The Ghost Dancer lives again while dancing with the Sun. D'ombre et de lumière
Extraits
Droit
Europe's Role in a South African Methodology
This work consists of essays on the so-called Middle Ages, seen from two perspectives. Writing from a sideline perspective, as opposed to the perspectives of historically mainstream theologies, in the first part of the book the author proposes a method for reading religious political texts with European philosophical insights but with a relevance for South Africa. This is done by comparing so-called Medieval texts with South African texts and situations within the demands of liberation, contextualisation, and communalism.In the second part of the book, from a female perspective, the author reevaluates the post-Biblical history of Christianity, criticising the terms "Patristics" and "Middle Ages". A South African women's theology is then offered as the outcome of the sideline perspective on the Bible, history and theology discussed in this book.
12/1991
Informatique
LEARN ACTIVEX DEVELOPMENT USING VISUAL C++ 6.0. CD-ROM included
Learn ActiveX Development Using Visual C++ 6.0 presents the basics of the Component Object Model, the ActiveX Template Library, and the Microsoft Foundation Classes, and explains how these technologies all work together to create cutting-edge components for modem applications and web pages. The text then covers the creation of several types of ActiveX controls in both ATL and MFC, and how to support Property Pages and events in both ATL and MFC. Finally, the author explores the mechanics of using ActiveX on the Internet.
Learn ActiveX Development Using Visual C++ 6.0 is the first in Wordware's series of ActiveX/COM-oriented books for Visual C++ programmers. While some of the information within these books overlaps to ensure that each book stands alone, each does focus on a specific ActiveX/COM-related technology. Look for these other titles: Learn OLE DB Development with Visual C++ 6.0 (1-55622634-9), Learn ActiveX Template Library Development with Visual C++ 6.0 (1-55622-633-0), and Learn Microsoft Transaction Server Development Using Visual C++ 6.0 (1-55622-629-2).
This book:
> Presents the basics of COM, ATL, and MFC.
> Shows how to create several types of controls in both ATL and MFC.
> Demonstrates Property Page and event support in ATL and MFC.
> Explores the use of ActiveX on the Internet.
> Includes a CD containing complete source code and projects; several third-party applications and utilities for creating HTML, CDF, OSD, and ASP files; and trial versions of Borland tools.
01/1999
Droit
Intra-Group Arrangements under Articles 85 and 86 of the Treaty Establishing the European Economic Community
The theory of enterprise unity is of particular importance to multinational enterprises with many affiliates. The law pertaining to the relationship of the various entities within such a group has to address itself to a whole array of problems. The comparison of the approaches taken by the legal systems surveyed is concerned with the antitrust perspective as discernible from the enforcement practice. The possible application of the Competition Rules to such intra-group arrangements involves an examination of conspiratorial situations in which corporate personnel, agents, unincorporated divisions and incorporated subsidiaries as well as corporations owned by the same person(s) take part.
12/1984
Histoire internationale
National Heroes and National Identities. Scotland, Norway and Lithuania
This book investigates the concept of the heroic, questions what it is that makes the national hero an indispensable appendage to any possible interpretation of national identity, and asks why scholars stop short before coming to terms with this elusive phenomenon. It finds answers by following heroic traditions in Scotland, Norway and Lithuania from the early modern period to the twentieth century. The book argues that heroic traditions – prevailing trends in situating heroes in national history – owe much to the early modern state. Both national heroes and the nation state had been conceived with a similar moral political mindset that looked for new ways to identify sources for commonality. The confluence of political theory and Realpolitik attested to three classical types of polities, i.e. civitas popularis (democracy), regnum (kingship), and optimatium (aristocracy), as found at that time in Scotland, Norway and Lithuania respectively. The author shows the varied impact these patterns had on heroic traditions. The long record of national heroes in Scotland is explained as a vestige of the legacy of civic humanism, the continuing traditions of the heroic king-lines in Norway are seen as a result of long-standing absolutism, while the belated arrival of national heroes in Lithuania is excused by the country's aristocratic if at times oligarchic past.
