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Consideration of the concept of beneficial ownership to make clear who can be entitled to the treaty benefits. 2. (...) Article 15 is used to determine which enterprise the person performs for in such cases where the employment contract might not reflect the actual situation. (...) The intention of the beneficial owner concept was to clarify the use of the words “paid to…a resident” in the Model and so the phrase should be read in that context. – Further clarification was made as to who is a beneficial owner of a payment under Articles 10, 11 and 12: o Beneficial owners are those that have the right to use and enjoy the payment unconstrained by contractual or legal obligations to pass the payment on.
Language:English
Score: 1127266 - https://www.un.org/development...d-and-Developing-Countries.pdf
Data Source: un
With ever-increasing swathes of the world’s population trying to access rich content wherever and whenever they want it, this essential, yet finite, resource of the mobile industry is running out. How can we make sure everyone gets a fair share? What are the new innovative models for efficient allocation to increase the carrying capacity of the increasingly-overburdened airwaves? (...) The ability to forecast and adapt to change determines the success or failure of technology companies. (...) In this dynamic story-led session, 6 industry leaders will share their stories of their sometimes difficult, but always beneficial, journeys toward integrated innovation. Wednesday 26.10.2011 11:00-12:30 DebateSpace #3 Storytelling #1: Turning the Tanker Forum Session
Language:English
Score: 1116580 - https://www.itu.int/wftp3/Publ..._E/web/WebSearch/page0026.html
Data Source: un
Microsoft PowerPoint - Agenda Item 4.ppt 1 W A N S E 2 9 0 Agenda Item 4 Financial Management of Airports W A N S E 2 9 0 ICAO’s Policies on Charges (Doc 9082) • Users to bear full and fair share of the costs [§29] • Airports to maintain accounts for cost recovery purposes [§29] • Aggregation of costs may be beneficial in certain circumstances [§30iv] • Users not to be burdened with costs not allocable to them [§30vi] • Differential charges to be transparent and fair [§31v] W A N S E 2 9 0 Airport Economics Manual (Doc 9562) • Chapter 3: Airport financial management • Chapter 4: Determining the cost basis for charging purposes • Chapter 5: Charges on air traffic and their collection • Chapter 6: Non-aeronautical activities • Chapter 7: Financing airport infrastructure 2 W A N S E 2 9 0 Financial Situation • Improvement noted in recent ICAO surveys • Most sampled airports recover their costs/make a profit (83% of the 343 reporting airports) W A N S E 2 9 0 Performance Management • Define performance objectives related to Key Performance Areas (KPAs) • Set and report performance indicator and target – Input – Output – Outcome W A N S E 2 9 0 Financial Management • Business plan and budget • Budget control • Financing and cash management 3 W A N S E 2 9 0 Accounting System • Financial statements • Cost centers statements • Service lines statements W A N S E 2 9 0 Accounting Finance statements Statement for cost centers Statement for service lines Allocation to cost centers Allocation to Service lines Determine cost basis for charges Establish individual charges Process for determining Cost Basis for Individual Charges W A N S E 2 9 0 Determining Cost Basis for Charges • Allocate to cost centers/service lines • Attribution of non-aeronautical revenues to the cost basis – Single till – Dual till – Hybrid system 4 W A N S E 2 9 0 Determining Cost Basis for Charges (cont.) • Traditional method – Allocation of costs into cost bases for individual charges • Flexibility added by CEANS – Aggregation of cost bases W A N S E 2 9 0 Setting Airport Charges • Application of economic principles – Differential charges – Modulated charges • Principles – Non-discrimination – Transparent – No-cross subsidization – Time limitation W A N S E 2 9 0 Setting Airport Charges (cont.) • Landing • Lighting • Approach/aerodrome control • Parking • Aerobridge • Hangar • Passenger services • Cargo • Security • Noise & emissions 5 W A N S E 2 9 0 Non-Aeronautical Activities • Types (see Doc 9562, Table 6-1) • Setting concession fees and charges – Determining market value – Tenders • Contractual aspect – Leases for premises, land – Management contracts – Free zones W A N S E 2 9 0 Airport Financing • Traffic forecasts • Cost-benefit analysis • Financing plan • Sources of financing W A N S E 2 9 0 Exercises • Principles • Non-aeronautical activities Economic situation • Performance management • Single/dual till • Differential charges EXERCISES ON AGENDA ITEM 4 INDIVIDUAL Q1. (...) (c) Charges should be determined on the basis of sound accounting and other economic principles.
