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Giving up smoking is a serious business – but the focus is on fun throughout Greater Glasgow today when NHS Greater Glasgow celebrates No Smoking Day.
Smoking is the biggest single preventable cause of premature death in Glasgow, where one in five people die because of their smoking habit.
This year NHS Greater Glasgow is mounting its biggest-ever drive to help local smokers quit – and No Smoking Day kicks off a series of initiatives in the city and beyond over the next few weeks to assist smokers give up tobacco.
One of the main activities in Glasgow today is a day-long event at St Enoch Centre to promote the wide range of help and advice available at local pharmacies, which includes access to free or low-cost Nicotine Replacement Therapy (NRT) patches on the NHS directly from pharmacies – without the need to go to a doctor or nurse for an NHS prescription.
Radio Clyde DJ George Bowie is visiting the stand in St Enoch Centre to lend his support, and staff from NHS Greater Glasgow's Pharmacy Health Promotion and Smoking Concerns – NHS Greater Glasgow's specialist tobacco project – are offering prizes and incentives to smokers pledging to quit, including nicotine patches, T-shirts, hats, umbrellas, pens, caps, clocks and toothbrushes. And for those who decide to take the plunge, there'll be the option of smokelyser tests to measure carbon monoxide levels in their blood.
A team of pharmacists specially trained in smoking cessation are on hand to deliver specialist advice throughout the day, from 10am to 3.30pm, and will refer clients to community pharmacies for continued support closer to home.
Quitters' packs are also being handed out along with lists of pharmacies participating in the direct supply scheme– and even "begging letters" for children to hand to mums, dads, and other loved ones they want to see stop smoking.
A total of £10,000 worth of promotional items, ranging from balloons, T-shirts, umbrellas, leaflets and stickers is being distributed throughout the area by Smoking Concerns, NHS Greater Glasgow's specialist tobacco project, to coincide with No Smoking Day.
It's anticipated that more than 100 localised events, organised mainly through frontline NHS staff in the area's Local Health Care Co-operative (LHCCs), will be held in various parts of Greater Glasgow today.
Meanwhile, workers in more than 200 Glasgow workplaces – all businesses signed up to the Scotland's Health at Work (SHAW) award scheme –are being encouraged to stub out smoking through a variety of No Smoking Events, including competitions, lucky dips and health fairs.
"We know that giving up smoking can be very difficult and that's why we are expanding our frontline services. We want more people to take advantage of what's on offer to help them stop. The No Smoking Day events here will highlight in a fun way what can be done to tackle what is a deadly serious health issue for many people."
"Nearly 38% of the population in the NHS Greater Glasgow area are smokers but stopping smoking is the single most effective way of improving your health.
For more information on stopping smoking, contact Smoking Concerns on 0141 201 9825.
Today's No Smoking Day events in Greater Glasgow are part of a wider campaign to encourage local smokers to quit.
Next month (April 2003), NHS Greater Glasgow launches its biggest ever stop-smoking campaign with the help of local pharmacists and smoking cessation groups in 15 Local Health Care Cooperatives(LHCCs).
Smokers will be able to pop into pharmacies throughout Greater Glasgow participating in the scheme to provide free or low-cost Nicotine Replacement Therapy patches on the NHS plus advice on how to quit, without having to go to a GP or nurse for an NHS prescription.
Meanwhile, LHCC smoking cessation groups will provide smokers with intensive support to give up smoking. Contact Smoking Concerns on 0141 201 9825 for details of nearest groups.
Smoking kills 13,000 Scots per year and half of all lifelong smokers die prematurely, losing on average seven or eight years of life.
Annual inpatient costs of NHS Greater Glasgow because of illnesses related to smoking run to an estimated £14.44 million.
Media inquiries: Communications Office, NHS Greater Glasgow tel 0141 201 4429.


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America’s structure of government was established, initially, as a check and balance utility, specifically designed to counter the inherent corruptive nature of man. As we all learned in civics class, it was the Constitution of 1787 that documented the operating basis of the existing federal government. In the beginning the signers for ratification believed, despite the endorsement of a federal system that the Constitution was a document specifically written with the explicit purpose of limiting the power of the federal government. Witnessed, rather adamantly at the time by Rode Island, wherein these islanders, as a requirement of ratification, insisted that The Bill of Rights be the Constitution’s first amendment. In other words, there was enough evidence to suggest that the Constitution was designed as an implicit imposition upon government. It is my supposition that (at the time) this covenant of implicit imposition was considered definitive, material, and interminable. As proof of my confidence in this supposition, I submit that without passage of The Bill of Rights (the first ten amendments to the Constitution) there would be no Constitution.
The original signers of the Constitution imagined the possibility of a draconian federal government; they therefore set in place certain check and balances to curtail such encroachments. But they could not have imagined the 16th amendment (individual income tax) to the Constitution. Nor could they have subsequently imagined a federal government empowered not only to tax but to distribute the bounty of such taxation to states with terms and conditions set not by congress but by regulators. These are the very same regulators who work directly for the executive branch of the federal government.
The power to tax is in unison the power to distribute; such a symbiosis is the fundamental of absolute power. All of the issues regarding the curtailing of individual rights and freedoms stem from the derivatives and collaterals associated to and from the power to tax and distribute. Taxation, distribution of what is harvested from taxation, and political power all run concurrent to a gargantuan governmental enterprise – these concurrent expressive(s) also make up the DNA of a socialistic style of governing.
If there is a constant that is formidable and steadfast in this modern world, it is the constant of change. Conversely, if there is one tangible of enduring perpetuity, the one dependable status quo, it is the lust for political power. This lust for political power is intrinsic to human nature and inherent to operating systems. Remembering that power, even the one that serves the so called common good, is to be feared, its propagation is, by nature, insidious; power is also amoral, apathetic, and – most important to understand – insatiable. Political power is a force that, while seemingly or indeed is creating good results on the one hand, often enough, is resulting in unintended consequences on the other. Political power exercised by either party is not to be trusted; such power must constantly be monitored by an independent press and looked upon with askance.
It is understood that power is a prima facie of all governments; but power is also the blunting instrument used by all politicians when items of beneficial significance or the soft sell efforts fail to achieve their goal. The struggle for the attainment and retaining of power is the contextual of history. Political power is so omnipotent that it has prompted one to lie, cheat, steal, and murder. Millions upon millions of dollars are spent on political campaigns because political power is the sublime of positioning; in contrast, the loss of political power positions the counter party as the character of ignominious dismissal.
Those in government, elected or appointed, Democrat or Republican, are interested in broadening their platform of political influence. As a consequence, most politicians, because we do not have a federal term limit, are in favor of a bigger, larger, wider, deeper government. It is therefore predetermined that government will grow; not just in size but in ambiguity, political contrivance, and duplicity.
Subsequently, by means statutory and lawful, extralegal, and piratical, those with political power will strive to subdue, restrict, or limit any and all that is perceived as an obstacle or hindrance to their exercise of power. Those outside of such power will strive to attain political power; the cycle is self-perpetuating and as ancient as the City of Ur.
The current affairs of congress are a perfect example of politicians jockeying for the power position; each surveying the possibilities, each trying to pick the winner in the upcoming horse race. Mr. Powerful has survived his most recent outcry of “stupidly” by the chicanery of hosting a beer drinking babbling moment, wherein all main characters in the Cambridge melodrama showed up for reasons unclear. The House of Representatives actually believes that the federal ‘cash for clunkers’ program is a stimulus worthy for more cash investment – two billion dollars more is the present goal. Paying citizens to drag in their cars to have the federal government (another word for taxpayer) pay them $4,500 for a car that is worth substantially less is the perfect instance of outright clinical insanity. If such a program is considered a success, why not pay people to trade their computers, bicycles, cell phones, old clothes for new; let’s have every American home owner, at the government’s expense, turn their home ‘green’.
It is all about political power; policy has been downgraded from substance to Public Relations Theater; such is motorized not by sensibility but by polls and focus groups. Therefore, the old adage of “he who has the gold rules” once again is validated; it has just been juxtaposed for comparative sameness with gold. Either a political party has it or not; either one has the gold or not; with such an absolute either or, one can truly understand why political power is to be feared.
In addition, political power will not compromise, it will not subordinate even to good sense. Political power will only abate its thrust and slash if confronted with overwhelming counter power; and such abatement will always be bloody.