02/1993
12 ans et +
Les 8 royaumes mortels Tome 1 : La cité de Pierre-de-Vie
Raised as a slave in the Darkoath camps of Aqshy, Kiri dreams of a better life. Of a city of wonders, the place of her birth… Lifestone ! She despairs of ever reaching it until a fateful day arrives when her barbarian captors are attacked by Sigmar's noblest warriors, the Stormcast Eternals. Seizing her chance, Kiri flees through a mysterious realmgate that takes her far from the fiery lands of Aqshy. She arrives in the realm of Ghyran and finds the city of Lifestone. But a curse lies on this place, withering its noble spirit. Her path leads her to a special group of children who, like her, are realm-marked the prophecised saviours of Lifestone. There's Thanis, the fighter ; Alish, the inventor ; Kaspar ; the sneak and Elio, the healer. But dark forces are allying against the children and will do anything to stop them achieving their destiny.
06/2019
Histoire internationale
After The Last Ship
After the Last Ship illustrates the author's own history, as well as its connection to the history of other women and children who left India and made the journey across the Kala Pani, the Indian Ocean, and lived as migrants in other countries. In this book the author brings greater understanding of how subjectivities are shaped through embodied experiences of ‘mixed race'. She bears witness to the oppressive policies of the fascist government in Portugal in the 1960's and 1970's and the effects of displacement and exile, by reconstructing her own passage from India to Mozambique and finally to Australia. Further, the author shows the devastation that labels such as ‘half-caste', ‘canecos' and ‘monhe' can cause, when they eat at your flesh, your being, and your body. She sheds light on how identity and culture can serve as vehicles of empowerment, how experiences of belonging can germinate and take root post-diaspora.
04/2014
Non classé
Islam in the West
This book studies the historical, religious and political concerns of the Iraqi Shi‘i community as interpreted by the members of that community who now live in the United Kingdom and Ireland, following the 2003-2010 war and occupation in Iraq. It opens up a creative space to explore dialogue between Islam and the West, looking at issues such as intra-Muslim conflict, Muslim-Christian relations, the changing face of Arab Islam and the experience of Iraq in the crossfire of violence and terrorism – all themes which are currently emerging in preaching and in discussion among Iraqi Shi‘a in exile. The book's aim is to explore possibilities for dialogue with Iraqi Shi‘i communities who wish, in the midst of political, social and religious transition, to engage with elements of Christian theology such as pastoral and liberation theology.
05/2013
Ecrits sur l'art
Seeing loud. Basquiat and music
During the late 1970s and early 1980s, New York City was financially and socially bankrupt, but the art and music scene was flourishing. During these years, the downtown New York music scene - no wave, hip-hop, disco funk and club culture - shaped Jean-Michel Basquiat as both a musician and an artist. This catalog for a traveling exhibition explores how Basquiat's painting has parallels in his music (sampling, cut-up, rapping), and takes a new look at his production as a writer and a poet in light of his connections with the then-emerging hip-hop culture. This beautifully illustrated exhibition catalog of rarely seen photographs and images sheds new light on Basquiat as a musician, exploring how his art and music are related, and how they reflect on his identity as a Black artist in the United States, the downtown New York music scene, and contemporary culture.
08/2023
Non classé
Black and White Speech in the Southern United States
This study compares the pronunciation of the stressed vowel nuclei of black and white southerners interviewed for the Linguistic Atlas of the Middle and South Atlantic States. The informants from Maryland (two pairs), Virginia (seven pairs), and North Carolina (seven pairs), were all interviewed in the period 1933-1939 by a single field worker, Guy S. Lowman, Jr., and were matched as closely as possible for age, education, social class, and geographical proximity. The principal findings of the study are that systematic differences exist between black and white speakers in the pronunciation of the stressed vowels, on the phonic or subphonemic level. This is the same type of variation that is used to characterize dialect differences in the United States. The differences in speech, however, while systematic, are not categorical : i.e., there are no speech features examined that exist solely for black or white speakers. Another finding was that regional variation in speech was less apparent for black speakers than for white speakers.
