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: 724375.83
-
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: 706863.5
-
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: 699615.8
-
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: 697976.7
-
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: 694631.3
-
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: 694534.8
-
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: 691828.7
-
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: 689556.35
-
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: 688715.67
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https://www.un.org/esa/ffd/wp-...13STM_Presentation_Krysiak.pdf
Data Source: un
WHY ARE TIERED PRICES ECONOMICALLY FEASIBLE
If we look at what the cost of a product is composed of : 1) The most tiny part (often < 15 %) is
represented by the variable costs : * raw materials * packaging * variable utilities * direct labor * container
WHY ARE TIERED PRICES ECONOMICALLY FEASIBLE
The essence of the cost is represented by non variable costs :
Fixed production costs : * Staff * Industrial site management * Supervision * Site utilities * QC / QA * Maintenance * Industrial planning * Depreciation * Industrial engineering
R & D Administration costs
* Marketing & selling * Administration
And
The Profit
• THESE NON VARIABLE COSTS (INCLUDINGTHESE NON VARIABLE COSTS (INCLUDINGTHESE NON VARIABLE COSTS (INCLUDINGTHESE NON VARIABLE COSTS (INCLUDING PROFITS) CAN BE ARBITRARILY ALLOCATED,PROFITS) CAN BE ARBITRARILY ALLOCATED,PROFITS) CAN BE ARBITRARILY ALLOCATED,PROFITS) CAN BE ARBITRARILY ALLOCATED, WHICH EXPLAINS THE PRICING FLEXIBILITY.WHICH EXPLAINS THE PRICING FLEXIBILITY.WHICH EXPLAINS THE PRICING FLEXIBILITY.WHICH EXPLAINS THE PRICING FLEXIBILITY.
N.B.N.B.N.B.N.B.
1) This 1) This 1) This 1) This evolution evolution evolution evolution in in in in the the the the ratio direct ratio direct ratio direct ratio direct / indirect/ indirect/ indirect/ indirect costs is costs is costs is costs is one of one of one of one of the caracteristics the caracteristics the caracteristics the caracteristics of modernof modernof modernof modern economieseconomieseconomieseconomies
2) This trend 2) This trend 2) This trend 2) This trend would still be would still be would still be would still be more important ifmore important ifmore important ifmore important if we were considering we were considering we were considering we were considering distribution distribution distribution distribution costs andcosts andcosts andcosts and taxestaxestaxestaxes
0000
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Direct Costs
Indirect Costs of Production (fixed)
Administrative & Marketing Costs
R & D
PROFIT
0000
20202020
40404040
60606060
80808080
100100100100
120120120120
Industrial Countries
Direct Costs
Indirect Costs of Production
(Fixed)
Administrative & Marketing
Costs
R & D
Profit
Direct Costs
Indirect Costs of Production
(Fixed)
Administrative & Marketing costs
R & D
Profit
0000
20202020
40404040
60606060
80808080
100100100100
120120120120
Industrial Countries Developing Countries
Direct Costs
Indirect Costs of Production
(fixed)
Administrative & Marketing
Costs
R & D
Profit
Indirect Costs of Production
(fixed)
Administrative & Marketing Costs
R & D
Profit
Direct Costs Direct Costs
0000
20202020
40404040
60606060
80808080
100100100100
120120120120
Industrial Countries Developing Countries
Direct Costs
Indirect Costs of Production
(fixed)
Administrative & Marketing
Costs
R & D
Profit
Direct Costs Direct Costs Direct Costs
Indirect Costs of Production
(fixed) Indirect Costs of
Production (fixed)
Administrative & Marketing Costs
R & D
Profit
0000
20202020
40404040
60606060
80808080
100100100100
120120120120
Industrial Countries Developing Countries
Direct Costs
Indirect Costs of
Production (fixed)
Administra- tive & Marketing
Costs
R & D
Profit
Direct Costs Direct Costs
Indirect Costs of
Production (fixed)
Administrative & Marketing
Costs
R & D
Profit
Direct Costs
Indirect Costs of Production (Fixed)
FOR A COMPANY, IT IS POSSIBLE TO A LARGE EXTENT, TO IMPROVE THE GLOBAL PROFITABILITY IN SELLING ADDITIONAL QUANTITIES OF VACCINES AT A PRICE LESS THAN THE « FULLY LOADED COST »
THE FINANCIAL LIMITS OF THE SYSTEMTHE FINANCIAL LIMITS OF THE SYSTEMTHE FINANCIAL LIMITS OF THE SYSTEMTHE FINANCIAL LIMITS OF THE SYSTEM
Tiered prices Tiered prices Tiered prices Tiered prices have to have to have to have to rely rely rely rely on on on on the the the the existence of a existence of a existence of a existence of a solid marketsolid marketsolid marketsolid market in in in in industrial industrial industrial industrial countries countries countries countries
These principles can apply These principles can apply These principles can apply These principles can apply if if if if and when and when and when and when freefreefreefree production production production production capacitiescapacitiescapacitiescapacities do do do do existexistexistexist
In all In all In all In all otherotherotherother cases, cases, cases, cases, where where where where building up a newbuilding up a newbuilding up a newbuilding up a new production production production production capacity is necessarycapacity is necessarycapacity is necessarycapacity is necessary, the , the , the , the decisiondecisiondecisiondecision making process is subjectmaking process is subjectmaking process is subjectmaking process is subject to the to the to the to the regularregularregularregular allocation of allocation of allocation of allocation of resourcesresourcesresourcesresources....
And the profitability is generated only when theAnd the profitability is generated only when theAnd the profitability is generated only when theAnd the profitability is generated only when the financialfinancialfinancialfinancial and opportuniy costs and depreciationand opportuniy costs and depreciationand opportuniy costs and depreciationand opportuniy costs and depreciation are are are are coveredcoveredcoveredcovered....
Language:English
Score: 687458.35
-
https://www.wto.org/english/tr...presentations_e/16martin_e.pdf
Data Source: un