industry_corpus2: Politics & Administration


text:
The first book of Benedict XVI’s formidable oeuvre on the life of Jesus of Nazareth deals explicitly with the political life of Christ, or what Benedict in the preface modestly terms His “public activity.” Although not explicitly terming Christ’s activity as political, Benedict XVI does tell us that he regards this “public activity” as the more “urgent” activity, in contradistinction to the childhood of Christ. What Benedict XVI initially and modestly calls Christ’s “public activity” is eventually unveiled as political activity and treated as such for the duration of this considerably difficult tome. This essay review will aim to validate the latter claim, elaborate it and explore Benedict XVI’s political teaching to the extent that it is made visible in the first part of his biographical rumination on Jesus Christ.
Before proceeding, it is necessary to elucidate certain presuppositions which form the groundwork of this essay, in order to avoid misunderstanding. First and foremost, this essay does not make the audacious claim to concern its self with the political philosophy of Jesus Christ, nor with the political philosophy of Benedict XVI. Rather, the aim herein is to extrapolate what appears to be a rather esoteric teaching on political philosophy encapsulated in a broader work; Jesus of Nazareth. Benedict XVI’s book on Christ eludes, as a whole, any easy categorization. It is a work of history while also being a work of theology. The two are linked by a thread of philology. Within the work, there appear all the virtues of mythology, poetry, and philosophy. Methodological political philosophy appears nowhere explicitly; political science is absent. Their absence in any methodological or scientific sense portends their presence in common sense, as befits classical liberal arts. The book is, in short, a classical text written in modern times. It thus transcends modern categorization. To those unfamiliar with classical scholarship, the book may appear inadequate rather than transcendent.
Turning to this possible inadequacy, in the spirit of Thomistic disputation; a modern critique of the book may well go something like this: Though it pretends to history, it is not methodological enough to be accurate history. Though it pretends to theology, it relies too heavily on historical fact. Though it pretends to academic scholarship, it condenses too much in the name of popular evangelization. In other words: because it cannot be compartmentalized to fit the narrow confines of the modern social sciences, and at the same time cannot be said to be authentically “classical” as it was written recently, it is therefore worthless. For even if we were to grant that it is stylistically and organizationally “classical”, the modern social sciences seldom admit of the notion that classical texts are important beyond their historical value as “old” texts, or windows into the past.
By way of analogy, one of the best examples of this phenomenon is the treatment of The Beowulf as described by J.R.R Tolkien in his 1936 lecture, “Beowulf: The Monsters and the Critics.”. The modern social sciences, incapable of allowing that pre-scientific civilization had anything of value to teach us about ourselves, presumed (according to Tolkien) to treat The Beowulf as at best a historical account testifying to particular cultural traits of Germanic tribal society. Likewise, had Benedict XVI written his book on Jesus five hundred years ago, it may have historical value now. As such, being a contemporary work executed in the classical style, it may border on irrelevance in the view of modern social sciences. Benedict XVI himself does not think his book irrelevant. In fact, he feels the “public activity” of Jesus, which according to the Pope commenced with His baptism, of “urgent” importance for modern audiences. By demonstrating this relevance, Benedict XVI not only defends the political relevance of Christianity, but of the classical liberal arts as a means of seeking for and presenting wisdom.
Finally, it would be the height of folly—particularly for Catholics—to treat this book as if it were written by a mere academic. It is written by the Pope. Benedict XVI addresses this matter esoterically when he tells us in his preface that the book is not to be treated as a statement of dogma ex catedra, but rather is the result of his path towards the face of God. We as readers, the Pope tells us, are free to disagree—he asks only for a bit of sympathy “without which understanding is impossible.” This exoteric liberal magnanimity has an esoteric undercurrent to it: if the Pope, who is the political authority for the Catholic Church and who aspires to be a moral authority for the lay, having the powers he has, decides not to dictate dogma, but rather invites disagreement, asking only sympathy, then those who aspire to abide by his example as Catholics ought to comport themselves likewise towards their fellow men. If the Pope refuses to exercise the authority of his station, preferring instead to share his personal path and ask for sympathy in an attempt to understand—what Catholic can approach the subject of Christ in a manner less charitable to eventual disagreement than this? The Pope, with his modesty and academic openness has in a sense limited the acceptable range of deliberation to modest academic openness. No room has been left for narrow dogmatism or appeals to the authority of station over the authority of argument and—above all—of dialogue. When we consider that the Pope, for Catholics, is Christ’s vicar on Earth, we realize that his political comportment in this matter is also a prelude to the political philosophy of his entire oeuvre; of Jesus of Nazareth.
The political philosophy of the oeuvre can be seen implicitly in a great many portions, but there are three explicitly political points of reference which somewhat anchor said political philosophy. The first of these is Benedict’s enumeration of the ”contradictory” partisan factions constituting the political environment into which Jesus ventures (aged around 30, which is the age when a man ”gains the right to public”, ergo political, “activity”). Benedict identifies these factions as Caesar on one end, Christ on the other, and between them the Zealots, the Sadducees, the Pharisees and the Qumran. Benedict takes care to note that the contradictory opposites find their way ultimately to Jesus, as Christians eventually would spring from all of these partisan backgrounds. The partisans identified by Benedict do not represent a unique or melodramatic archetype in human affairs. Caesar is the epitome of the good and evil of the human political arts, the Zealots are in strict opposition to these arts as a (universally) human thing in favor of the political arts as a Jewish thing, or in the service of Judaism. Where the Zealots are romantic and populist, the Sadducees are realistic and pragmatic, as are the Pharisees. The Qumran, whom Benedict describes as ”essentialist” (I,26) and who consider themselves The Authentic Israel (IV,78) are somewhat akin to Epicureans or, to use a more contemporary comparison, to the private life of the spirit. All of these factions are not melodramatic nor unique; their corresponding archetype can be located wherever politics can be located, which is to say wherever Man can be located. The only unique and melodramatic element in this mix is Jesus. Yet even this melodramatic presence is not limited to a moment in time, since if Jesus is indeed God, then He is present eternally, and thus eternally abreast the essentially permanent constitution of political natures inherent in humankind. As such, Jesus is in Benedicts view a pure historical phenomenon—pure, in the sense that He is God, historical in the sense of being located in a particular time, and phenomenological in the sense of the combination of Godhood and historical location resulting in a transformation of the nature of History. The incarnation is thus, in many ways, akin to a recreation of the World, of History itself.
” and an “internal unity…from the first moment of his life to the Cross and the resurrection”. (I,26-35) It is worth noting here that Benedict explicitly takes care to go beyond the juxtaposition between Caesar and God, and the question of rendering unto each what is owed. While Benedict does acknowledge the natural harmony between the two, disturbed only when Caesar usurps Godhood, he focuses our attention away from this lofty political generalization towards a broader appreciation of the partisanship of Jesus’ day—and subsequently partisanship in all times as it relates to the historical dialectic of “contradictory” oppositions in a tension that moves them towards the Absolute and Universal.
Autobasileia appears to us as one of the many interpretations of the meaning of the Kingdom of God that has arisen in Church history. As this history of interpretations moved closer to our times, the interpretation itself moved significantly away from autobasileia towards something approximating a worldly Kingdom, until finally in what Benedict characterizes as liberal theological thought, it became a kingdom rather than thekingdom of God. Both of these interpretations are, in Benedicts estimation, inadequate: ”The new closeness of the Kingdom of which Jesus speaks and the proclamation of which constitutes a specific moment in His rhetoric, is He Himself. Through His presence and His actions, God in a completely new way here and now enters history.” (III,66) In Benedicts estimation, this view of the life, death and resurrection of Christ as unique in human history forms the basis for understanding the kingdom of God. It is neither an internal ordering of the soul, nor an external ordering of the commonwealth; it is the historical fact of God intervening in the affairs of mankind through the Person of Jesus Christ. If the kingdom is this novel form of Divine intervention, what implication does that have for political philosophy?
To answer this question, it is worthwhile to step back and look upon the three pillars of Benedict’s political philosophy of Jesus of Nazareth as a whole. In summary, these pillars are the explicit entrance of Jesus into a partisan political arena, the basic choice given to mankind between the true and the false messiah, and the notion of the Kingdom of God as a real historical event; a unique and amazing phenomenon: the life, death and resurrection of Christ. One can immediately see from the resolution into the Absolute Christian life of the contradictory partisan oppositions from the first pillar an excellent illustration of the third pillar: the Kingdom of God. For Benedict described the resolution of the partisan political struggle surrounding Christ in a manner similarly confounding to Christs own proclamation of the Kingdom of God: Benedict calls the crucifixion of Christ contrary to the programs of the zealots (II,26). We may add that the resurrection was contrary to the program of the Pharisees and the Romans as well. That is to say: the entire historical event, as it was played out, ended by confounding all political expectations. Christ did not, in the manner of the Qumran, isolate himself from the politics like the Epicureans, but rather like Socrates the Philosopher went down to the Piraeus, into the City; into the political. Once there, he did not, in the manner of the Zealots, make Israel the aim of His political activity, merely the means (I,33). Contrary to the Sadducees and Pharisees, He proclaimed Himself the Messiah, but did not challenge their earthly rule; as no challenge was necessary (just as it was not necessary to challenge Pilate). ”You would have no power over me if it were not given to you from above”, Jesus tells Pilate; and in effect, told His Jewish masters. To vie for earthly power is not beneath Jesus on account of His distaste for Earthly glory or a preference for things of the spirit: it is a function of the fact that He is the ruler of the Universe, and therefore has no need to meet the challenge of the gauntlet thrown at his feet by the Pharisees, Pilate or even the Devil in the second temptation.
This entire point may appear bland for two types of person: the fundamentalist believer with access to what Leo Strauss often identified as wisdom stemming from revelation and to the fundamentalist unbeliever who, given that there is no God, is not impressed by a political philosophy at the core of which is the radical novelty that God exists and acts in history. The first type of person will be unmoved by what he would likely consider Benedicts tautological platitudes. The second type of person will be equally unmoved by what he would likely consider an unverifiable, improbable claim that renders the statement absurd. What type of person, then, would possibly be moved by this teaching? It would have to be the person of faith in contradistinction to the people with access to Divine revelation or the people who are recalcitrant and thus closed to the grace of God.
Since Jesus cannot merely be one of many interpreters of the Tora, Rabbi Neusner realizes that His claims must be taken seriously, that piety towards God demands a serious consideration of the teaching of Christ. Without entering into the specifics of the dialogue Benedict concocts between himself and the Rabbi, it must be said that the dialogue itself as literary form is, much like Platos dialogues, an indication of the political philosophy of Benedict’s Jesus of Nazareth. For in this dialogue, one sees the pious Jew and the pious Christian taking one another seriously without resorting to persecution or relativism. Persecution is a vice not unrecognizable to the modern liberal, but relativism is a more subtle and often unrecognized vice. Benedict’s dialogue with Rabbi Neusner is deadly serious without being deadly. It concerns the most fundamental questions of human existence without endangering said existence. It is religion par excellence: the ideal example of true multiplicity of cultures rather than the faux tolerance and multiculturalism of our present age. Benedict does not tolerate Neusner; he engages him. He does so because Neusner, as a Jew, does not tolerate Christ; he engages Him. This is, like Abraham wrestling with God, the proper comportment of the true man of faith and it indicates a preference for a politics where freedom exists as a means towards serious spiritual reflection and action, not merely as an end in and of itself, let alone as a synonym of tolerance.
There is of course a school of thought, or a mode of thinking, likewise considered serious, perhaps too serious for its own good, which confounds our triumvirate of the wise man through revelation, the wise skeptic and the man of faith: namely the man who is ”beyond good and evil”. In treating him, Benedict alludes directly to Nietzsche and takes up the central Nietzschean critique of Christianity as slave morality, rooted in a psychology of resentment. In doing so, Benedict goes beyond Max Schiller’s earlier critique of Nietzsche in Resentment & Morality, where the esteemed German phenomenologist elaborated on the novel, unique nature of Christian agape contra Nietzsches presumptions. Benedict instead makes a political argument against Nietzsche, pointing out that the Nietzschean presumption that weakness, poverty and suffering are vices which ought to be remedied by philosophical will to power is a presumption that is shattered in the face of mass suffering under totalitarianism and total war.
. The term Son of God severs all links to the sphere of political rule and becomes a statement of a special kind of unity with God, embodied by the Cross and the Resurrection.
By analogy, it may at first appear that we can come to comprehend the political philosophy of Benedict’s Jesus of Nazareth as Socratic insofar as Socrates refused rescue in the Phaedo, exemplifying the virtues demanded by Romans 13,1-7 while at the same time refusing to love the City when the City did not love God, as exemplified by Plato’s Apology. This paradox, or apparent contradiction of a religion and a political philosophy that holds as a moral virtue the simultaneous adherence to earthly Law and to Nature and Nature’s God, even when the two conflict, is made comprehensible to Man not by faith, but by philosophy. Benedict acknowledges as much when noting the “sole philosophical word that entered the credo”—homoousios. (X,280). This resort to philosophy was necessary to ground the Holy Trinity, and subsequently the paradox of God and Man, of Natural and conventional law in a concept within the grasp of Human Reason, in accordance to the Evangelist’s proclamation that upon gifting to them the Holy Spirit, Jesus “enlightened” their “minds.” And yet this is not tantamount to regarding Christianity as a mythology inspired by Hellenistic thought (a subject Cardinal Ratzinger elaborates in a much earlier essay). For Benedict contends for Hellenistic philosophy to be of assistance in helping us understand, there must first be a historical event—a fact of history—calling out for understanding. The fact of history that is the life of Jesus, Benedict tells us, quoting C.S. Lewis, “.… is strange. This whole story of a dying god appears to have in fact really happened at some point in time.” (VIII,240) It is, Benedict concludes—as Cardinal Ratzinger had done in an earlier and shorter work on Hellenism and Christianity—the amazing, unique and novel historical fact of the life of Jesus which is itself the key. For political philosophy, this suggests that Natural Right and History are not opposed, as Leo Strauss feared. For if History is above all the amazing transformation of the biosphere into what Jesuit paleontologist Pierre Teilhard De Chardin termed the nousphere by the life and death of Christ, then the philosophical question of Natural right lies at the core of History itself. Scientific history cannot be properly scientific without spiritual reflection on the life and death of Christ. This is a profound teaching which suggests that if the life of Christ has indeed transformed History from material to ethical—it can also transform politics this way.
The author has used the Polish version of Benedict XVI’s Jesus of Nazareth, thus all page references and quotes may not be accurate to the English-language counterpart. The quotes were originally translated from German to Polish, and then from Polish to English.

