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TRANSFER PRICING PRACTICAL MANUAL FOR DEVELOPING COUNTRIES : NOTE / BY THE SECRETARIAT
Table of main differences and possible uses of different Methods ........................................ 31 f. Flowchart of a typical transfer pricing scenario (with non-typical extensions) ..................... 31 g. (...) o Develop solutions (administrative, legislative etc) for typical problems (see for example Mexican example of dealing with maquiladores) • Internal process: role of TP-unit - Options (also depending on life cycle): o advice only o compulsory consultation o TP-unit will take over case handling E/C.18/2009/5 1709-45183 (C) • Case selection process, some options: o risk rating system (refer to chapter on risk assessment) o random o based on internal information o building up knowledge of your most important clients (international structure, global stream of transactions, high level idea of functions performed, financial statement analysis) • Additional issues and attitude-shifting: o retrospective: audit focused on adjustments with risk of lot of MAPs (especially with transactions with large number of countries) o prospective: adjustments limited to clear cut cases, in other situation strive for good future solution together with taxpayer. (...) Country specific practices - Benchmarking/Pre-determined Rates of Return (e.g. Brazil) iv. Typical cases – examples v. Specific industries - examples Transfer Pricing Adjustments and Penalties • Refer to specific chapter covering this topic, but provide summary of: • Use/type of adjustments o Primary o Secondary o Corresponding • Penalties o Base - shortfall (tax or taxable income)?
语言:中文
得分: 1215404.3 - daccess-ods.un.org/acce...t?open&DS=E/C.18/2009/5&Lang=C
数据资源: ods
REPORT OF THE SPECIAL RAPPORTEUR ON THE SITUATION OF HUMAN RIGHTS DEFENDERS ON HIS MISSION TO BURUNDI : NOTE / BY THE SECRETARIAT
The Special Rapporteur notes a number of serious incidents related to restrictions on freedom of expression in Burundi. A typical case in this respect i s that of Pierre Claver Mbonimpa, the President of the Association burundaise pour la protection des droits humains. (...) He was, however, banned from leaving the capital. 77. Another typical case is that of Faustin Ndikumana, the President of Parole et action pour le réveil des consciences et l’évolution des mentalités.
语言:中文
得分: 1029598.7 - https://daccess-ods.un.org/acc...en&DS=A/HRC/31/55/ADD.2&Lang=C
数据资源: ods
LETTER DATED 2007/06/18 FROM THE PERMANENT REPRESENTATIVE OF THE DEMOCRATIC PEOPLE'S REPUBLIC OF KOREA TO THE UNITED NATIONS OFFICE AT GENEVA ADDRESSED TO THE PRESIDENT OF THE HUMAN RIGHTS COUNCIL
These acts based on illegitimate last year’s GA “resolution” on DPRK remain illegitimate and unjust as well. This is a typical example of politicization, selectivity and double-standards selecting a specific country for purposes other than human rights and will inevitably lead the Council to a tragic fate of the former Commission.
语言:中文
得分: 991887.3 - daccess-ods.un.org/acce...et?open&DS=A/HRC/5/G/11&Lang=C
数据资源: ods
LETTER FROM THE DEMOCRATIC PEOPLE'S REPUBLIC OF KOREA CONCERNING THE REPORT OF THE SPECIAL RAPPORTEUR ON THE SITUATION OF HUMAN RIGHTS IN THE DEMOCRATIC PEOPLE'S REPUBLIC OF KOREA, GENEVA, 29 JANUARY 2009
This will inevitably lead to the damage of the credibility and the weakness of the operation of the UPR mechanism. This is a typical manifestation of politicization, selectivity and double standards and runs counter to the founding ideals of the Human Rights Council to conduct activities based on dialogue and cooperation.