12/1986
Sociologie
Marital Separation in Contemporary Ireland
This book is based on detailed interviews with a group of Irish women who have experienced marital separation. It links the women's accounts with literature on the values and beliefs about marriage, women and family which were prevalent when they were growing up in Ireland in the 1950s and 1960s. The book chronicles their young adult years, the early stages of their marriages and the events and processes which led to their separations. It explores the women's emotional reactions at the time of separating, the types of support which they found beneficial and the personal, social and financial consequences of having separated. Although the book is written from a sociological perspective, the combination of theory and practical insights make it accessible to a wide variety of readers. It aims to generate discussion and deepen understanding of an area into which there has been minimal research in Ireland and which poses a range of important questions for future researchers, practitioners and policy-makers.
12/2015
Non classé
Contemporary Studies in the National Olympic Games Movement
National Olympic Games were more closely connected with the Ancient Greek ideal than the modern international Olympic Games of de Coubertin. Moreover, such national or regional Olympic Games have not only been precursors for the international Olympic Games but also they have been further developed parallel with the international Olympic Movement - even in the 20th century, in Europe, in North and South America and in Asia. In the emerging nation states of Europe, both before as well as after the turn of the century, these national Olympic Games had a more important function (identity-forming) than the Olympic Games.
10/1997
Instruments de musique
Suite Nr. 1. Für Blasorchester und Schlagzeug. Volume IX opus 7. wind band and percussion
Erich Schmid (1907 - 2000) was an orchestra conductor, choir director and university lecturer who promoted world premieres and radio broadcasts of contemporary music in Switzerland. He himself studied with Bernhard Sekles, among others, then with Arnold Schönberg and followed the aesthetics of the New Viennese School in his compositions. The historical-critical Erich Schmid Edition publishes for the first time all sixteen opus-numbered works as well as three additional piano works. Suite No. 1 is an interesting hybrid that conveys the most modern compositional structure in the genre of light music. Schmid composed it shortly after the end of his year as a master student of Schönberg in Berlin. Like his other works of the time, its unusual instrumentation already shows an effort to move on from classical "high forms" and compose in looser structures, with the free use of the twelve-tone technique providing inner coherence. "Dance", "Waltz", "March" are linked by two inserted "Intermezzi" and introduced by an "Introduction". Not all movements require full instrumentation and are designed for solo rather than group performance. Professional playing techniques such as flutter tonguing and alienating sound effects through damping and muting are used. Instrumentation : wind band and percussion op. 7
04/2023
Anglais apprentissage
Encountering the Chinese. A Guide for Americans, Second Edition
To fathom the complex culture of China is a daunting task, but Hu Wenzhong and Cornelius Grove, in this substantially revised and updated edition of their popular book, have risen to the challenge. They provide a practical and sensitive cross-cultural analysis of Chinese culture along with insights into how best to communicate and interact with Chinese people. As the economic and diplomatie climate in China has changed, the frequency of contact between Chinese and Americans has increased in all areas : business, academic, scientific, professional, personal and cultural, making this book even more valuable. Relying on Hu's knowledge of his native Chinese culture and Grove's American perspective from his substantial experience in China, Encountering the Chinese will enable Westerners to establish more productive and rewarding relationships with the Chinese, both inside and outside the PRC. As in the first edition, the authors retain fondamental information on basic Chinese values, cultural norms, and mindsets and identify the cross-cultural factors that often lead to failed business negotiations, embarrassing faux pas and misunderstandings when Americans and other Westerners encounter the Chinese. In this second edition they have added a discussion of economic changes and the gradual demise of state-owned companies, and they give special attention to the shift among young urban professionals and businesspeople from traditional collectivist values toward individualism and a market economy mentality. There is also a new section for American women working in China.