industry_corpus2: Literature & Emotions


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26th May 2014 – HS2 faces years of parliamentary scrutiny during the Hybrid Bill process after individuals, groups and councils impacted by the £50 billion rail line deposited over 1,900 petitions with the Committee reviewing the detail of the Bill. Despite the Government’s best efforts to suppress opposition by insisting on four hard copies of all petitions be delivered by hand to Westminster and a £20 fee being charged, nearly four times the number of petitions have been submitted than were for Cross Rail., and double the number of petitions submitted for HS1.
The likely hood of HS2 ever reaching Manchester and Leeds reduced as it has become clear that the petitioning for Phase 1 (London to Birmingham) process will take longer than the three years Cross Rail took. If the Government tries to do deals with the largest petitioners then this will add even more pressure to a budget which is already out of control. HS2 Ltd admitted just last week to overspending its £101 million consultants’ budget by a staggering £87 million. While the Major Projects Authority rated the project Red/Amber for the fourth consecutive year in its Friday report.
“Public opinion polls have consistently demonstrated that British tax payers do not want HS2 and despite the Governments best efforts to steam roll through this political vanity project, to suppress negative reports and opposition, they cannot ignore the thousands of petitions that have been deposited. It is time for this white elephant to be given full and detailed scrutiny.

industry_corpus2: Transportation


text:
The Most Popular What Is the Best Brand of Makeup ?
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industry_corpus2: Others


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So it doesn’t happen all that often, but when it does it usually takes me by surprise. It’s every facilitator’s fear—the inappropriate comment. They come in lots of shapes and sizes, ranging from overly personal to highly offensive.
I remember a train-the-trainer session where a prospective trainer’s opening line was, “So Adam and Eve were in the garden.” I thought for sure this was a joke. He got to the end and said, “And that’s how crucial conversations skills could have prevented original sin.” Not the punch line I was expecting.
We all fear and dread over-shares and inappropriate comments, but what’s the best way to handle them in the moment? One thing that’s worked for me is to use a contrast of sorts: thank the person for being willing to share, and clarify what’s appropriate to share in this setting. What do you do in these types of situations?
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I like the contrasting as a beginning, as well. I also have found it useful to share what seems to be the true intent of the person, often asking for that if I am unsure (get their story), and reflect appreciation for that. I will acknowledge how I saw any positive aspect of the comment, if I authentically did, especially if it meets their intent. Then I will share how the comment may have been interpreted by someone unaware of the intent, and I will share the potential impact of that. Depending on the relationship, I may suggest they consider a different approach to achieve their aims and help them brainstorm. It helps when I can challenge my own stories about the person/event and remain empathic.
Yeah, what Allison said. Brilliant.

industry_corpus2: Subject Education


text:
Why Back Up Your Life?
Download Your Backup Plan App!
Feel Free to Share On Social Media!
“Chocolate is a vegetable, because it comes from a bean.” This is just one of many doubletake statements you’ll hear from Christine Awram (while wearing a pink tiara), as she encourages women to question any of their beliefs that limit an empowered, joyful and successful life.
She’s the founder of Woman Of Worth WOW Worldwide and is a dynamic speaker, author, visionary and philanthropist. Christine radiates vitality with her indomitable spirit and humour. Yet her earlier years began as a teenage runaway who experienced addiction, illness and depression. She inspires others by sharing the specific strategies she used to move from futility to fulfillment, and how she transformed challenges into passion and purpose.
Christine’s commitment to the empowered leadership of women resulted in her being honoured with the Outstanding Leadership Award by the Global Women’s Summit. She has personally inspired over 10,000 women through her WOW events, and believes she is just getting warmed up.


