Daily Archives: December 14, 2023

EU’s top court rules in favour of Amazon and Luxembourg in €250m tax dispute – Have a mailbox in Lux and a massive corp tax haven!

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The Court of Justice in Luxembourg ruled on Thursday against the appeal of the EU Commission. The Commission challenged a 2021 decision of the General Court of the European Union, which annulled the Commission’s illegal state aid charges against Amazon.

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In a statement from October 2017, the EU Commission concluded that Luxembourg granted undue tax benefits to the online sales giant by allowing it to shift profits to a tax-exempt company, Amazon Europe Holding Technologies.

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Back in 2003, the Grand Duchy accepted Amazon’s proposal on the tax treatment of two of its Luxembourg-based subsidiaries, allowing Amazon to shift profits from Amazon EU, which is subject to tax, to a tax-exempt company, Amazon Europe Holding Technologies.

After a three-year investigation launched in October 2014, the European Commission concluded in 2017 that the online sales giant received illegal tax benefits from Luxembourg.

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The General Court ruled in 2021 that “Luxembourg had not granted a selective advantage in favour of that subsidiary”, annulling the EU Commission’s decision.

The Commission then submitted its appeal against the ruling of the EU’s lower court, which was now rejected by the Court of Justice, the EU’s top court. The verdict is another blow at the approach of Margrethe Vestager, who for a decade held the post of EU competition chief, also losing a landmark case contesting Apple’s tax regime in Ireland.

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According to Matthias Kullas, Centre for European Policy expert on digital economy and fiscal policy, the ruling makes it more difficult for the Commission to take action against the aggressive tax planning of large digital companies.

“Aggressive tax planning means that taxes are no longer paid where economic value is generated. Instead, companies are established where taxes are low,” Kullas told Euractiv.

Companies with aggressive tax planning reduce their participation in financing public goods in the market. Yet, proportionate participation would only be fair, as these companies likewise benefit from public goods, including education and the administration of justice, Kullas explained.

“Against this backdrop, the minimum taxation that will apply in the EU from 2024 is a step in the right direction but does not solve the problem,” Kullas added.

For Chiara Putaturo, Oxfam EU tax expert, the EU tax rules do not work for the people but benefit the “super-rich and profit-hungry multinationals”.

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“Profit-driven multinationals cannot continue to sidestep their tax bills by having a mailbox in countries like Luxembourg or Cyprus,” she added.

In November, the EU, US, and UK voted against the UN tax convention to fight tax evasion and illicit financial flows, arguing that the Convention would be a duplication of the OECD’s work on tax transparency.

Source: EU’s top court rules in favour of Amazon in €250m tax dispute – EURACTIV.com

Yoga nidra might be a path to better sleep and improved memory

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Practicing yoga nidra — a kind of mindfulness training — might improve sleep, cognition, learning, and memory, even in novices, according to a pilot study publishing in the open-access journal PLOS ONE on December 13 by Karuna Datta of the Armed Forces Medical College in India, and colleagues. After a two-week intervention with a cohort of novice practitioners, the researchers found that the percentage of delta-waves in deep sleep increased and that all tested cognitive abilities improved.

Unlike more active forms of yoga, which focus on physical postures, breathing, and muscle control, yoga nidra guides people into a state of conscious relaxation while they are lying down. While it has reported to improve sleep and cognitive ability, those reports were based more on subjective measures than on objective data. The new study used objective polysomnographic measures of sleep and a battery of cognitive tests. Measurements were taken before and after two weeks of yoga nidra practice, which was carried out during the daytime using a 20 minute audio recording.

Among other things, polysomnography measures brain activity to determine how long each sleep stage lasts and how frequently each stage occurs. After two weeks of yoga nidra, the researchers observed that participants exhibited a significantly increased sleep efficiency and percentage of delta-waves in deep sleep. They also saw faster responses in all cognitive tests with no loss in accuracy and faster and more accurate responses in tasks including tests of working memory, abstraction, fear and anger recognition, and spatial learning and memory tasks. The findings support previous studies which link delta-wave sleep to improved sleep quality as well as better attention and memory.

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Source: Yoga nidra might be a path to better sleep and improved memory | ScienceDaily

Adaptive wax-motor roof tile can cut both heating and cooling costs

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an adaptive tile, which when deployed in arrays on roofs, can lower heating bills in winter and cooling bills in summer, without the need for electronics.

“It switches between a heating state and a cooling state, depending on the temperature of the tile,” said Xiao, the lead author of the study. “The target temperature is about 65° F — about 18° C.”