Language:English
Score: 1115748.6 - https://www.icao.int/sustainab...-Bangkok-2009/AgendaItem_4.pdf
Data Source: un
– Centralized unit or decentralized – International unit – Separate unit for nonresidents Development of expertise concerning tax treaties 17 Role of the Tax Authorities Tax authorities must have the necessary powers under domestic law to investigate claims, get information and collect tax Tax authorities should provide information to taxpayers – Text of treaties – Forms – Information required – Time limits Possibility of binding rulings or informal guidance 18 10 Persons Entitled to Treaty Benefits Residence determinations – “person”: relatively easy to determine – “resident” for Articles 23, 24(4) and (5): • Easy to determine as country applies its own domestic law – “resident” for most articles: determined under law of the other state • Resident certificates Dual residents Hybrid entities 19 Beneficial Owner Requirement for Articles 10, 11 and 12 Many issues and much uncertainty – International fiscal meaning or meaning under domestic law? (...) – Services performed in source country – PE, fixed base or time period Determination of income and imposition of tax – Problems with withholding (waivers) 28 15 Investment Income Same steps as for nonresidents generally Which article applies? – depends on character of payment Beneficial owner requirement for Articles 10, 11 and 12 Most countries use final withholding so that withholding agent is responsible for determining treaty benefits Article 13 (capital gains) presents special difficulties 29 Tax Avoidance and Tax Treaties Topic is covered in detail in Commentary on Article 1 Do tax treaties prevent the application of domestic anti-avoidance rules?
Language:English
Score: 1111919.2 - https://www.un.org/esa/ffd/wp-...0_Introduction_Arnold_Ault.pdf
Data Source: un
Now is the time to be crystal clear: we will prioritize clean cooking and call on member states, multilateral institutions, private sector, finance and civil society to join us in making clean cooking a priority, because: ➢ Clean cooking is beneficial for climate change and clean air. ➢ Clean cooking saves lives. ➢ Clean cooking is good for gender and development. (...) Prioritize access to clean cooking in national planning and policies, including energy planning, COVID economic recovery planning, and Nationally Determined Contributions to the Paris Agreement. 3. Provide international support to clean cooking transitions that reflect diverse users' needs and market conditions, including through making clean cooking a priority in climate finance. 4.
Language:English
Score: 1109154.4 - https://www.un.org/sites/un2.u...les_on_clean_cooking_25may.pdf
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 this context, it is necessary for treaty negotiators to determine, in view of the various characteristics of the different types of CIVs, if the generally applicable anti-abuse rules are sufficiently robust to avoid the use of CIVs as vehicles for treaty shopping, or if it is necessary to draft specific provisions dealing with CIVs. 2.
Language:English
Score: 1101566.6 - https://www.un.org/development...ective-Investment-Vehicles.pdf
Data Source: un
Extending the concept of beneficial ownership to other Articles of the UN Model 10. (...) This is the case, for instance, for the determination of the residence of a person, the determination of what is immovable property and of when income from corporate rights might be treated as a dividend. More generally, paragraph 2 of Article 3 makes domestic rules relevant for the purposes of determining the meaning of terms that are not defined in the treaty.
Language:English
Score: 1096124 - https://www.un.org/esa/ffd/wp-...ta-unmodel-RevisionToArt13.pdf
Data Source: un
“Regional and global value chains fragmented the production of goods and made the determination of origin a more complex exercise,” she noted. (...) Nevertheless, the business community cautioned that much work remains on making rules much easier for traders to understand and comply with in general. “For years we have been talking about the need to make rules of origin simple,” said  Martin Van Der Weide with the International Chamber of Commerce.
Language:English
Score: 1095817.6 - https://www.wto.org/english/ne...s_e/news20_e/roi_04mar20_e.htm
Data Source: un
Whether a business activity is substantial for the purposes of this paragraph shall be determined based on all the facts and circumstances. c) For purposes of applying this paragraph, activities conducted by connected persons with respect to a resident of a Contracting State shall be deemed to be conducted by such resident. 4. (...) Although these provisions apply regardless of whether or not a particular structure was adopted for treaty-shopping purposes, the Article allows the competent authority of a Contracting State to grant treaty benefits where the other provisions of the Article would otherwise deny these benefits but the competent authority determines that the structure did not have as one of its principal purposes the obtaining of benefits under the Convention. 6. (...) The tax authorities may, of course, on review, determine that the taxpayer has improperly interpreted the paragraph and is not entitled to the benefits claimed.”
Language:English
Score: 1095564.3 - https://www.un.org/esa/ffd/wp-.../14STM_CRP8_New-Article-29.pdf
Data Source: un
This is particularly important for the purposes of determining the object and purpose of the relevant provisions of the Convention. (...) All of the evidence must be weighted to determine whether it is reasonable to conclude that an arrangement or transaction was undertaken or arranged for such purpose. The determination requires reasonableness, suggesting that the possibility of different interpretations of the events must be objectively considered. 31.
Language:English
Score: 1092703.2 - https://www.un.org/esa/ffd/wp-...iscussion-draft-march-2014.pdf
Data Source: un