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The Portuguese transfer pricing rules have been in force since 2002, through the publication of Decree 1446-C/2001 (Portaria). This decree, combined with Article 63 of the Corporate Income Tax Code, establishes the transfer pricing principles and rules for Portugal. Complementarily, Article 138 of the Corporate Income Tax Code, as well as Decree 620-A/2008 of 16 July 2008, determine the framework of application of advanced pricing agreements (APAs).
These rules are based on the OECD Transfer Pricing Guidelines, and Portaria states that 'for its application, in cases of greater technical complexity, it is advisable to consult the OECD Transfer Pricing Guidelines'.
Portaria also states that these rules apply to all operations conducted between a corporate or individual taxpayer and any other entity with which the taxpayer has a special relationship, which seems to indicate that the rules apply to individuals, corporations and any other types of entities with whom the taxpayer has a special relationship. However, although those rules have specific corresponding provisions in the Corporate Income Tax Code, there is no reference at all to transfer pricing in the laws that govern taxation of individuals. This situation has triggered some as yet unresolved litigation between the Portuguese tax authorities and certain individuals regarding the use of transfer pricing rules to adjust individuals' taxable income. Although we should wait for final judicial decisions regarding this issue, it is more likely than not that the Portuguese transfer pricing rules do cover transactions that involve individuals, but do not allow any adjustment on the taxable income of individuals, but only in the taxable income of corporations and other entities subject to corporate income tax.
Portuguese transfer pricing rules do not apply to equity operations, namely dividends, equity increases and decreases, etc.
a resident entity – or a foreign company's permanent establishment (PE) – and entities resident in jurisdictions listed as tax havens.
In addition, foreign entities and Portuguese PEs; Portuguese entities and correspondent foreign PEs; and Portuguese PEs and foreign PEs are also deemed to be related parties.
Portaria clarifies that the scope of 'operations' subject to the transfer pricing rules includes financial operations and any commercial transaction, including those involving fixed or intangible assets, or goods, rights or services, even if those were conducted within cost sharing or contribution agreements, service agreements or other types of agreements, or if those result from any alteration of business structures, especially whenever that alteration involves the transfer of intangible elements or a compensation for losses or for lost profits. The Portuguese transfer pricing rules cover both domestic transactions as well as cross-border transactions, including those between a branch or a PE and its mother entity.
whenever the conditions of a transaction, conducted between a Portuguese taxpayer and a resident related party, differ from those that would have been agreed, contracted or performed between independent enterprises, then the Portuguese tax authorities might carry out the adjustments required for the taxable income of that Portuguese taxpayer to be no different than what it should have been in the absence of the special relationship.
The wording of Article 3 of Portaria has two relevant specificities: that taxpayers can only perform self-initiated transfer pricing adjustments on their tax return in case of cross-border transactions and when those adjustments are positive; and that all other transfer pricing adjustments are the exclusive competence of the tax authorities and, as such, are dependent on the tax authorities' assessment and decision.
Although the Portuguese transfer pricing rules are closely based on the OECD standards, in 2014 the Portuguese tax authorities launched some new rules regarding the tax deductibility of some types of costs, namely financial, that do define a threshold above which those costs will not be tax-deductible, even when they comply with the transfer pricing rules, which is a first deviation from the strict application of the arm's-length principle in some specific fields in which the tax authorities have faced, through consistent litigation, difficulties in effectively applying the arm's-length approach.
Accounting rules and treatment are generally the basis for the computation of the taxable income, although the Corporate Income Tax Code has several specific identification, recognition and deductibility rules that do differ from the accounting rules and require a specific reclassification or computation within the taxable income assessment.
Article 13 of Portaria sets documentation requirements, namely a yearly preparation of a transfer pricing file for any taxpayer that has recorded, in the previous tax exercise, a total revenue of at least €3 million. Although that transfer pricing file must be prepared each year (for those taxpayers that have reached the above-mentioned threshold), it is not required to be automatically delivered to the tax authorities. It would only need to be provided to the tax authorities upon specific request, usually within a 10-calendar-day delivery deadline. Article 63 of the Corporate Income Tax Code also provides that taxpayers need to maintain proper transfer pricing support documentation.
the transfer pricing economic analysis conducted to assess the compliance with the transfer pricing rules of each group of controlled transactions.
No specific provisions are expressed in the legislation regarding a documentation structure of a master file and a local file. Nevertheless, the Portuguese transfer pricing documentation requirements already address the contents and information that the OECD recommends to include in the master file and the local file, and, in practice, the Portuguese tax authorities have been accepting documents with a master file or local file structure, if those do comply with the Portuguese documentation requirements (those do require some additional information compared to the OECD master file or local file approach).
the transfer pricing methodologies used to assess compliance with the transfer pricing rules.
Following BEPS Action 13, the Portuguese Budget Law for 2016 introduced a new additional documentation requirement through Article 121-A of the Corporate Income Tax Code. This new provision implements the country-by-country (CbC) reporting obligation for fiscal years starting on or after 1 January 2016. This new rule follows OECD recommendations regarding the CbC reporting requirements. The Portuguese legislation allows a surrogate entity to be designated by the group, in the event a parent entity is not obliged to file a CbC report (CbCR), or where an automatic exchange of information process by the tax authorities of that jurisdiction with the Portuguese tax authorities is not in place. Nevertheless, such a reporting entity should be identified and communicated to the Portuguese tax authorities by the end of the relevant tax period.
another motive (which needs to be disclosed on the 'other information' field of the CbCR.
The CbC rules also imply the submission of additional information, also based on the OECD CbC guidelines, namely a communication of who will be the CbC reporting entity and in which jurisdiction that entity is located. The corresponding form also requires some information regarding that entity, namely its tax number and address, as well as the confirmation if that entity is a final ultimate owner or if it is submitting the CbCR as a surrogate entity. The deadline for that communication submission is the end of the fifth month after the closing of the accounts.
the profit split method (PSM), the transactional net margin method (TNMM) and any other method deemed as the most appropriate taking into consideration the facts and circumstances and the arm's-length principle, whenever the methods foreseen in (a) are deemed non-applicable.
As a result of the wording of Article 4 of Portaria, transaction-based methods such as CUPM, CPM and RMM are deemed as being the common usual methods, while the remaining profit-based methods can only be applied whenever the taxpayer can demonstrate that the transaction-based methods were not applicable.
As a result, the method selection process described in the transfer pricing file of the taxpayer needs to address that inherent method hierarchy and, apart from explaining and supporting why the applied methods were deemed as being the most appropriate ones to test the controlled transactions under analysis, in the event profit-based methods were applied, it also needs to explain why transaction-based methods could not be applied or were not deemed as being the most appropriate testing method.
Portaria contains quite detailed considerations about comparability, whether in Paragraph 3 of Article 4 or in Article 5 (the title of this article is 'Factors of comparability'), and those considerations follow closely the OECD Transfer Pricing Guidelines.
Usually, whenever the taxpayer (or its related-party counterparty) conducts similar transactions with independent parties, then the internal CUPM, through the use of internal comparable data, will be deemed the most appropriate method to test compliance with the transfer pricing rules.
The tax authorities do consider that internal comparable data may provide more reliable data to analyse the transaction or company under analysis than external comparable data. Taking this into consideration, internal comparable data are usually preferred over external data.
If no internal comparable data (or no good internal comparable data) is available, but that external comparable price data can be identified, and whenever those external comparable data can be deemed as sufficiently comparable, then this is usually considered as the second-best testing method.
issued or loaned to an entity located in the same region.
There have already been some court cases that have confirmed the importance of comparability within the application of the CUPM.
When the CUPM cannot be applied, one of the remaining indirect methods will be used, which will require the search of potentially comparable companies developing potentially comparable activities to the one being tested, within publicly available databases. Those methods are usually less demanding in terms of comparability, but those searches will nonetheless seek to obtain the most comparable data possible, namely through detailed industry and activity description searches, complemented with internet searches for more information about the potentially comparable companies. Apart from the comparability factors, those searches will seek to confirm whether those potentially comparable entities comply with the Portuguese independence rules (meaning that none of those entities can be directly or indirectly owned by a corporation by 20 per cent or more, and cannot own directly or indirectly any subsidiary by 20 per cent or more).
The PSM is a method rarely used to date, because taxpayers are usually reluctant to proactively share information about the profits earned by their non-resident related entities, although tax authorities have tried to enforce the use of this method in some cases, with limited success. A possible outcome of BEPS may be an increased use of PSM, although this is yet to be seen in practice.
The audit procedure usually begins with a notification sent by the tax authorities to the selected taxpayer, which sets out the nature and scope of the audit, as well as the rights and obligations of the taxpayer during the audit process. Nevertheless, we have observed an increasing tendency of the tax authorities to send initial informal requests for information prior to the sending of the notification and of the official audit procedure. In most cases, tax audits will be conducted through a series of requests for information or documents and access to accounting systems and books, and through several meetings and queries conducted with the accounting and financial interlocutors of the taxpayer. We have also observed an increasing tendency of the tax auditors to contact third parties (e.g., clients or providers) to gather evidence or to confirm statements made by the taxpayer.
When the tax authorities identify potential transfer pricing issues within transactions conducted with non-resident entities they seek to gather information about the global tax position in order to assess the profit share by jurisdiction. For that purpose, they usually send requests of cooperation to other tax jurisdictions for them to issue requests of information to the counterparties of the transaction located in those jurisdictions.
The implementation of CbC reporting (see Section II) will provide more information to the tax auditors to identify potential non-compliance of certain group transfer pricing policies.
