In accordance with former Staff Regulation 1.2(m), a
conflict of interest exists even if there is only a possibility that a staff member could
benefit from an association with any profit-making or transactions due to his or her
official position with the Organization. (...) The prohibition on staff members becoming
involved in businesses or activities which may give rise to a conflict of interest is set out
in former Staff Regulation 1.2(m) (in force at the time of the events, the subject matter of
the present case) as follows:
Staff members shall not be actively associated with the management of, or hold a
financial interest in, any profit making business or other concern, if it were
possible for the staff member or the profit making, business or other concern to
benefit from such association or financial interest by reason of his or her position
with the United Nations.
(...) Akello likely obtained personal gain from the company’s profits derived
from the provision of services to the Organization.
Language:English
Score: 737121.7
-
www.un.org/en/internalj...at/judgments/2013-UNAT-336.pdf
Data Source: oaj
€ 7,500 Gross profit € ? € 2,500 Operating expenses € 2,000 € 2,000 Operating profit € ? (...) “Operating profit” is a better term than “net profit”, because net profit is also used to represent the profit of a company after interest and taxes have been subtracted.
(...) The TNMM is applied and the profit level indicator is the operating profit margin.
Language:English
Score: 721363.2
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https://www.un.org/esa/ffd/wp-...oads/2014/10/6STM_CRP4_Ch5.pdf
Data Source: un
GENERAL PROVISIONS
Article 1
This Law introduces profit tax and governs the manner of profit taxation.
Article 2
The profit tax rate shall be proportionate.
Article 3
Each taxpayer shall compute and pay the profit tax.
(...) Article 7
A natural person that performs a registered activity and pays personal income tax in a lump sum shall be exempted from profit tax.
III. TAX BASE
Article 8
The base for computation of profit tax shall be the profit shown in the tax balance.
Language:English
Score: 714272.56
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https://www.wto.org/english/th...cc_e/mkd_e/WTACCMKD6_LEG_6.pdf
Data Source: un
When the US adopted the `comparable profit method’ (CPM) and profit split
in the 1994 transfer pricing regulations, some countries objected that it was
6 Le Gall JP. (2007) The David R. (...) The US has always maintained that both CPM and profit
split satisfy the arm’s length standard despite the lack of precise comparables
(and in the case of profit split, using no comparables at all to allocate any
residual profits). (...) Otherwise,
profits would be “attributed” to the PE that have nothing to do with it,
because the PE is not engaged in the activity that generates these profits.
Language:English
Score: 712766.94
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https://www.un.org/esa/ffd/wp-...014/10/ta-tp-CommentsAYZPT.pdf
Data Source: un
Gross profit is defined as Net Sales minus Cost of Goods Sold.
6.2.6.3. (...) Gross profit is defined as net sales minus cost of goods sold. (...) By comparison, the application of the transactional net margin method, which analyses a financial ratio based on operating profits, will generally result in an arm’s length range of positive operating profits.
Language:English
Score: 709542.43
-
https://www.un.org/esa/ffd/wp-...ethods_20120924_v7_HC-accp.pdf
Data Source: un
Gross profit is defined as Net
Sales minus Cost of Goods Sold.
(...) Gross profit is defined as sales minus cost of goods sold.
(...) The unadjusted gross profit mark‐ups of
these comparables are thus not calculated similar to the gross profit mark‐up of Associated
Enterprise 1.
Language:English
Score: 709438.6
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https://www.un.org/esa/ffd/wp-.../ta-tp-Oct2011_TP_Chapter5.pdf
Data Source: un
The profits covered consist in the first place of the profits obtained by the
enterprise from the carriage of passengers or cargo. (...) The Commentary notes as follows:
5. Profits obtained by leasing a ship or aircraft on charter fully equipped,
mannedcrewed and supplied must be treated like the profits from the carriage of
passengers or cargo. (...) Thus the paragraph does not apply to the taxation of
profits from the operation of ships in international traffic but does apply to the taxation of
profits from the operation of aircraft in international traffic.
Language:English
Score: 706718.1
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https://www.un.org/esa/ffd/wp-...sport_Arts3and8_Commentary.pdf
Data Source: un
Gross profit is defined as Net Sales minus Cost of Goods Sold.
(...) B.3.2.7. Arm’s Length Gross Profit Margin
B.3.2.7.1. The financial ratio analysed under the Resale Price Method is the gross profit margin. Gross profit is defined as net sales minus cost of goods sold.
Language:English
Score: 704622.75
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https://www.un.org/esa/ffd/wp-..._Methods_20161127_v7_clean.pdf
Data Source: un
The profits covered consist in the first place of the profits obtained by the enterprise from the carriage of passengers or cargo. (...) The provision therefore covers other classes of profits as well, i.e. those which by reason of their nature or their close relationship with the profits directly obtained from transport may all be placed in a single category. (...) The Commentary notes as follows:
5. Profits obtained by leasing a ship or aircraft on charter fully equipped, mannedcrewed and supplied must be treated like the profits from the carriage of passengers or cargo.
Language:English
Score: 703573.24
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https://www.un.org/esa/ffd/wp-...13STM_Presentation_Krysiak.pdf
Data Source: un
Microsoft Word - BEPS comments Bangladesh.docx
Answers from Bangladesh to the questionnaire set by the UN about Base Erosion and Profit Shifting.
1.Q. How does base erosion and profit shifting affect Bangladesh?
(...) These include profit shifting through supply chain restructuring that contractually re-allocates risks, and associated profit to
affiliated companies in low tax jurisdictions. (...) Unfortunately Bangladesh has no scientific method to determine the exact profit of an MNE, whether is has reported its profit correctly.
Language:English
Score: 702203.96
-
https://www.un.org/esa/ffd/wp-...ta-BEPS-CommentsBangladesh.pdf
Data Source: un