01/1999
Monographies
Shakespeare, Hogarth and Garrick. Plays, Painting and Performance
In London in 1770 Georg Christoph Lichtenberg (1742-1799) remarked, 'What a work could be written on Shakespeare, Hogarth and Garrick ! There is something similar in the genius of all three. ' Two-and-a-half centuries on, Robin Simon's highly original and illuminating book takes up the challenge. William Hogarth (1697-1764) and David Garrick (1717-1779) closely associated themselves with Shakespeare, embodying a relationship between plays, painting and performance that had been understood since Antiquity and which shaped the rules for history painting drawn up by the Académie royale in Paris in the seventeenth century. History painting was considered the highest form of art : a picture illustrating a moment drawn from just a few lines in a revered text. Hogarth's David Garrick as Richard III (1745) transformed those ideas because, although it looked like a history painting, it was also a portrait of an actor in performance. With it, Hogarth established the genre of theatrical portraiture, a new and distinctively British kind of history painting. This book offers a fresh examination of theatrical portraits through close analysis of the pictures and of the texts used in performance. It also examines the central role of the theatre in British culture, while highlighting the significance of Shakespeare, Hogarth and Garrick in the European Enlightenment and the rise of Romanticism. In this context another trio of genius features prominently : Lichtenberg, Gotthold Ephraim Lessing and Denis Diderot. Familiar paintings and performances are seen in an entirely new light, while unfamiliar pictures are also introduced, including major paintings and drawings that have never been published. The final chapter shows that the inter-relationship between plays, painting and performance survived into the age of cinema, revealing the pictorial sources of Laurence Olivier's legendary film Richard III.
06/2023
Divers
Dirty Panties (English Edition)
Roxane is a young Parisian whose Bohemian life seems stuck in an endless loop of idle afternoons and wine-soaked nights with her roommate. Strapped for cash and novelty, she starts selling her used underwear online. Dirty Panties chronicles her first steps in this marketplace, from the creation of her online persona to the real-life rendezvous with shady customers. This new business soon impacts Roxane's daily life and the people around her. The world she has just stepped into might be much more bizarre than what she expected. Roxane's journey exploring her own appetite for transgression tackles such contemporary themes as sex work, consent and economic domination. How far will she go and where will this end ? Maybelline Skvortzoff's drawing is detailed and vivid and the story is in turn hilarious, awkward, touching and dark. Much like Phoebe Waller-Bridge's character in her TV series Fleabag, Roxane is at the same time completely clueless and determined to make it on her own in this world where everything can be bought and sold. Roxane vend ses culottes -- the original edition of Dirty Panties -- won the 2023 Artemisia award for best humor comic and has been shortlisted for many awards including the official selection of the 2023 Angouleme Festival.
01/2024
Non classé
From Scarcity to Sustainability
For futures studies and environmentalism the late 1960s and early 1970s were a heyday period of great publicity, and much scientific interest was devoted to them. The study 'Limits to Growth', commissioned by the Club of Rome, has played an important role for the further advancement of these fascinating fields. Each of them in its own way deals with the long term prospects of humankind and desirable future paths of humanity and the globe. This investigation illustrates a very important phase in the development of these two areas and writes a history of ideas and a history of impact of the Limits to Growth debate and other activities of the Club of Rome. It includes information that has so far only been known to a very limited number of directly involved individuals and looks into very recent stages of the sustainable development debate and newest developments of more pragmatic and critical futures studies. For the purpose of this study some 100 interviews have been made worldwide with very well known and often influential individuals. Among them are : Sicco Mansholt, Alexander King, Jan Tinbergen, Robert Jungk, Saburo Okita, Lord Kennet, Johan Galtung, Barry Commoner and Philip de Seynes.