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It wasn’t until Xiao’s idea of using a wax motor that the idea of adaptive roof tiles took its final shape. Based on the change in the volume of wax in response to temperatures it is exposed to, a wax motor creates pressure that moves mechanical parts, translating thermal energy into mechanical energy. Wax motors are commonly found in various appliances such as dishwashers and washing machines, as well in more specialized applications, such as in the aerospace industry.

In the case of the tile, the wax motor, depending on its state, can push or retract pistons that close or open louvers on the tile’s surface. So, in cooler temperatures, while the wax is solid, the louvers are closed and lay flat, exposing a surface that absorbs sunlight and minimizes heat dissipation through radiation.

But as soon as the temperatures reach around 18° C, the wax begins to melt and expand, pushing the louvers open and exposing a surface that reflects sunlight and emits heat.

In addition, during the melting or freezing process, the wax also absorbs or releases a large amount of heat, further stabilizing the temperature of the tile and the building.

“So we have a very predictable switching behavior that works within a very tight band,” Xiao explained. According to the researchers’ paper, testing has demonstrated a reduction in energy consumption for cooling by 3.1x and heating by 2.6x compared with non-switching devices covered with conventional reflective or absorbing coatings. Because of the wax motor, no electronics, batteries or external power sources are required to operate the device, and unlike other similar technologies, it is responsive within a few degrees of its target range.

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Source: This adaptive roof tile can cut both heating and cooling costs | ScienceDaily

Things That Make No Sense: Epic Lost Its Fight Over Apple’s Closed iOS Platform, But Won It Over Google’s More Open Android Platform

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When Epic went after both Apple and Google a few years ago with antitrust claims regarding the need to go through their app stores to get on phones, we noted that it seemed more like negotiation-by-lawsuit. Both Apple and Google have cut some deals with larger companies to lower the 30% cut the companies take on app payments, and it seemed like these lawsuits were just an attempt to get leverage. That was especially true with regards to the complaint against Google, given that it’s much, much easier to route around the Google Play Store and get apps onto an Android phone.

Google allows sideloading. Google allows third party app stores. While it may discourage those things, Android is way more open than iOS, where you really can’t get your app on the phone unless Apple says you can.

Still, it was little surprise that Apple mostly won at a bench trial in 2021. Or that the 9th Circuit upheld the victory earlier this year. The 9th Circuit made it clear that Apple is free to set whatever rules it wants to play in its ecosystem.

Given all that, I had barely paid attention to the latest trial, which was basically the same case against Google. But, rather than a bench trial, this one was a jury trial. And, juries, man, they sure can be stupid sometimes.

The jury sided with Epic against Google.

That leaves things in a very, very weird stance. Apple, whose system is much more closed off and where Apple denies any ability for third parties to get on the phone without Apple’s permission is… fine and dandy. Whereas, Google, which may discourage, but does allow third party apps and third party app stores… is somehow a monopolist?

It’s hard to see how that state of affairs makes any sense at all.

Google has said it will appeal, but overturning jury rulings is… not easy.

That said, even if the ruling is upheld… it might not be such a bad thing. Epic has said that it’s not asking for money, but rather to have it made clear that Epic can launch its own app stores without restriction from Google, along with the freedom to use its own billing system.

And, uh, yeah. Epic should be able to do that. Having more app stores and more alternatives on app payments would be a good thing for everyone except Google, and that’s good.

So I don’t necessarily have a problem with the overall outcome. I’m just confused how these two rulings can possibly be considered consistent, or how they give any guidance whatsoever to others. I mean, one takeaway is that if you’re creating an ecosystem for 3rd party apps, you’re better off taking the closed Apple route. And, that would be bad.

Source: Things That Make No Sense: Epic Lost Its Fight Over Apple’s Closed iOS Platform, But Won It Over Google’s More Open Android Platform | Techdirt

5Ghoul: 14 5G attack Used For easy and cheap Disruptive Attacks On Smartphones

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A team of researchers from the ASSET Research Group in Singapore have published the details of a collection of vulnerabilities in the fifth generation mobile communication system (5G) used with smartphones and many other devices. These fourteen vulnerabilities are detailed in this paper and a PoC detailing an attack using a software defined radio (SDR) is provided on GitHub. The core of the PoC attack involves creating a malicious 5G base station (gNB), which nearby 5G modems will seek to communicate with, only for these vulnerabilities to be exploited, to the point where a hard reset (e.g. removal of SIM card) of the affected device may be required.