The Portuguese transfer pricing rules do not include any specific consideration on intangibles, but, as mentioned earlier, they contain an explicit referral rule directly to the OECD Guidelines. As such, the guidance for how to identify and recognise transactions with intangibles for transfer pricing purposes are the OECD Guidelines. As a result, the changes originated through BEPS Actions 8–10 were assimilated by the Portuguese market players as a more recent and updated definition of the guidance on how to deal with intangibles for transfer pricing purposes, not requiring a specific legislative change (and no such legal change is foreseen or expected regarding intangible definitions).
Consequently, the recognition process has to be based on a detailed functional and risk analysis, which will identify the intangibles in the transactions under review, how they contribute to the creation of value and how they interact with other intangibles, with tangible assets and with business activities. The new OECD guidance clarifies that this functional analysis step will have to focus on DEMPE (development, enhancement, maintenance, protection, exploitation) functions and risks, seeking to identify which entity develops those functions, which entities assume the subsequent risks, which have control over risk (requiring ability and resources to perform that control) and which are funding the DEMPE functions or risks. It also highlights some specific functions deemed as particularly relevant for intangibles, namely design and control of research and marketing programmes, direction of and establishing priorities for creative undertakings, control over strategic decisions regarding intangible development programmes, management and control of budgets, important decisions regarding defence and protection of intangibles, and ongoing quality control over functions performed by independent or associated enterprises. Similarly, it also highlights some specific risks deemed as particularly relevant for intangibles, namely risk related to the development, obsolescence risk, infringement risk, product liability risk and exploitation risk.
Taking into consideration that tax treatment is a critical factor in any investment decisions, in 2014 the Portuguese government launched a tax reform aiming to achieve a more competitive tax framework to attract investment, and promote economic growth and employment. Intangibles was one of the areas in which tax treatment was significantly changed.
More specifically, the 2014 tax reform launched a new regime for intangibles through Articles 45-A and 50-A of the Corporate Income Tax Code. Article 45 aimed at recognising tax effects for intangibles with an indefinite life, and as such, it introduced the recognition, as a tax-deductible expense, of a constant depreciation, within the 20 tax exercises following the recognition, of the acquisition cost of some specific intangible assets that have no limited lifetime, namely patents, brands, licences and permits, production processes, models or other assimilated rights. The same applies to goodwill generated by acquisitions of the shares of other entities or of other entities' assets and liabilities.
Similarly, at the same time (2014), a patent box regime was also introduced which enabled that income deriving from the sale or the temporary licensing of the use of industrial property rights (i.e., patents and industrial drawings and models) was 50 per cent exempt from corporate tax taxation. In 2016, that regime was amended, following the BEPS Action 5 guidance, also introducing a limit on the tax deduction, as well as a 30 per cent uplift on the tax deduction of some eligible R&D expenses.
Tax authorities always fear that intangibles' intra-group transactions might lack effective substance and that they might have been artificially structured only to benefit from tax incentives or to shift profits abroad. These concerns regarding substance were particularly addressed by BEPS Actions 8–10.
Despite the 'substance over form' concept being generally foreseen in the Portuguese rules, as stipulated in the General Taxation Law, the issues addressed under these BEPS Actions are not specifically embedded in the Portuguese transfer pricing rules. However, we do not anticipate that the Portuguese tax authorities will formally propose changes to the domestic transfer pricing framework. Hence, the OECD Guidelines are followed because Portugal is a Member State of the OECD and because the Portuguese transfer pricing rules include a specific referral to the OECD Transfer Pricing Guidelines.
Nevertheless, it is important to note that the Portuguese transfer pricing rules are not embedded within the anti-abuse rules in place within the Portuguese legal and tax framework. As the application of the substance over form concept often implies more than just a pricing adjustment, we have observed several court decisions that have ruled against the tax authorities' attempt to recharacterise some transactions (due to the lack of substance) based on the transfer pricing rules, as the court considers that those attempts lack the substantiation and support required by the Portuguese anti-abuse rules, which are quite complex. As a result of that complexity, the Portuguese anti-abuse rules are not a path that is often followed by the Portuguese tax authorities, which, together with the fact the Portuguese transfer pricing rules are not embedded within that anti-abuse regime, limits the effectiveness of the substance over form concept in Portugal. It is still too early to conclude whether the new BEPS guidance can improve this paradigm.
Under this new guidance, a contractual arrangement and the subsequent expected return will only be accepted if each party that is supposed to bear a risk is deemed to be effectively controlling that risk, taking the decisions to take on, lay off or mitigate that risk, and to have the financial capacity to bear that risk. As a result, even more than before, the functional and risk analysis is a critical part of the transfer pricing analysis. The new guidance calls that analysis the 'accurate delineation of a transaction', meaning comparing what derives from a written contract with the actual behaviour of the parties.
The new guidance also states that the mere fact that a party is funding an activity or controlling the funding risks does not entitle that entity to the returns associated with the operational risks of that activity, unless it does exercise control over those risks as well. Control of funding risk is deemed to be about being able to evaluate an investment opportunity as an investor, meaning as a provider of funds, to take investment decisions and to set up mitigation procedures for funding risks. As a result, these functions and risks are deemed to be entitled to a remuneration aligned with what the market usually pays for similar financial functions, which is no more than a risk-adjusted financial return, and not the residual income deriving from operational risks or activities. The new guidance goes even further when stating that if the legal funding entity is not even managing and controlling the funding risks, namely due to lack of resources, but only providing the funds (meaning that some other entity is effectively managing and controlling that funding activity), then it will only be entitled to receive a risk-free rate of return.
Comparatively, control of operational risks implies being able to analyse the consequences of potential alternative operational decisions on the business being developed and on its subsequent returns, having the authority to take those operational decisions and to assess, decide and implement mitigation procedures for those operational risks. Operational risks are entitled to receive residual returns.
All of these characteristics imply specific resources and specific operational know-how, which cannot be found in pure funding structures. As such, decision-makers must be competent in the area of risk for which the decision is required, and they must be performing the decision-making function in the location of the entity claiming to be controlling the risk and the associated return. As a result, mere minutes of board meetings performed outside of that location, or signature of documents executing the decisions are deemed to be insufficient to demonstrate decision-making (this has already been enforced by an existing rule in place in Portugal, namely through the concept of 'effective management').
Traditional 'principal versus operational structures', in which the operational structures were traditionally awarded a return based on a transactional net margin method or a comparable profit method and the funding principal would get the residual income, might be non-compliant with the new guidance whenever the principal is merely funding the activity and not managing and controlling the operational risks.
Whenever more than one entity controls the risks that drive the return, they will have to share the income based on their real contributions to the value creation.
The new guidance recognises that payment for use of an intangible should be made to the party having the legal rights to such intangible, which, at a first glance, could be seen as a step back in the substance over form paradigm. However, the new guidance also stipulates that, when another entity has developed or participated in the development of the DEMPE functions, provides funding or assumes risks, a separate transaction dealing with that contribution must be considered. That assertion implies that the income flow deriving from the use of an intangible will not be diverted from the legal owner, but that entity has a transfer pricing obligation to remunerate the other entities that are developing activities that the legal owner is not performing, which can mean that the legal owner may end up not registering any profit at all after appropriately compensating the other group members for their contributions.
The new guidelines also recognise that the legal owner does not need to perform all the DEMPE functions, as independent parties do sometimes subcontract others to develop parts of those functions, but, in that case it requires control to be effectively applied over those subcontracted activities and their performance, which requires determining the objectives of the outsourced activities, as well as capability to understand and assess the performance of the activity, to take decisions regarding selection, hiring, change and cancellation, as well as to effectively exercise those functions.
ongoing quality control over functions performed by other parties that may have a material impact on the value of the intangible.
viability and profitability risks associated with the returns to be generated by the future exploitation of the intangible being able to generate appropriate returns compared to the research and development costs.
The party actually controlling, managing and assuming the risks will be entitled, through a secondary transaction, to the potential gains and losses deriving from those risks. In contrast, a party that is not controlling, managing and assuming those relevant risks, nor developing the relevant functions listed above, will not be entitled to the gains or responsible for the losses.
There were no formal settlement or negotiation procedures with the Portuguese tax authorities foreseen in the Portuguese General Tax Law before the introduction of APA procedures. Until then, the interaction between taxpayers and tax authorities consisted mostly of audits, investigations and litigation.
The only procedure that could be deemed as closer to a negotiation or settlement procedure is the taxable income revision procedure foreseen in Article 91 of the General Tax Law, which can only be initiated in the event the tax authorities do apply indirect methods to determine the taxable income of the taxpayer. In that procedure, both parties (taxpayer and tax authorities) will nominate experts who will analyse the case, and conduct working sessions and contradictory debates (which end up involving some kind of negotiation) in order to achieve a common technical understanding, which will be binding for the tax authorities (except in cases of tax crimes).
Although the law did not specifically entail a negotiation alternative (apart from APAs, which will be addressed below), there have been cases where, in view of the proposed adjustments, informal discussions with the tax authorities (at an administrative stage of the process or during the audits) were conducted, in order to assess the arm's-length pricing of the controlled transaction under controversy.
In this regard, it should be noted that following this solution is dependent on a variety of issues, ranging from the specialisation of the tax authorities' audit team involved in the process, and the availability of the latter for initiating such a negotiation, to the complexity of the analysis.
In situations where the tax authorities' transfer pricing team is not involved or the taxpayer pursues a resolution of the controversy aimed at a full annulment of the proposed adjustment, this alternative is usually not successful.