语言:中文
得分: 980028.6 - daccess-ods.un.org/acce...et?open&DS=A/HRC/10/G/6&Lang=C
数据资源: ods
LETTER DATED 2010/01/21 FROM THE PERMANENT MISSION OF THE DEMOCRATIC PEOPLE'S REPUBLIC OF KOREA TO THE UNITED NATIONS OFFICE AT GENEVA ADDRESSED TO THE PRESIDENT OF THE HUMAN RIGHTS COUNCIL
Country-specific procedures including the “special rapporteur” which is a typical manifestation of politicization, selectivity and double standards continues to remain.
语言:中文
得分: 968450.1 - daccess-ods.un.org/acce...et?open&DS=A/HRC/13/G/7&Lang=C
数据资源: ods
NOTE VERBALE DATED 10 JUNE 2011 FROM THE PERMANENT MISSION OF AZERBAIJAN TO THE UNITED NATIONS OFFICE AND OTHER INTERNATIONAL ORGANIZATIONS IN GENEVA ADDRESSED TO THE PRESIDENT OF THE HUMAN RIGHTS COUNCIL
In the course of the examination it was established that the injuries which caused F.Badalov’s death are typical in cases involving shots of this kind from sniper weapons.
语言:中文
得分: 946094.7 - daccess-ods.un.org/acce...t?open&DS=A/HRC/17/G/11&Lang=C
数据资源: ods
LETTER DATED 4 MAY 2017 FROM THE SECRETARY-GENERAL ADDRESSED TO THE PRESIDENT OF THE SECURITY COUNCIL
As indicated in the medical notes and records, it is assessed that this is likely due to lack of movement by the casualty at some point. 5.21 Early photos of the casualties’ injuries show blisters on the arms, which are typical of sulfur mustard injuries. Picture 1. Provided by authorities of the Syrian Arab Republic. 5.22 Photos taken by the FFM of the patients several months after the reported incident in Hospital 601 show both typical and atypical signs of exposure to sulfur mustard. (...) Some of these scars do appear similar to thermal burns; however, it is possibly due to inadequate treatment. 5.25 The casualties described losing vision with gradual restoration of sight and a burning sensation in the eyes, which is typical for sulfur mustard exposure; however, there was no indication of blepharitis, which is a common condition. 5.26 Both patients complained of some shortness of breath and tightness in the chest. 5.27 Overall, the history, presentation of the casualties, and subsequent treatment appears to be consistent with exposure to sulfur mustard.
语言:中文
得分: 913544 - https://daccess-ods.un.org/acc.../get?open&DS=S/2017/400&Lang=C
数据资源: ods
NOTE VERBALE DATED 2007/09/11 FROM THE PERMANENT MISSION OF THE REPUBLIC OF ARMENIA TO THE UNITED NATIONS OFFICE AT GENEVA ADDRESSED TO THE PRESIDENT OF THE HUMAN RIGHTS COUNCIL
GE_ 07-14090 (C) 170907 170907 A/IˉIRC/6/G/8 Page 2 Annex P6_TA (Z006)0069 Cultural heritage in Azerbaijan European Parliament resolution on cultural heritage in Azerbaijan N 妯 T阮E E脚厂口Z】E况邝 P况厂ZZ况阴E邝Z, having regard to its resolutions of 9 Iune ZOOSI and 27 October ZOOSZ On Azerbaijan, having regafd to its resolution of 19 Ianuary 2006 On 迂le European Neighbourhood P0licy,3 having regard to its Previous resolutions on 迂le Sou由 Caucasus and, in Particular, its resolution of 11 March 1999 On Support fof the Peace Process in 迂le CaucaSuS4 and its recommendation to the Council of 26 February 2004 On EU Policy towards the South CaucaSuS,5 having regard to the Council decision of 14 Iune 2004 to include both Armenia and Azerbaijan in 迂le European Neighbourhood P0licy, in Particular for the Purpose of fostering good neighbourly relatiOnS, especially 迂lrough respect for Inin0ritieS, having regard to the Obligations of Armenia and Azerbaijan Wi迂lin 迂le framework of the Council of EurOPe, especially 迂lrough 迂le European Cultural C0nVentiOn, the revised European Convention for the Protection