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 If some interest expense is treated differently from other interest, have tax administrators been able to audit these deductions effectively? (...) 3) Are you familiar with, and do you think tax administrators in your country are familiar with, the typical legal structures for foreign investments in your country (whether FDI or portfolio investments)? Do these structures typically involve layers of offshore companies? Where are these companies typically located?
Language:English
Score: 1034613.2 - https://www.un.org/esa/ffd/wp-...uestions-IssuesDiscussions.pdf
Data Source: un
USE OF CENSUSES TO MONITOR THE MDGS—THE UGANDA CASE A typical population census is a good source of data for some of the Millennium Development Goals (MDGs). (...) Population censuses are very expensive exercises, and are undertaken once every 10 years (for most of the countries). (...) Capacity and resource g) Funding: Census undertaking is an expensive exercise, there is need to ensure sustainable funding for production of statistics to inform the SDGs.
Language:English
Score: 1032998.4 - https://www.un.org/en/developm...ShortNotes/Andrew%20Mukulu.pdf
Data Source: un
key is limit on foreign tax credit – Appropriate amount of interest should be allocated to foreign source income Domestic Law: Residents Earning Foreign Source Income Residents incurring interest expenses to acquires shares of foreign corporations – Are dividends from foreign corporations exempt or taxable? (...) Payments economically equivalent to interest 3. Expenses related to financing Up to each country Should be based on economic substance Doesn’t apply to deductible payments on deemed equity 18/11/2015 25 Entities Covered At a minimum, rules should apply to all entities that are part of a multinational group Optionally, rules can apply to members of a domestic group and/or standalone entities Application of rules to PEs and non- corporate entities? (...) Should rules be based on gross or net interest expenses? – Gross expense is simpler but causes risk of double tax with respect to entities that borrow and on-lend Should there be a de minimis rule?
Language:English
Score: 1029325.6 - https://www.un.org/esa/ffd/wp-...alPortfolioInterest_Arnold.pdf
Data Source: un
“ San Diego, 9-11 May 2006 4 ITU-T Typical Terminal settings: Personal PC, Headset, Web Camera PC Joint ITU-T Workshop and IMTC Forum 2006 “H.323, SIP: is H.325 next?“ San Diego, 9-11 May 2006 5 ITU-T Typical Terminal Settings: Group of 2-4 PC, In-expensive Mic/Speaker with EC, Web Camera Joint ITU-T Workshop and IMTC Forum 2006 “H.323, SIP: is H.325 next? (...) Phone: +81 45 651 7555 Fax: +81 45 224 6799 http://www.meetingplaza.com/ A Web Conference System Architecture for the Broadband Era Web Conference System/Service: Definition? A Typical Application:Meetings with branch offices and the head quarter Typical Terminal settings: Personal Typical Terminal Settings: Group of 2-4 Typical Terminal Setting: Group of 5+ Requirements on Networks What is important (user’s voices)?
Language:English
Score: 1026670.5 - https://www.itu.int/ITU-T/work...05/presentations/s1p8-kato.pdf
Data Source: un
Functional Cost Categories • Percentage Break Down of Operating Expenses 2. Functional Operating Expense Comparisons • Flight Operating Costs • Example: B-757 Operating Costs • Cost comparisons across aircraft types 3. (...) Airline Operating Costs • DOT Form 41 traffic, financial, and operating cost data reported to the DOT by US Major airlines – Data is reported and published quarterly for most tables – Detail of reporting differs for different expense categories • Aircraft operating expenses by aircraft type and region of operation • Other expenses more difficult to allocate by aircraft type • DOT Form 41 includes the following schedules: – P12 : Profit and Loss statement – P52 : Aircraft Operating Expenses – P6 : Operating Expenses by Objective Groupings – P7 : Operating Expenses by Functional Groupings – P10 : Employment Statistics – B1 : Balance Sheet 4 Objective Cost Categories • Salaries and related fringe benefits – General management, flight personnel, maintenance labor, aircraft & traffic handling personnel, other personnel • Materials purchased – Aircraft fuel & oil, maintenance materials, passenger food, other materials • Services purchased – Advertising & promotions, communications, insurance, outside maintenance, commissions, other services • Separate categories for: – Landing fees, rentals (including aircraft), depreciation (including aircraft), other expenses 5 Functional Cost Categories • Aircraft operating costs – Expenses associated with flying aircraft, also referred to as “Direct Operating Costs” (DOC) • Aircraft servicing costs – Handling aircraft on the ground, includes landing fees • Traffic service costs – Processing passengers, baggage and cargo at airports • Passenger service