12/1991
Anglais apprentissage
A Daily Dose of English. Pour enrichir son anglais chaque jour de l'année
Une page et cinq minutes par jour pour enrichir son anglais sans s'en rendre compte. Puiser son inspiration dans des citations de personnages célèbres. Apprendre des proverbes et des expressions idiomatiques. Découvrir les subtilités de la langue grâce à des jeux de mots. Today's Quote "There is nothing noble in being superior to your fellow men. True nobility lies in being superior to your former self". Ernest Hemingway Today's Expressions I'm not going out with them tonight, I've got other fish to fry. Oil prices have reached new highs. Today's Pun Did you hear about the guy whose whole left side was cut off ? He's all right now.
09/2018
Beaux arts
Grotesques. Fantasy Portrayed, édition bilingue anglais-néerlandais
At the end of the 15th century, the underground ruins of Emperor Nero's famous palace were discovered in Rome : the Domus Aurea. The walls were painted with sumptuous symmetrical decorations teeming with a host of bizarre animals and mythical creatures. This was the beginning of a new visual language, which was known as 'grotesque' after the site found in 'grotto-like' ruins. Hans Vredeman de Vries and Cornelis Floris spread the grotesque style with its endless variations through their printed designs. In the 16th century, grotesque ornaments became popular not only in painting and architecture, but also in glass painting, metalsmithing and book printing. Today we still link the term 'grotesque' to the capricious, bizarre, monstrous - but also to the caricatural and laughable. Bosch and Bruegel were the great pioneers of the grotesque in printmaking with their fantastic drolleries. James Ensor, Fred Bervoets, René De Coninck, Carll Cneut and others are part of a long tradition of artists who were, and still are, inspired by the grotesque : both as a concept and as a figural style.
08/2019
Histoire internationale
On the Border - The Otherness of God and the Multiplicity of the Religions
The Christian theology of religions at present faces a crisis. What precisely is the task of the theology of religions ? Does it merely consist in interpreting the non-Christian religions as steps, phases or contributions in the light of Christianity ? Has one from the theological side conceded the maximum to the non-Christian religions by acknowledging them as anonymous Christianity (Karl Rahner)? This study is an exploration on how one shall liberate the religion of the other from anonymity : how one shall leave the other with his/her own name. The model of thought employed in this study is gained through an analysis of the intercultural process of understanding, explained with instances from Africa and South America.
01/1994
Histoire et Philosophiesophie
Concepts of Mass in Contemporary Physics and Philosophy
The concept of mass is one of the most fundamental notions in physics, comparable in importance only to those of space and time. But in contrast to the latter, which are the subject of innumerable physical and philosophical studies, the concept of mass has been but rarely investigated. Here Max Jammer, a leading philosopher and historian of physics, provides a concise but comprehensive, coherent, and self-contained study of the concept of mass as it is defined, interpreted, and applied in contemporary physics and as it is critically examined in the modern philosophy of science. With its focus on theories proposed after the mid-1950s, the book is the first of its kind, covering the most recent experimental and theoretical investigations into the nature of mass and its role in modern physics, from the realm of elementary particles to the cosmology of galaxies.
The book begins with an analysis of the persistent difficulties of defining inertial mass in a noncircular manner and discusses the related question of whether mass is an observational or a theoretical concept. It then studies the notion of mass in special relativity and the delicate problem of whether the relativistic rest mass is the only legitimate notion of mass and whether it is identical with the classical (Newtonian) mass. This is followed by a critical analysis of the different derivations of the famous mass-energy relationship E = mc2 and its conflicting interpretations. Jammer then devotes a chapter to the distinction between inertial and gravitational mass and to the various versions of the so-called equivalence principle with which Newton initiated his Principia but which also became the starting point of Einstein's general relativity, which supersedes Newtonian physics. The book concludes with a presentation of recently proposed global and local dynamical theories of the origin and nature of mass.
Destined to become a much-consulted reference for philosophers and physicists, this book is also written for the nonprofessional general reader interested in the foundations of physics.
