ganding and Lenteng Districts. Data were collected by interview method with 227 farmers consisting of 111 farmers from Ganding District and 116 farmers from Lenteng...

The basic of language use in news discourse is not only to understand, but also more importantly is the usefulness in diction which can increase the literacy interest on the reader and give impression to the reader sensitivity. This research aim to identify diction of local wisdom in news discourse on...