costs – Meals, flight attendants, in-flight services • Reservation and Sales costs – Airline reservations and ticket offices, travel agency commissions • Other costs, including: – Advertising and publicity expense – General and administrative expense 6 Total Airline Operating Cost Breakdown • US Major airline total operating costs : – 44% is aircraft operating expense, which includes fuel, direct maintenance, depreciation, and crew – 29% is servicing expense • Aircraft servicing (7%) • Traffic servicing (11%) • Passenger service (11%) – 14% is reservations and sales expense • This figure was 19.5% in 1993, but declined steadily throughout the 1990s – 13% is overhead expense • Advertising and Publicity (2%) • General and Administrative (6%) 7 Functional Cost Comparison • Adapted from Form 41, used by Boeing, MIT (and Aviation Daily) for more detailed comparisons FLIGHT (DIRECT) OPERATING COSTS (DOC) = 50% • All costs related to aircraft flying operations • Include pilots, fuel, maintenance, and aircraft ownership GROUND OPERATING COSTS = 30% • Servicing of passengers and aircraft at airport stations • Includes aircraft landing fees and reservations/sales charges SYSTEM OPERATING COSTS = 20% • Marketing, administrative and general overhead items • Includes in-flight services and ground equipment ownership • Percentages shown reflect historical “rules of thumb”. 8 Activity Drivers per Functional Category • Aircraft Operating Costs – Per Block Hour (for example, $2550 for 185-seat B757-200) • Aircraft Servicing Costs – Per Aircraft Departure (average $800) • Traffic Servicing Costs – Per Enplaned Passenger (average $15) • Passenger Servicing Costs – Per RPM (average $0.015) • Reservations and Sales Costs – % of Total Revenue (average 14%) • Other Indirect and System Overhead Costs – % of Total Operating Expense (average 13%) 9 Flight Operating Costs • Flight operating costs (FOC) by aircraft type: – Reflect an average allocation of system-wide costs per block hour, as reported by airlines for each aircraft type – Can be affected by specific airline network or operational patterns – Collected by US DOT as Form 41 operating data from airlines • Typical breakdown of FOC for US carrier: CREW: Pilot wages and benefits FUEL: Easiest to allocate and most clearly variable cost MAINTENANCE: Direct airframe and engine maintenance cost, plus “burden” or overhead (hangars and spare parts inventory) OWNERSHIP: Depreciation, leasing costs and insurance 10 Example: B757-200 FOC • Costs per block-hour of operations (avg. 186 seats): CREW $ 489 FUEL $ 548 MAINTENANCE $ 590 OWNERSHIP $ 923 TOTAL FOC $ 2550 per block-hr • Based on 1252 mile average stage length and 11.3 block-hr daily utilization (average for US Major): – Different stage lengths and utilization by different airlines result in substantial variations in block- hour costs for same aircraft type – Also, differences in crew costs (union contracts, seniority), maintenance costs (wage rates), and ownership costs (age of a/c) 11 Number of Seats FOC per FOC per Utilization Stage Length Airline Aircraft Block Hour Seat Hour (hrs/day) (Miles) American 101 188 2,568$ 13.66$ 10.3 1460 Continental 34 179 2,568$ 14.35$ 12.1 1860 Delta 101 182 2,357$ 12.95$ 11.6 984 America West 12 190 2,065$ 10.87$ 13.1 1167 Northwest 48 191 2,260$ 11.83$ 11.7 1137 Trans World Air 20 179 2,656$ 14.84$ 11.8 1405 United 98 186 2,684$ 14.43$ 11.2 1281 USAir 34 182 3,069$ 16.87$ 11.1 1254 AVERAGE 458 186 2,481$ 13.34$ 11.3 1252 Boeing 757‐200 Flight Operating Costs 12 Comparison of FOC Across Aircraft Types • All else being equal, larger aircraft should have highest flight operating cost per hour, lowest unit cost per ASM: – There exist some clear economies of aircraft size (e.g., two pilots for 100 and 400 seat aircraft, although paid at different rates) – Also economies of stage length, as fixed costs of taxi, take-off and landing are spread over longer flight distance • But, many other factors distort cost comparisons: – Pilots paid more for larger aircraft that fly international routes – Newer technology engines are more efficient, even on small planes – Reported depreciation costs are subject to accounting procedures – Aircraft utilization rates affect allocation of costs per block-hour 13 A/C Type Seats FOC / block-hr FOC / seat-hr Average stage(mi) Daily block-hrs DC9-30 100 $1973 $19.73 472 8.1 A320 148 $2270 $15.33 1191 11.7 B727-200 150 $2555 $17.03 704 8.4 B757-200 186 $2550 $13.71 1252 11.3 B747-400 375 $6455 $17.21 4065 12.4 FOC Comparison: Selected Aircraft 14 FOC Comparisons (cont’d) • Flight operating cost comparisons on previous slide provide insights into different aircraft characteristics: – Largest B747-400 aircraft has highest total FOC per block hour, while smallest DC9- 30 has highest FOC per seat hour, as expected – However, lowest cost per seat hour (and in turn per ASM) provided by new technology mid-sized