The possibility to conclude unilateral and multilateral APAs was introduced in 2008 and the inherent legal dispositions were subsequently amended in 2014, essentially with the aim of promoting and facilitating unilateral agreements. As such, the APA alternative is the unique course of action in situations in which a taxpayer wishes to proactively seek a negotiated understanding for a complex transfer pricing issue. However, note that a rollback of the terms and conditions negotiated under the APA is not formally possible, according to Portuguese law, although the tax authorities have informally agreed in the retroactive application of some signed APAs. Therefore, any retroactive application of the APA is subject to acceptance by the tax authorities responsible for the negotiation.
Portuguese tax laws do not include any specific process for handling formal inquiries into transfer pricing issues. Therefore Portuguese tax authorities should follow the general tax inspection procedures stated in the Portuguese Tax Procedure Code (CPPT), as well as apply the timelines and detailed requirements given by the Complementary Requirements Code for Tax Inspection Procedures (RCPIT).
Regarding the tax inspection procedure, Portuguese tax authorities may start this procedure for a four-year period after the end of the accounting period to which the tax assessment relates. However there are special rules applied if the tax return presents tax losses; in such cases, the forfeiture period shall be the same as the exercise of such right.
The tax inspection procedure follows strict formal requirements, is continual and must be concluded within six months (Paragraph 1 of Article 57 of the General Tax Law). However, under certain circumstances, this period may be extended twice for three months each.
The audit procedure is completed when the tax auditor considers that all the necessary information has been obtained to draw up a proposed tax audit report. This proposal is sent to the taxpayer, who has 10 days in which to dispute the preliminary conclusions of the proposal. After the 10-day period has elapsed, the tax auditor will issue a final audit report, which may give rise to an additional tax assessment.
an administrative appeal, 30 days after the notification of the act to be appealed.
Finally, resolution of tax disputes is regulated by a complex set of legal rules that determine different types of actions and deadlines, among other things, depending on the type of dispute in question.
for the arbitration court (Article 10 of the Legal Regime of Tax Arbitration), within 90 days after any of the facts foreseen for the judicial courts mentioned above, or from the notice of the decision – as long as such acts can be subject to a separate claim – or from the end of the term for the decision of the administrative appeal; or within 30 days from the declaration of the illegality of acts determining the tax base when it does not give rise to the assessment of any tax.
preparation of the allegations in written form (typically, in an articulate form), indicating and providing all means of evidence needed.
As for the timelines, once again it depends on which litigation forum was used by the taxpayer: if the taxpayer has appealed to the judicial courts, a first instance decision is usually reached within three to five years after the submission of the process to the competent court. In situations where the taxpayer initiates the process in the arbitration court, a decision is usually reached within four to six months.
In Portugal, the initial courts are the only fact-finding forums. As such, all evidence needs to be produced in the court of first instance. For this purpose, all means of evidence are admissible (documents, witnesses, specialist technical reports, etc.), albeit the judge has some discretionary power to decide which means of evidence are useful for deciding the case.
As such, any further appeals cannot be based on the existence of additional evidence, or aimed at producing evidence on the case under analysis. Nonetheless, the applicant can appeal based on the fact that the first instance decision did not allow a certain mean of evidence necessary for the decision of the cause, or such decision did not consider certain statements, documents or other means of evidence that should have been considered in the decision.
an appeal to the Supreme Administrative Court within 10 days after the final decision from the initial court, if the reasons for appealing include only legal grounds.
In any case, if the value of the case is lower than €5,000, no appeal can be brought.
As a rule, the process includes a notification of the intention to appeal (within the aforementioned 10 days), a notification by the court accepting the appeal, and the presentation of the grounds for appealing and conclusions, within 15 days after the notification by the court (for the applicant), and 15 days after the end of the deadline for the applicant to present the allegations, with respect to the defendant.
With respect to the likely timing for reaching a decision, it is somewhat difficult to estimate such deadline – in fact, it greatly depends on the complexity of the issue, as well as the court that is going to decide the appeal. Nonetheless, this tends to be a rather lengthy process, with decisions from the superior courts being reached 10 or even 15 years after the appeal.
breach of the audi alteram partem and 'equality of arms' principles.
In practice, most arbitration decisions are final.
Portuguese transfer pricing rules do not include any specific provisions for secondary adjustments and, in practice, we have not observed any attempt by the tax authorities to apply such adjustments.
Nevertheless, a case could be made that such adjustments could occur regarding customs, VAT or even stamp tax.
Regarding customs, for example, in the case of a transfer pricing post-year-end adjustment to the price paid for imported goods, the Portuguese customs rules establish that a post-importation change in the reported customs value due to such an adjustment always needs to be reported (even in situations where the duty rate is zero).
the post-closing adjustment decreases the price paid by the importer of the goods: should the transfer pricing adjustment decrease the price paid by the importer, a duty refund may be requested, within three years from the date of the taxable event, provided that the importer can provide proof to support the claim.
The administrative procedure for claiming a refund is the same as the one prescribed for other value-related corrections; however, the taxpayer should contact the customs authorities to seek guidance on how to proceed.
It should be noted that, although in theory an aggregate transfer pricing adjustment (i.e., an adjustment to the importer's profitability under a profit-based pricing method) may be relevant for adjusting the value of imported goods, the fact is that those types of adjustments rarely allow for a correction to the value of the goods for customs purposes.
As such, it is recommended that, should customs be a concern for the taxpayer, a transaction-by-transaction transfer pricing adjustment be made, in order to be relevant for revising the customs duties already paid.
There is also a relevant interaction between the customs authorities and the VAT tax authorities whenever a customs value increase or decrease is reported. In fact, in situations where a customs value increase is reported to the customs authorities, such an adjustment will automatically result in the assessment of additional VAT, if applicable; and where a customs value decrease is reported, the taxpayer needs to file a request in order to obtain a refund of overpaid VAT.
penalties ranging from 30 per cent up to 100 per cent of the VAT or customs duties owed, with a maximum of €45,000 per transaction, plus 4 per cent interest per annum.
These penalties may be reduced when a voluntary disclosure is made.
Regarding VAT, in situations where a post-year-end adjustment occurs, and the taxpayer wishes to adjust the value of the goods or services considered for VAT purposes correspondingly, the corrective invoice that performs the adjustment needs to meet all the requirements of an original invoice, plus a reference to the original invoices to which the adjustment refers, and a reference to the elements of the original invoices that are subject to modification.
Only corrective invoices that comply with these requirements may be considered in adjusting any original invoices that have already been submitted in the periodic VAT return.
On the other hand, if the corrective invoice reduces the taxable value of the transaction, also causing a reduction in the VAT initially paid, the taxpayer may correct the initial VAT amount, up to the end of the period subsequent to the one in which the circumstances giving rise to the correction occurred. Note, however, that this is not a mandatory regularisation.
If the corrective invoice results in more taxable value for the transaction, thus more VAT than the amount initially deducted, such regularisation is mandatory and can be done, without incurring penalties, until the end of the period subsequent to the one to which the original invoice refers. If this correction is not made by the prescribed deadline, the correction is still mandatory but then should take place in a replacement of the periodic VAT return for the period when the correct transaction should have occurred.
Regarding penalties, specific transfer pricing penalties (from €500 to €10,000) apply for failure to present transfer pricing documentation within the time frame determined by the tax authorities. Should the taxpayer be subject to a transfer pricing adjustment, no specific transfer pricing penalties apply.
In addition, depending on the circumstances, general tax penalties of up to €150,000 apply for refusal to provide information, or for providing incorrect or incomplete information.
Double taxation treaties signed by Portugal do include the possibility for taxpayers to invoke a mutual agreement procedure (MAP).
Also, as Portugal is a member of the European Union, the taxpayer may, whenever there is a tax dispute involving another member of the EU, invoke the EU Arbitration Convention (EUAC).
As a practical disadvantage, the MAP is a long process and, ultimately, the tax authorities are not obliged to reach a decision on eliminating double taxation. Therefore, whenever possible (i.e., when the dispute involves another member of the EU), it is highly recommended that the taxpayer invokes the EUAC, as there is an obligation to reach a decision within two years after all relevant documentation is filed (in practice, we have had some cases where an agreement has been reached within three to five years).
There are also some cases where the Portuguese tax authorities have even reached a decision to eliminate double taxation with respect to years already closed for inspection, under the good-faith and collaboration principle.
Portugal adopted several of the OECD recommended BEPS initiatives prior to the publication of the BEPS reports, and is following through with the implementation, when required, of the remaining ones.
The Portuguese tax authorities have become increasingly active in transfer pricing issues, developing more audits and focusing more on complex issues, namely intangibles, financial operations, systematic loss makers, branches and equity allocation. We have also observed an increase in the number of APAs under negotiation.
It is still too early to judge the impact of the adoption of the BEPS initiatives. Surely, the tax authorities have expectations that these new rules will effectively tackle several of the usual tax-optimisation structures that were set up by multinational enterprises to achieve greater tax efficiency. The complexity and subjectivity of some of the recommended measures could make achievement of that objective difficult. It is likely that significant changes in the way multinational enterprises operate will occur and empty structures with no substance will probably disappear, but they will probably be replaced by other structures in which part of the relevant functions focused on by BEPS will be developed, as well as the relevant risks assumed. Those structures will still seek to take advantage of taxation differentials between jurisdictions, which are not expected to disappear, as tax authorities and governments will still compete to attract investment and employment, and, as a consequence, tax revenues, through differential and attractive tax measure packages.
BEPS measures, namely the greater consistency deriving from the new documentation requirements and the new guidance, will probably increase and accelerate the already current trend of greater centralisation and greater automatisation and IT integration regarding transfer pricing policies and documentation, as opposed to the multiplicity of local policies aimed at adapting global policies to address local specificities of local transfer pricing rules. The digital economy is expected to be particularly affected by BEPS, although the divergences between the United States, European Union and OECD regarding this issue may imply lengthy negotiations and require adaptations to the current proposed measures.
1 Patrícia Matos is a partner and chartered accountant and Filipe de Moura is an associate partner at Deloitte & Associados, SROC, SA.