Hardware Setup for 5Ghoul PoC testing and fuzzer evaluation. (Credit: Matheus E. Garbelini et al., 2023)
Hardware Setup for 5Ghoul PoC testing and fuzzer evaluation. (Credit: Matheus E. Garbelini et al., 2023)

Another attack mode seeks to downgrade the target device’s wireless connection, effectively denying the connection to a 5G network and forcing them to connect to an alternative network (2G, 3G, 4G, etc.). Based on the affected 5G modems, the researchers estimate that about 714 smartphone models are at risk of these attacks. Naturally, not just smartphones use these 5G modem chipsets, but also various wireless routers, IoT devices, IP cameras and so on, all of which require the software these modems to be patched.

Most of the vulnerabilities concern the radio resource control (RCC) procedure, caused by flaws in the modem firmware. Android smartphones (where supported) should receive patches for 5Ghoul later this month, but when iPhone devices get patched is still unknown.

Source: 5Ghoul: The 14 Shambling 5G Flaws Used For Disruptive Attacks On Smartphones | Hackaday

Most of this is about crashing the modem. The implication (not spelt out here) is that by restarting the modem or by forcing it to downgrade (to a mode probably no longer supported by the national provider) you force the phone to connect to your own access point, where you can then listen in on the traffic and chain other vulnerabilities to the phone.

New way to charge batteries using indefinite causal order, comes with counterintuitive findings

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Batteries that exploit quantum phenomena to gain, distribute and store power promise to surpass the abilities and usefulness of conventional chemical batteries in certain low-power applications. For the first time, researchers, including those from the University of Tokyo, take advantage of an unintuitive quantum process that disregards the conventional notion of causality to improve the performance of so-called quantum batteries, bringing this future technology a little closer to reality.

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At present, quantum batteries only exist as laboratory experiments, and researchers around the world are working on the different aspects that are hoped to one day combine into a fully functioning and practical application. Graduate student Yuanbo Chen and Associate Professor Yoshihiko Hasegawa from the Department of Information and Communication Engineering at the University of Tokyo are investigating the best way to charge a quantum battery, and this is where time comes into play. One of the advantages of quantum batteries is that they should be incredibly efficient, but that hinges on the way they are charged.

While it’s still quite a bit bigger than the AA battery you might find around the home, the experimental apparatus acting as a quantum battery demonstrated charging characteristics that could one day improve upon the battery in your smartphone. Credit: Zhu et al, 2023

“Current batteries for low-power devices, such as smartphones or sensors, typically use chemicals such as lithium to store charge, whereas a quantum battery uses like arrays of atoms,” said Chen. “While chemical batteries are governed by classical laws of physics, microscopic particles are quantum in nature, so we have a chance to explore ways of using them that bend or even break our intuitive notions of what takes place at small scales. I’m particularly interested in the way quantum particles can work to violate one of our most fundamental experiences, that of time.”

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the team instead used a novel quantum effect they call indefinite causal order, or ICO. In the classical realm, causality follows a clear path, meaning that if event A leads to event B, then the possibility of B causing A is excluded. However, at the quantum scale, ICO allows both directions of causality to exist in what’s known as a quantum superposition, where both can be simultaneously true.

Common intuition suggests that a more powerful charger results in a battery with a stronger charge. However, the discovery stemming from ICO introduces a remarkable reversal in this relationship; now, it becomes possible to charge a more energetic battery with significantly less power. Credit: Chen et al, 2023

“With ICO, we demonstrated that the way you charge a battery made up of quantum particles could drastically impact its performance,” said Chen. “We saw huge gains in both the energy stored in the system and the . And somewhat counterintuitively, we discovered the surprising effect of an interaction that’s the inverse of what you might expect: A lower-power charger could provide higher energies with greater efficiency than a comparably higher-power charger using the same apparatus.”

The phenomenon of ICO the team explored could find uses beyond charging a new generation of low-power devices. The underlying principles, including the inverse interaction effect uncovered here, could improve the performance of other tasks involving thermodynamics or processes that involve the transfer of heat. One promising example is solar panels, where heat effects can reduce their efficiency, but ICO could be used to mitigate those and lead to gains in efficiency instead.