B757, followed by A320 – B747-400 costs suffer from high wage rates paid to senior pilots who fly international services on this aircraft type – Comparisons of same-sized B727 and A320 show newer A320 with lower costs: • A320 more fuel efficient, with two pilots (vs 3 on B727) • A320 has higher daily utilization, due to longer stage length 15 Cost and Productivity Comparisons • Average unit cost for 8 selected majors increased from 9.15 to 9.53 cents (4%) between 1993-1999 • The top four major carriers have very similar unit costs in this time period • Unit cost increased dramatically between 1993 and 1999 for Continental (17%) and USAir (24%) • Southwest and America West had the lowest unit cost, while USAir had the highest unit cost 16 Unit Cost (Total System Operating Expense/ASM) 0.06 0.07 0.08 0.09 0.1 0.11 0.12 0.13 0.14 0.15 1992 1993 1994 1995 1996 1997 1998 1999 2000 Year U ni t C os t ( $/ A S M ) 8 Majors Average American Northwest Delta United 17 Unit Cost (Total System Operating Expense/ASM) 0.06 0.07 0.08 0.09 0.1 0.11 0.12 0.13 0.14 0.15 1992 1993 1994 1995 1996 1997 1998 1999 2000 Year U ni t C os t ( $/ A S M ) US Air 8 Majors Average America West Continental Southwest 18 Aircraft Productivity • Measured in ASMs generated per aircraft per day: = # departures X average stage length X # seats • Aircraft “utilization” measured in block-hours/day: – Block hours begin at door close (blocks away from wheels) to door open (blocks under wheels) – Gate-to-gate time, including ground taxi times • Increased aircraft productivity achieved with: – More flight departures per day, either through shorter turnaround (ground) times or off-peak departure times – Longer stage lengths (average stage length is positively correlated with increased aircraft utilization = block hours per day) – More seats in same aircraft type (no first class seating and/or tighter “seat pitch”) 19 Airline Flights per Day Block Hours Stage Length Seats ASMs Continental 3.9 8.3 719 104 291,246 United 4.3 7.5 564 109 264,284 Southwest 8.2 10.2 400 122 399,746 Example: Boeing 737‐500 Productivity 20 Airline Crew Fuel Maintena nce Owner ship Total Continental $510 $430 $651 $698 $2,291 United $927 $487 $1048 $510 $2,974 Southwest $388 $537 $251 $350 $1,526 Example: Boeing 737‐500 FOC per block hour 21 8 8.5 9 9.5 10 10.5 11 11.5 12 98-1 98-2 98-3 98-4 99-1 99-2 99-3 99-4 00-1 00-2 00-3 00-4 01-1 01-2 01-3 01-4 02-1 02-2 B lo ck H ou rs /D ay AA UA DL WN Daily Aircraft Utilization (block‐hrs/day) Top 3 Majors and Southwest 22 0.03 0.035 0.04 0.045 0.05 0.055 1998 1 1998 2 1998 3 1998 4 1999 1 1999 2 1999 3 1999 4 2000 1 2000 2 2000 3 2000 4 2001 1 2001 2 2001 3 2001 4 2002 1 2002 2 $/ A SM AA UA DL W N Unit Aircraft Operating Cost ($/ASM) 23 • Measured in ASMs per employee per period • As with aircraft, employee productivity should be higher with: – Longer stage lengths (amount of aircraft and traffic servicing for each flight departure not proportional to stage length) – Larger aircraft sizes (economies of scale in labor required per seat for each flight departure) – Increased aircraft productivity due to shorter turnaround times (more ASMs generated by aircraft contribute to positive employee productivity measures) • Yet, network airlines with long stage lengths and large aircraft have lower employee productivity rates Employee Productivity 24 ASMs/employee and Average Stage Length 25 ASMs/employee and Average A/C Size 26 Summary: Costs and Productivity Challenges • Unit cost differences not entirely due to labor costs: – Differences in aircraft productivity can account for up to one half of difference in aircraft operating expenses per ASM – Translates into about 25% of total unit cost difference between traditional carriers and LCCs • Network carriers are exploring alternatives for increasing aircraft productivity to reduce unit costs: – Continuous connecting banks to reduce ground times at hubs – Higher density seating options (e.g. removal of First Class) – More “point-to-point” flying to increase aircraft utilization • Successful new “business models” will depend on reducing both aircraft and labor unit costs – In addition to fine-tuning fare structures to maximize unit revenues 27 https://www4.icao.int/newdataplus
Language:English
Score: 1021383.5 - https://www.icao.int/MID/Docum...costs%20and%20productivity.pdf
Data Source: un
Improper characterization of income or expense items 105. Tax may be reduced by improperly characterizing an income or expense item in order to make use of an exemption or reduced rate. vi. (...) Improper allocation of expenses 109. When a foreign corporation operates both within and without a country, it often must allocate certain expenses between its branch operations within the country. (...) Other expenses creating problems of allocation include head office expenses, certain legal fees, deductible charitable contributions and certain taxes. b.