industry_corpus2: Finance & Economics


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U.S. President Donald Trump speaks before signing an executive order to require colleges and universities to "support free speech" on campus or risk loss of federal research funds during an event in the East Room of the White House on Thursday, March 21, 2019.
WASHINGTON — President Donald Trump on Thursday fulfilled a promise he made to conservative activists earlier this month by signing an executive order that makes federal research dollars for universities and colleges contingent on assurances of free speech on their campuses.
“If a college or university does not allow you speak, we will not give them money,” the president said.
Connecticut’s universities said Thursday they already protect free speech.
The Trump administration did not define what would have to occur for a school to lose its funding and how the administration would enforce the rule.
However, Reitz said, the university does regulate speech “that is not protected by the First Amendment - specifically such as true threats and harassment,” through the Student Code of Conduct and a policy against discrimination and harassment.
Conservative activists, however, say Yale and other universities are liberal bastions that value political correctness over free speech.
They point to a 2015 incident at Yale, where Professor Nicholas Christakis stepped down from his post as the head of a residential college- but retained his tenured teaching position — after confronting students who protested an e-mail sent to them by his wife, Erika Christakis. The e-mail questioned the school’s policy against various insensitive forms of behaviors, like wearing offensive Halloween costumes.
Last year, Christakis was awarded the university’s highest faculty honor, the Sterling Professorship.
John Morgan, spokesman for Quinnipiac University, said the school does not have a free speech policy.
“But we are very supportive of free speech,” Morgan said.
Yale is among the top schools in the nation when it comes to federal research dollars.
The National Science Foundation ranked Yale 15th in spending on research, having spent more than $950 million in 2017, of which $541 million came from federal grants.
UConn received nearly $215 million in federal research grants in 2018.
Trump initially proposed the idea to tie research dollars to free speech during a March 2nd speech to conservative activists, during which he highlighted the case of activist Hayden Williams, who was punched while recruiting on the University of California, Berkeley campus in February.
While conservatives say universities discriminate against visiting conservative speakers, the schools say that when they allow controversial speakers to exercise their First Amendment rights on campus, they must do their best to defuse tensions and keep students safe.
The school approved a request from the College Republicans for Shapiro’s appearance only after holding a so-called pre-event review process. It restricted access to the event and offered counseling to students who might be offended by Shapiro’s talk.
Lucian Wintrich was heckled at UConn when he tried a couple of months before that to deliver his speech, “It’s OK To Be White.” The event ended when a protester took his notes from the lectern and a fracas ensued.


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mmmmmm looks and sound yummy :).
I'll have to try this -- but I generally bake my seeds with some sea salt. I don't wash the seeds before baking either.
I should have taken this recipe with me last week. We spent Halloween weekend at a cabin in the mountains (here on Kauai). After carving the pumpkin I toasted the seeds in the oven at 350 with light oil. We had to make due with canola oil and the taste was so-so.

industry_corpus2: Agriculture & Fisheries


text: Offering an outdoor pool swimming pool Hotel Alicante is located in Chillán 400 metres from the bus station and 3 km from the downtown area. Free Wi-Fi access is available and a daily breakfast is included. Guests staying at Alicante are 80 km away from Nevados de Chillán Ski Centre. Rooms at Hotel Alicante feature cable TV and private bathrooms with showers. The property offers free parking and is 500 metres from the train station.

industry_corpus2: Hospitality & Catering


text: Lone Star State of Texas. It's the perfect way to see who is single in Texas, what we're all about, and it's free. Does online dating really work? Don't ask us, ask the hundreds of thousands people who met that special someone last year on Match.com. And you know how all those happy endings got started? Create a profile now and be on your way to finding your match. Meet the love of your life! On Match.com, a loving relationship in Wylie is just a photo click away.


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CCAPP supports a high visibility visitor program, hosting a spectrum of visitors from advanced graduate students to senior faculty, for short and long term visits.
Visitors are invited to collaborate in observational or theoretical cosmology and/or experimental or theoretical astro-particle physics interacting with CCAPP members and researchers at other institutions while utilizing extensive CCAPP resources and infrastructure, both experimental and theoretical.
CCAPP will support the local expenses (and often subsidize the travel for more junior researchers) for qualified visitors who spend a few days or a few months working with CCAPP members on CCAPP related science.
Take I-670 west to SR 315 north. Exit at Lane Avenue. Turn right.
Taxi or Uber is the easiest way to get from the airport to your hotel or campus.
Take any major highway to I-270. Take I-270 to SR 315 south. From SR 315 south, exit at Lane Ave. Turn left.
Take any major highway to I-71 north. Take I-71 north to SR 315 north. Exit at Lane Avenue. Turn right.
Take any major highway to I-70 east. Take I-70 east to SR 315 north. Exit at Lane Avenue. Turn right.
Take any major highway to I-70 west. Take I-70 west to SR 315 north. Exit at Lane Avenue. Turn right.
The Physics Research Building is located on main campus. CCAPP is located on the south end of the building on the Mezzanine (M) Floor.
For driving participants, visitor parking is available at Tuttle Garage or Lane Avenue Garage.


text: Tula Pink Self Healing 24x36 Cutting Mat. Premium Cutting Mat made from PVC vinyl with a solid plastic core is made to last. It's self healing technology allows for quick recovery of cuts from rotary blades all while extending the life of your blades with its safe working surface. This mat offer reversible cutting surfaces; gold guidelines available when measuring is required and a solid black surface when it's not. Store flat.