01/2000
Light novel
I'm in Love with the Villainess. Tome 3
Plus d'un an s'est écoulé depuis qu'a eu lieu la révolution, et Rae et Claire sont devenues enseignantes à l'Académie Royale. Alors que les négociations de paix progressent avec l'Empire de Nar, elles sont envoyées là-bas au travers d'un échange étudiant. Avec moult nouveaux personnages, c'est un chapitre inédit qui s'ouvre pour " I'm in Love with the Villainess " !
02/2023
Light novel
I'm in love with the villainess. Tome 1
Rei Ôhashi, une simple employée de bureau d'une petite entreprise, se retrouve soudainement dans le corps de l'héroïne de son jeu vidéo de drague préféré, Revolution. Maintenant sous le nom de Rae Taylor, elle est prête à accomplir son objectif. Passer du bon temps avec les princes du jeu ? Non. Son coeur appartient à la méchante de l'histoire, Claire François. Bien décidée à la chérir et à rester à ses côtés, sa nouvelle vie commence dans un monde empreint de magie !
12/2021
Yuri/homosexualité féminine
I'm in Love with the Villainess Tome 2
Rei Ohashi est une employée de bureau surmenée qui se voit réincarnée dans son jeu de drague préféré " Révolution ", sous le nom de l'héroïne Rae Taylor. Pourtant, ce ne sont pas les princes du jeu qui l'inté-ressent... mais la méchante noble Claire François ! Utilisant sa connaissance du jeu, Rae a réussi à devenir la servante de Claire. Pourtant, elle se retrouve à jouer les intermédiaires entre Thane et Claire...?
12/2023
Yuri/homosexualité féminine
I'm in Love with the Villainess Tome 1
Rei Ohashi est une employée de bureau surmenée qui se voit réincarnée dans son jeu de drague préféré " Révolution ", sous le nom de l'héroïne Rae Taylor. Pourtant, ce ne sont pas les princes du jeu qui l'intéressent... mais la méchante noble Claire François ! Après de nombreuses heures de jeu dans le monde réel, Rei réussira-t-elle à se rapprocher de dame Claire grâce à sa connaissance du jeu et son amour pour elle ?
12/2023
Informatique
USING STAROFFICE
- Make the most of the integrated StarOffice environment
- Create standard documents and templates quickly and easily with the AutoPilot wizards
- Export documents and graphics as HTML files and publish them on the Web
- Create professional-looking documents with styles and templates
- Streamline your workflow with automated functions, including AutoComplete, AutoFormat, and AutoCorrect
- Add hyperlinks and graphic objects to your documents
- Enhance text and presentation documents with special font and 3D effects, 3D graphics, and sounds
- Work with vector graphics and bitmapped images and use basic and advanced drawing functions
- Get connected and organized with StarMail and StarSchedule
- Customize every aspect of your StarOffice desktop
- Manage contacts with the built-in Address Book
- Automate your workflow by using macros
- Troubleshoot common and not-so-common problems when working on documents
- Install and manage StarOffice for multiple users
11/1999
Cinéma
Lumières sur Lumière
Autour des Lumière - Antoine, Auguste et Louis - 14 chapitres de documentation, sources, ressources, citations et références. Entre autres. Quelques pas (de géants) entre les fantasmagories et la photographie animée. La pédagogie à La Martinière en 1862. Un tableau pointilliste des mœurs autour de 1895. A propos de polémiques sur le cinématographe Lumière, rappel des contestations entourant les inventions de Gutenberg, de Jacquard, de Thimonnier, d'Edison. Premières projections, premiers compte rendus, premières recettes, premiers Conseils d'Administration... Que sont devenus les films Lumière ? Les brevets de Monsieur Louis, suivis d'un autoportrait 1922-1946 en 13 interviews. Eloge d'Auguste Lumière par Edouard Herriot, Henri Langlois, Jean Renoir, Eric Rohmer, Jean-Luc Godard... " Ce que je sais le mieux, c'est mon commencement " n'est pas la maxime favorite des spécialistes de cinéma. Mais c'est d'abord les esprits non prévenus des amateurs que Lumières sur Lumière souhaite instruire en amusant. Pareilles miettes de proto-histoires cherchent, non à déconstruire, mais à reconstituer le puzzle d'une vision d'ensemble dont l'auteur devrait être le lecteur.
