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For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 6. (...) The profits to be taxed in that other State shall be determined on the basis of an appropriate allocation of the overall net profits derived by the enterprise from its shipping operations. (...) In determining such adjustment, due regard shall be had to the other provisions of the Convention and the competent authorities of the Contracting States shall, if necessary, consult each other. 8 3.
Language:English
Score: 1168626.7 - https://www.un.org/esa/ffd/wp-...tion-EC18-2006-7-annex-rev.pdf
Data Source: un
In general, the Article does not rely on a determination of purpose or intention but instead sets forth a series of objective tests. (...) For example, domestic law principles of the Contracting State where the income arises may be applied to identify the beneficial owner of an item of income, and Article 22 then will be applied to the beneficial owner to determine if that person is a qualified person that is entitled to the benefits of the Convention with respect to such income. Such determination is made at the time the benefit would be accorded.
Language:English
Score: 1161664.9 - https://www.un.org/esa/ffd/wp-...16/11/13STM_CRP16_beps-lob.pdf
Data Source: un
One group of the members proposed inserting a "free-standing beneficial ownership limitation provision" in the Commentary on Article 1 of the Convention as an optional provision.1 The other group recommended that, instead of making any changes to the Commentary on Article 1, the Committee should undertake as a new project a review of the beneficial ownership concept, including the question of whether that concept is relevant for other Articles of the UN Model. (...) There are further considerations that the Sub-committee and the Committee of Experts may wish to take into account relating to the interpretation of the beneficial ownership concept. Some of these factors may make it difficult to achieve a common understanding of the term “beneficial owner”, unless that term is seen as having an international fiscal meaning. 28. (...) For exactly the same reason – that the UN Model Convention employs the place of effective management as the connecting factor in both alternative versions of Article 8 – it seems hard to make a case for the inclusion of the beneficial ownership limitation in Article 8.
Language:English
Score: 1161539.8 - https://www.un.org/esa/ffd/wp-...0/4STM_EC18_2008_CRP2_Add1.pdf
Data Source: un
In such a case the bit budget available to compress a single video frame is determined by the instantaneous frame rate and currently available bandwidth. (...) The number of blocks used to encode the image is determined by the compression ratio which defines the total number of bits available (the bit budget). (...) Alternatively, simple hardware assist could be provided which would immediately make the codec real-time in practice. It should be noted that the quality of the codebook is such that it has not been found to be beneficial to enable the wavelet residual encoding option for channel bandwidths up to 128kbps.
Language:English
Score: 1149734.9 - https://www.itu.int/wftp3/av-a...video-site/9811_Seo/q15f18.doc
Data Source: un
General enquires Email: unv.media@unv.org Tel: +49-228-815 2000 Fax: +49-228-815 2001 Partnership enquires Email: partnershipsupport@unv.org Tel: +49-228-815 2000 Fax: +49-228-815 2001 2 As a UN Volunteer, Anja supports the UNHCR’s Refugee Status Determination Unit in Jordan, where she interviews asylum seekers to determine whether they meet the legal criteria to be recognized as refugees according to the 1951 Refugee Convention. Prior to joining UNV, Anja spent more than half a decade processing asylum cases under the Swedish Governmental Refugee Status Determination (RSD), which she found to be a rewarding experience. (...) Striking this balance to key to building healthy, ongoing, beneficial relationships that will yield fruit in the years to come.
Language:English
Score: 1143657.2 - https://www.unv.org/node/6435/pdf
Data Source: un
You have to keep on running the marathon, working hard towards your goals, getting better, and success will be the reward attained for your hard work and determination. Are you there yet? Granted, our progress is encouraging, and we have already accomplished a lot, from connections with various organizations in Swaziland to researching a comprehensive guide or gaining new team members. (...) When you have a good idea, remain passionate and do whatever necessary to make it a reality. I think most important is to have an open mind. In this age, technology is constantly changing the manner in which we do things. It’s up to us to make it better, more beneficial to society, more adept at solving pressing challenges… an entrepreneur is one who is able to identify these problems and implement solutions to them!
Language:English
Score: 1136473.8 - https://www.itu.int/wftp3/Publ..._brochure_updated_part1_63.pdf
Data Source: un
You have to keep on running the marathon, working hard towards your goals, getting better, and success will be the reward attained for your hard work and determination. Are you there yet?Granted, our progress is encouraging, and we have already accomplished a lot, from connections with various organizations in Swaziland to researching a comprehensive guide or gaining new team members. (...) When you have a good idea, remain passionate and do whatever necessary to make it a reality. I think most important is to have an open mind. In this age, technology is constantly changing the manner in which we do things. It’s up to us to make it better, more beneficial to society, more adept at solving pressing challenges… an entrepreneur is one who is able to identify these problems and implement solutions to them!
Language:English
Score: 1136473.8 - https://www.itu.int/wftp3/Publ..._files/WebSearch/page0063.html
Data Source: un
The Committee will have to consider the issues related to the tax treatment of CIVs, and to determine if these issues need to be addressed in its upcoming work. (...) The different legal forms of CIVs and the various domestic tax systems can make it difficult to determine whether a CIV is a company, or respectively, a person, and a resident, as the legal personality and the liability to tax are relevant for the treatment as a resident for the purpose of applying the UN Model Double Taxation Convention. (...) In fact, Article 29 of both the OECD and the UN Model Double Taxation Convention suggest to determine explicitly the conditions under which a CIV is considered as a “qualified person” and can claim treaty benefits in the case that a “limitation on benefits” provision is used in a treaty.
Language:English
Score: 1135646.7 - https://www.un.org/development...e-Investment-Vehicles-CIVs.pdf
Data Source: un
Modern Customs administrations have recognized that streamlining and simplification of clearance procedures is beneficial to importers, exporters and their national economies. (...) The purpose of this study is to determine the problems that exist in the Customs clearance process. (...) In particular, the study seeks to: a. determine the time taken for the clearance of goods upon arrival until the physical release of goods (Cargo turnaround time); b. determine the average time taken for the Customs clearance process; c. determine the average time taken for the Customs release process; d. identify the bottlenecks in the Customs clearance and release processes; e. consider possible corrective action and make recommendations. 3.
Language:English
Score: 1135118.6 - https://www.wto.org/english/tr...e/case_studies_e/trs_mys_e.doc
Data Source: un
The world would recognize that a beneficial rectification to all would come about, after the unleashing of a war supported by just a few – either by shortsightedness or by meanness of interests – after it was verified that the pretexts brandished were not true and after observing the reaction of a people that, as will always be done by every invaded and occupied people, begins to fight and will fight over the respect for its right to self-determination. (...) Can we believe that everyone is fostering friendship among our nations on the basis of “the respect for the principle of equality of rights and the self-determination of the peoples”? And why then has my people suffered and still suffers from over four decades of aggressions and economic blockade? (...) The scandalous distribution of Iraq’s wealth must cease immediately. This will prove beneficial to the United States, whose youths are dying there while waging an unjust and inglorious war; it will prove beneficial to Iraq, whose people will be able to turn over a new leaf in its history; it will prove beneficial to the United Nations, that has also been a victim of this war; and it will prove beneficial to all of our countries, that have endured the international economic recession and the increasing insecurity threatening us all.
Language:English
Score: 1129590.2 - https://www.un.org/webcast/ga/...8/statements/cubaeng030926.htm
Data Source: un