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Score: 1020482.2 - https://www.un.org/esa/ffd/wp-...STM_CRP11_Add1_Tax-Evasion.pdf
Data Source: un
– In the case of MNOs, retail customers do not completely factor in the price paid by those who call them when deciding which MNO to subscribe to – • there exists a CPP externality between subscribers and those who call them • But for a common economic group (e.g. a household or a company), this externality is internalised – Ability to Solve Disputes • Reasons not to Regulate; – IC Revenues are Important – Especially in the First Years – Regulation is Expensive Per Se – Only last solution How to Regulate • Reciprocal or Asymmetry? (...) Hurricanes – High network build and operating costs: • Supplier Network engineers and designers are flown in on expensive Expat contracts in order to build a mobile network • A similar situation is typical in regard to on-going operations Why would termination prices be different in different countries?
Language:English
Score: 1017114.6 - https://www.itu.int/ITU-D/fina...e_termination_Jan_Tjernell.pdf
Data Source: un
Participants must be medically fit and in possession of medical insurance coverage to meet expenses for any sickness or medical emergency during your stay in Thailand. 4.3 There are no restrictions on import of foreign currency. (...) The Bangkok Mass Transit Authority operates Airport Bus service to the city centre. 5.3 When departing, the hotel can arrange for transportation to the airport, at the expense of the participant. Public taxis, which are less expensive than hotel taxis, are also available. (...) At restaurants, a tip of about 10% is expected unless a service charge has been added to the bill. 6.6 Although the tap water in Bangkok is chemically treated, it is recommended to drink only bottled water and beverages. 6.7 The type of electrical plug and socket typically used in Thailand is two parallel prongs: — END — http://www.tmd.go.th/ http://www.koh-chang.cz/images/zasuvka_thai.jpg
Language:English
Score: 1016221.1 - https://www.icao.int/APAC/Meet...-%204%20Att%20C%20Bulletin.pdf
Data Source: un
Participants must be medically fit and in possession of medical insurance coverage to meet expenses for any sickness or medical emergency during your stay in Thailand. 4.3 There are no restrictions on import of foreign currency. (...) The Bangkok Mass Transit Authority operates Airport Bus service to the city centre. 5.3 When departing, the hotel can arrange for transportation to the airport, at the expense of the participant. Public taxis, which are less expensive than hotel taxis, are also available. (...) At restaurants, a tip of about 10% is expected unless a service charge has been added to the bill. 6.6 Although the tap water in Bangkok is chemically treated, it is recommended to drink only bottled water and beverages. 6.7 The type of electrical plug and socket typically used in Thailand is two parallel prongs: — END — http://www.tmd.go.th/
Language:English
Score: 1016221.1 - https://www.icao.int/APAC/Meet...T3/5.%20Meeting%20Bulletin.pdf
Data Source: un
Food and transportation costs during the trip as well as personal expenses shall be borne by the winners. It is important to highlight that the awards are non-transferable, cannot be redeemed for cash and cannot be substituted for other awards. 10. (...) However if you do so, he/she will have to bear all the expenses of the trip. UNIDO will not facilitate any kind of assistance. 14. What is the weather like in Vienna? Vienna has a typical continental climate, with hot summers and cold winters.
Language:English
Score: 1016221.1 - https://www.unido.org/sites/de...016.Essaycompetition_FAQ_0.pdf
Data Source: un