11/1987
Droit
Transport and Risk Communication
The process of transnationalization in Europe is reflected in the growth of transport flows and the rapid development of new infrastructure facilities. The highly transport sector confronts policy makers with pressing challenges because some major environmental problems are attached to transport. Decision making in the field of transport and the environment is very complicated because of the complexity of the infrastructures themselves and because of the involvement of local actors in the decision making process. The central task of this book is to show how regions and countries deal with this complexity and the new challenges, different ways in which three small European countries face the many uncertainties and controversies surrounding infrastructural policies. Economical constraints, institutional and cultural factors are shown to interfere with the debates on transport-issues and the environmental risks attached to them. Each case-study describes the national characteristics of the transport sector and analyses in some detail one of the major controversies which recently arised around infrastructural projects.
09/1997
Poésie
Adagio d'ombre et de lumière
Ce recueil de poèmes est une promenade le long d'un lac paisible où un doux Adagio de mots caresse l'onde. A coups de virgules et de points l'auteur sème des jardins de syllabes et de voyelles, cueille les vers, en fait des bouquets. Au cours des pages la nostalgie du passé, l'amitié, l'amour, la tristesse , la nature se mélangent d'ombre et de lumière délicatement tissé dans ce recueil.
12/2020
Poésie
Fragments d'ombre et de lumière
Pour avoir frôlé à l'aube tes beaux rivages Orné de mille merveilles mes rêves sages Etoffé mon esprit d'énergiques défis Souvent je t'ai rendu grâce Ô ma poésie Incroyable alchimie que les mots prenant vie Et ma plume guidée qui effleure la page Un recueil de poèmes original qui vous en fera voir de toutes les couleurs !
09/2021
Droit international
Hidden dividend distributions & hidden capital contributions, 2e édition. A technical guide
Luxembourg companies have a legal personality that is separate from that of their shareholder(s). Consequently, they may enter into agreements with their shareholders as they do with third parties. However, when the terms and conditions of those agreements do not adhere to the arm's length standard, tax adjustments may be required in accordance with the concepts of hidden dividend distribution and hidden capital contribution. Both concepts aim at a separation of the sphere of the company (which is itself subject to corporate income tax on its worldwide income) from that of its shareholders. As such, the concepts of hidden dividend distribution and hidden capital contribution are cornerstones of Luxembourg's transfer pricing rules. In addition, in the context of associated enterprises (in a group of companies), tax adjustments might be required under Article 56 of the Luxembourg Income Tax Law ("LITL"). Hence, a clear distinction must be made between agreements that adhere to the arm's length principle and agreements that, motivated by the shareholding relationship, shift advantages from the company to the shareholder or vice versa. Therefore, each contractual relationship between a company and its shareholder(s) must be considered. Luxembourg tax law does not provide for exhaustive definitions of hidden dividend distributions and hidden capital contributions. Both concepts have their origins in case law of the German Reich Tax Court (Reichsfinanzhof) and have been carefully extended and refined through the years by the German Federal Tax Court (Bundesfinanzhof). Since the publication of the first edition of this book back in 2011, the Luxembourg Courts had to decide in numerous cases involving both concepts. This book offers a one-of-a-kind, practical insight into the tax treatment of hidden dividend distributions, hidden capital contributions and triangular cases. Charts, case studies and checklists aid the reader in identifying and assessing the various cases in which hidden dividend distributions and hidden capital contributions may arise. A new chapter with practical case studies considers situations that may occur in the context of multinational groups, Luxembourg alternative funds and individual shareholders. Reading this thorough guide is indispensable for an in-depth understanding of the concepts of hidden dividend distribution and hidden capital contribution. Tax advisers, practitioners and tax students should gain substantially from the insights provided in this book.
01/2024