of Archaeological Heritage, and 迂le FraIneWOrk Convention for the Protection of National Min0ritieS, Which they have ratified and undertaken to reSPec[, having regard to the UNESCO l9S4 Hague Convention for 迂le Protection of Cultural Property in the Event of Armed Conflict and its l9S4 Pr0tOcOl, as applicable to occupied territOrieS, to Which both Armenia and Azerbaijan are party, TExZ A绪口癣ZE绪, P6_TA(ZO0S)0Z43_ TExZ A绪口癣ZE绪, P6_TA(ZO0S)04l 1_ TExZ A绪口癣ZE绪, P6_TA(Z006)00Z8_ O_T C l7S, Zl.6_l999, P_ ZSI_ O_T C 98 E, Z3_4_Z004, P_ 193_ A/IˉIRC/6/ G/ 8 Page 3 一 having regard to 迂le 2003 UNESCO Declaration concerning 迂le Illtentional Destruction of Cultural Heri[age, by Which the international community recognises the importance of tl〕e protection of cultural heritage and reaffirms its commitment to combat its intentional destruction in any form S0 that Such cultural heritage Inay be transmitted to 迂le Succeeding generatiOnS, 一 having regard to 迂le report of the International Council of Monuments and Sites (ICOMOS)6 and the UN Committee for Human Rightsl intermediary report on freedom of Worship and religi0n,7 一 having regard to Rule llS(S) of its Rules of PrOcedure, A_ Whereas allegations have been Inade by Afmenia that campaigns to destroy 迂le Armenian cemetery at Djulfa in the region of Nal出ichevan Were carried Out by Azerbaijani forces in November 1998 and December 2002; Whereas the Inost recent destruction took Place in December ZO0S, as evidenced by Video footage taken by 迂le Armenian auth0ritieS, B_ Whereas 迂lere Were numerous reactions by 迂le international community to these actions二 Whereas Azerbaijan has Ilot provided answers to inquiries by Mr Abdelfattah Am0r, 迂le former Special rapporteur of the United NatiOnS, concerning 迂le events of November 1998 and December ZO0Z, C_ Whereas Serious allegations have been raised about the involvement of 迂le Azerbaijani authorities in the destruction of these In0nuInen[S, D_ underlining 迂le exceptional nature of the Djulfa ceInetery, Which Still had 6 000 滢苑况zC苑滢况厂S (crosses carved in Stone typical of Armenian religious art) remaining and Which testifies to 迂le e迂lnic and cultural diversity of 迂le regiOn, E. (...) Introduction and historical background It has been brought to the attention of 迂le Signatories of this Memorandum that Since 1998 迂le Afmenian archaeological complex of Iugha (of Iulfa in Persian) in the Autonomous Republic of Nal爻hijevan (/茱zerbaijan) has been Systematically Submitted to Willful destruction and 由at betWeen December ZOOS and March 2006 it has been definitively destroyed by members of Azerbaijan,S military forces_ Located in 迂le border area between Ifan and Na1(hijeVan, to 迂le West of the ruined city of Iugha, on a hill divided by 迂lree Small ValleyS, 由is cemetery Was culturally and historically a unique testimony of Afmenian Presence in 迂le region_ With originally Inore than l0,000 Inemorial Stelae, it constituted the largest collection of Afmenian tombstones and cross一stones (滢阮况ZC阮滢况厂S), Inany of them bearing Philologically relevant inscriptions_ They covered a Period from the early Middle Ages (Slh century) until the early l7th century_ Most ZC阮况ZC阮滢况厂S date from the lSIh and l6Ih centuries and represent a Style Which is at tl〕e Same time typical for 迂le region Nal爻hijevan and for Armenian craftsmanship of 迂le late Middle Ages_ The historical Armenian Provinces of Sha_haPOnk, Yernjak and Goghtn are Situated in a territory 迂lat is now known as 迂le Autonomous Republic of Nal爻hijevan in the Republic of Azerbaijan_ The former city of _Tugha is Situated in Yernjal〈, On 迂le left bank of the river AraXeS, Which today defines [he border betWeen Iran and Na1(hijeVan_ Already in the 7Ih century AD Iugha Was a famous Settlement_ During 迂le l0一l3Ih centuries it developed into a t0Wn, and eVentually, during the lS一l7Ih centurieS, became an important trading centre for the entire South Caucasian region_ When in l60S the Ifanian Shah Abbas retreated after having been defeated by the Ottoman f0rceS, he deported the entire regional Afmenian Population of 迂le Iugha borderland into Iran Wi迂1 迂le intention to leave a depopulated and devastated area behind him二 a Positive consequence of 迂lis cruel eviction Was the improvement of c0InInerce, arts and manufacturing in Iran by 迂le neW Armenian Settlers_ The depopulated city of _Tugha Was Partially destroyed by 迂le Iranian forces_ Ye[, the eighteen ancient churches of _Tugha, as Well as the ruins of a Inagnificently built bridge, 迂le caraVanSerai, 迂le covered market, Inany Public and private h0uSeS, and a number of Scattered headstones in 迂le ceInetery, remained 迂le Silent, but expressive Witnesses of History_ The Wide range of Surviving building types and the historical complex of the t0Wn told 迂le history of the People and their architecture_ It Was a life一Size Inuseum 一 an irreplaceable cultural documentation of humanity_ A旧RC/ 6/G/ 8 Page 6 Having Survived Inassacres and expulsions of tl〕e indigenous Armenian Population in tl〕e early l7Ih century, 由is Outstanding Site had been repeatedly attacked and ruined during the Zolh century, in particular during Russian railWay constructions in l903一l904 and after 迂le final Inassacre and expulsion of the Armenians of Nal出ijevan in l9l9一l9ZZ_ II1 l9Z8一l9Z9, 由ere Were Still up to 3,000 疫阮况ZC阮ZC况厂S and a few 迂lousand flat, tW0一edged, cap一Shaped tombstones_ TT1e French _Tesuit missionary AleXand工e de Rh0deS, during his travel in l648, described the cemetery of Iugha and registered about ten thousand eXiSting, Standing and Well一preserved 疫苑况ZC阮疫况厂S_ II1 l903一l904 a railroad Was built near 迂le Russian border二 Inany headstones Were then irreversibly damaged of destroyed_ H0WeVer, approximately 6,000 headstones remained lntact_ II1 l9lS, 迂le photographer Afam Vruyr, and after him 迂le historian S_ Ter一AVetiSSian, in l938一l939, counted and documented Some tomb一stones Which had been cut Obliquely二 this Sh0WS 迂lat Inany of 由ese headstones had been intentionally broken already in tl〕e Soviet Period_ Z.
语言:中文
得分: 911226.5 - daccess-ods.un.org/acce...get?open&DS=A/HRC/6/G/8&Lang=C
数据资源: ods
《关于禁止�
This project chose some typical biological laboratories of different types and levels to play an exemplary role in the purpose of enhancing biosafety capacity building and management of laboratories nationwide. 6.
语言:中文
得分: 884820.4 - daccess-ods.un.org/acce...S=BWC/MSP/2008/MX/WP.19&Lang=C
数据资源: ods
EXTRAJUDICIAL, SUMMARY OR ARBITRARY EXECUTIONS : REPORT OF THE SPECIAL RAPPORTEUR, PHILIP ALSTON : ADDENDUM
But statistical data recording systemic pathologies are no substitute for the vivid details of reasonably typical cases. Thus this report begins by illustrating the major current concerns through four recent case studies. (...) The case looked very typical of many reported by the police in Nigeria. 9. (...) This scenario is illustrated in two, apparently all too typical, cases. In the first, two boys44 were arrested by police in Nsukka, Enugu state.
语言:中文
得分: 875623.4 - daccess-ods.un.org/acce...DS=E/CN.4/2006/53/ADD.4&Lang=C
数据资源: ods