industry_corpus2: Manufacturing


text:
General: The first part of the year has you a little on a cloud. It's not all roses. In fact, you may stick your head in the sand and let a lot of things go while waiting for things to resolve themselves. They won't. And there's no guarantee that someone else is going to fix them for you. You bring the party, and they may help you out in return, but giving up control to someone else means that you'll be kept in the dark.
By mid-spring and on through the summer, you're focused on taking care of you. This may be a time where you can't rely on others to help you, or where you actually don't want other people to guide you. You may either be very generous or very stingy, but probably generous. You want to convince yourself that you're doing well, and the way you do that is by trying to convince other people that you're in a good financial position to buy them gifts or entertain them.
As fall turns into winter you're going to start focusing more on your own personal expression. Your bodily and material needs should be taken care of. From winter on through much of 2019, you're going to be about being you, no matter what that means. This is a time of self-discovery, and you may try new things to figure out who you are now and what you want. It seems as if you have a lot of choices - at you think you do - and you may stumble on the way, but you're not going to get hurt badly. You may not even feel it at all.
Love: If you're in a close relationship, the first quarter of the year may test you. It doesn't necessarily mean you'll fight and break up, but in order to keep the relationship from being ruined, you will both have to rethink and reassess what you want from each other and learn different roles. Otherwise, there will be power struggles and withdrawing. You have to get through this. If you do, your relationship will change, but for the better, no matter what happens to it.
Things ease up as April turns into May, but it's not all smooth sailing. At the very least, any explosive fighting or drama is petering out while other, perhaps worse things occur, like the silent treatment. It's possible that when nothing is wrong at all, you and your love are forced to be apart because of circumstances beyond your control or because temporary separation is better for your security and stability in the long run. For example, one of you may have to take a job far away, or one or both of you simply has to work more than usual.
Love gets easier through the fall and winter, though your closest relationships are still tested. Some of them may end by now if they're not strong. However, the ones that are meant to last will come through this well, though not the same. It's going to be your job to infuse the romance and the fun back into the relationship, even if everything feels like a chore, and even if you feel ignored and underappreciated.
Money: Make sure that whomever you share a bank account with, and whomever you owe money has an accurate idea of how much you have and how much you owe. Your partner or your creditor may demand too much, hide money, or think that you have more disposable income than you actually have. Be honest up front, even if it causes a fight. By springtime, you should be able to come to an understanding that allows you to follow your shared dream for a better future.
And during the spring, there's either more money or more opportunity to make money if you've been diligent at work and if you're willing to market yourself. You can put yourself out there and promote yourself properly, most of the time. Be careful not to grossly overestimate your value in early summer: no one likes a braggart or a person who can talk the talk but can't walk the walk. You will have to put your money where your mouth is this summer.
In autumn and winter, you get a chance to make money based on whatever you established over summer. By this point, you should have the skills, the network, and the security to know that you can do what it takes to keep generating an income. As you get closer to the end of the year, you'll want to celebrate, partially to relieve the tension elsewhere in your life. However, you don't have to worry about putting yourself in debt, since you're not likely to go over your limits.
Career: The beginning of the year may end up with you trying to keep any progress you've made in your career from disappearing. It may feel like two steps forward and three steps back. It may be that your attention isn't on your career, but your home and family. There may be an opportunity or blessing there that doesn't jive with advancing your career, and that's fine: by the time spring rolls around, you'll be ready to take this newfound motivation and apply it to making money and getting back to business.
You're brilliant over the spring, and if there's anything new and interesting you want to implement in your career, do it. This is a good time to make friends with smart people, especially those who know things you don't know. This is harder to do than one thinks, but you're a good listener right now, and that's sometimes all it takes to make new friends. This is the network that will help you get into new and interesting places and come into your own.
The weirdness you've been experiencing in your career and in your ambition is subsiding for the most part come late fall and winter. Things are still weird in some ways, but you're settled and ready to move on and make new things. Your ambition is bigger than just you and your family, but everyone around you. Politics, volunteering, and social betterment may be on your plate. If you have the opportunity to join a group or be more active in the community this winter, take it.


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We also can supply dance shoes,dance tights,dance bags and other dance accessories in very high quality and low price. We have our own Design Team,can accept custom designs,welcome to send us your designs or samples. We have many fabric materials can be selected,if have sepcial requirements,welcome to tell us,we can look for the fabrics for you.
You can contact with the salesmen, please send an email to her/him and tell more details about the logo or sticker. Besides, we promise that goods will be arranged as soon as possible and delivered in the shortest time. If you need, we can recommend some forwarders to you and you can compare the price and services.
Q5:Could you provide the design for me9 Of course, We are not only a manfacturer but also a designer. If you are interested in our bags, please do not hesitate to contact us for further information. Q8:How to contact with you 9 You are the number one priority at My Promo Bags and we are eager to hear what you have to say.
Dance travel bags Travel bag manufacturer More than 1000 styles of travel bag optional 360° trolley systems Bag OEM Customized Dance travel bags Business type: Manufacturer, welcome to visit our factory; Main Markets: USA , Europe, Japan, Canada, Australia, Middle East, Russia, South America, etc. Main Material of Travel bag : Genuine Leather, PU, nylon, polyester, PC, ABS, PVC, PP , aluminum, canvas and so on; Size of Travel bag : 15,16,17,18,19,20,21,22,23,24,25,26,27,28,29,30,31,32 inch, optional; Lining of Travel bag : Nylon or Polyester 70D, 150D, 190D, 210D, 420D etc. Trolley systems of Travel bag : Systems: build in, or 360 degree wheel systems, optional ; Handle: aluminum alloy, iron, optional; Wheels: iron, stainless steel, zinc alloy, aluminum alloy + Rubber, PP, optional; Zipper systems of Travel bag : Zipper’s Material: Nylon, Polyester, Iron, and Copper optional; Zipper’s size: 3#, 5#, 8#, 10#, optional; Lock with password: optional; Color of Travel bag : Black, white, red, pink, orange, blue, green, yellow, silver, purple, brown, or other optional; Printing of Travel bag : Sublimation, silk screen printing, hot stamping etc.
We are specialized making bags and leather products in different material as per requiremnts,located in huadu dist. 3.Please do not hesitate to give us a call or send an email if you have any questions at all. We are more than happy to answer even the smallest question for you and we will gladly give you a bid on any item you are interested in.
4.At the same of good quality, we also give customers good price. 5.We can ensure in China, at the same quality our price is the best. It is very easy and convenient for you to pay a visit to our factory.
Shenzhen Jingfengshun Bag Co., Ltd.
Alibaba.com offers 582 dance competition bags products. About 17% of these are travel bags, 12% are garment bags, and 4% are duffel bags.
A wide variety of dance competition bags options are available to you, such as polyester, nylon, and canvas. You can also choose from garment bag, external frame, and dress & gown bags. As well as from free samples, paid samples.
There are 596 dance competition bags suppliers, mainly located in Asia. The top supplying countries are China (Mainland), Pakistan, and Hong Kong, which supply 88%, 10%, and 1% of dance competition bags respectively.
Dance competition bags products are most popular in North America, Western Europe, and Northern Europe.
You can ensure product safety by selecting from certified suppliers, including 84 with Other, 78 with ISO9001, and 46 with BSCI certification.


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Our choir is the place to be at HLC. This energetic group of people meets every Wednesday evening at 7:00 p.m. in the Choir Room for practice, prayer, singing and fellowship. If you are interested in joining the Choir please contact the Church office at 859-689-7590.
Choir Practice will resume in the fall!!


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Hotdog Hotshot Roll out your cart and compete in New York City to see who will be top dog! Serve up toothsome treats in 15 legendary locations all over the Big Apple and find fun facts along the way.
my buddy hotdog "howlin hotdog" howling at some sirens. he's a twelve year old toy fox terrier and yes he is a good dog!!!
Nyanpire: The Gothic World of Nyanpire (ã�«ã‚ƒã‚“ã�±ã�„ã�‚, Nyanpaia) is a Japanese dÅ�jinshi manga series written and illustrated by Yukiusa about a black cat who becomes a vampire after being abandoned. An anime television series by Gonzo aired in Japan between July 6, 2011 and September 19, 2011.

industry_corpus2: Film & Entertainment


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Sadly, a Boston attorney was recently charged with operating a vessel under the influence of alcohol following a boating accident that resulted in a young woman losing her arm.
The website reported that the lawyer was arraigned recently on the charges while he was still wearing his swim trunks. Urbelis was allegedly operating the 29-foot boat Naut Guilty on May 30 when a woman, identified as Nicole Berthiaume, 19, fell overboard, catching her arm in the vessel’s propeller.
Berthiaume attends Quinsigamond Community College in Worcester, the newspaper reported.
Recently, we discussed how drunk boating accidents can be deadly and result in catastrophic injuries, as more people are expected to take their personal watercrafts out as the weather warms up. Unfortunately, alcohol use is a factor in almost a third of all recreational boating fatalities in the U.S., according to the Coast Guard.
As this case shows, if you operate a boat while you are allegedly intoxicated, you can face significant criminal charges. This is especially true if you are involved in an accident that results in deaths or injuries.
With this in mind, if you have been injured or had a loved one killed due to a drunken boater’s reckless actions, you may have certain legal rights allowing you to hold him or her accountable. It is very important for the proper investigation to occur, evidence is preserved and witnesses are interviewed in order to preserve the injured party’s legal rights. In the video above, maritime attorney Carolyn Latti explains what you should do if you are injured in a boating accident.
For more information about recreational boating accidents, visit our Facebook or Twitter pages, and continue to follow our blog or contact Latti & Anderson LLP.

industry_corpus2: Law & Justice