More information: Charging Quantum Batteries via Indefinite Causal Order: Theory and Experiment, Physical Review Letters (2023). journals.aps.org/prl/accepted/ … 109d959f76f487564a34

Source: New way to charge batteries harnesses the power of ‘indefinite causal order’

Israel’s F-35I Combat Experience Is Providing Lessons – showing that ALIS, JIT supply chains and not having control over the software running are disasters waiting to happen

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LaPlante lauded Schmidt’s ability to rapidly field mission data files, packages of information loaded onto F-35s before each flight.”What General Schmidt and his team did, in about a week – week-and-a-half – is turned around these mission data files. That’s the brick that goes into the airplane. And that I think the lessons learned on how you did that can apply all the way around the world.”

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The ‘just-in-time’ logistics strategy and the cloud computing hub that is the foundation for F-35 logistics are of especially high concern. While those systems may be adequate for peacetime operations — and even that is highly debatable — during a time of conflict, relying on them could leave F-35s stranded on the ground.

Those lessons are in addition to the Pentagon’s own review of its long-distance F-35 logistics operations.

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“This program was set up to be very efficient… [a] just-in-time kind of supply chain. I’m not sure that that works always in a contested environment,” Lt. Gen. Schmidt said. “And when you get a just-in-time mentality, which I think is it’s kind of a business model in the commercial industry that works very well in terms of keeping costs down and those kinds of things, it introduces a lot of risk operationally.”

“The biggest risk is that F-35 units have little in terms of spare parts on the shelf to keep their aircraft flying for any sustained amount of time.”

This US Navy graphic provides a very general look at the many layers of complexity just in that service's logistics chains, including joint service, non-military U.S. government, foreign military, and commercial entities.&nbsp;<em>USN</em>

This US Navy graphic provides a very general look at the many layers of complexity just in that service’s logistics chains, including joint service, non-military U.S. government, foreign military, and commercial entities. USN

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logistically specifically, it was designed to be maintenance on demand, essentially. So the aircraft could relay a message to the supply warehouse and say, this part is getting ready to fail. And then Lockheed could send that part out to the base and it could be replaced, rather than having to have large warehouses full of supply parts, not knowing which was gonna fail and what you might need. You take that into the maritime service and the challenge, Tyler, is that you can’t logistically operate that way because we could have a ship, in this case, off the coast of Taiwan that needs a part, and Lockheed Martin can guarantee its arrival into Okinawa. But now there is no FedEx, UPS, DHL that’s gonna get it out to the aircraft carrier. So it stops and now you have a delay and it has to go get picked up and the aircraft might be down. I don’t know if they have resolved that challenge…”

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In addition to being supplied by the U.S. with a surge in spare parts and other items, Israel enjoys an advantage with its F-35 fleet no one else has. It’s developed its own additional sustainment and upgrade system and is the only partner that can test modifications and deploy them, including to the jet’s software, on its own. The IAF even has its own specially configured test F-35 to assist in these efforts.

The IAF realized early on that a troubled U.S. centralized support structure for the jets – a centralized cloud-based ‘computer brain’ called the Autonomic Logistics Information System (ALIS) – wouldn’t meet its needs, especially during a large-scale conflict.

ALIS proved to be riddled with issues, exacerbating maintenance and logistics backlogs. It also turned out to be so intrusive in what data it collects that many foreign operators took steps to firewall off portions of their other networks from it.

The F-35 JPO ultimately decided to abandon efforts to fix the system in favor of a completely reworked architecture called the Operational Data Integrated Network (ODIN). That replacement system is still in development.

Even before the inception of ODIN, Israeli officials negotiated a unique arrangement giving them a degree of independence from the rest of the program.

From our story about concerns over spare F-35 parts:

The F-35Is have a distinct configuration that is importantly not dependent on ALIS. On top of that, it is the only user of the F-35 to have the authority to install entire suites of additional domestically-developed software on its jets and to perform completely independent depot-level maintenance.”

“The ingenious, automated ALIS system that Lockheed Martin has built will be very efficient and cost-effective,” an anonymous Israeli Air Force officer told Defense News in 2016. “But the only downfall is that it was built for countries that don’t have missiles falling on them.”

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There is a major lack of spare parts within the F-35 ecosystem as it is, so the Israel case does serve as an example of what readiness can look like if the parts needed to support the fleet during wartime were actually available.

Israel’s experience, however, doe offer, as was previously pointed out: “an important example of how things might be structured differently and that it can be done. If nothing else, the drivers behind the IAF’s push for independence from the broader F-35 program all speak directly to many of the issues that Lt. Gen. Schmidt and others are just starting to raise more publicly now.” 

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Source: Israel’s F-35I Combat Experience Is Providing Lessons For Future Pacific Fight