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1. The existence within the EU of different sets of national transfer pricing rules laying down that transactions between taxpayers under common shareholder control should be taxed as if they had taken place between independent taxpayers undermines the proper functioning of the internal market and represents a large administrative burden on taxpayers .
2. In order to find pragmatic solutions to this problem, the EU Joint Transfer Pricing Forum (JTPF) was set-up by the Commission in October 2002. The Commission has reported twice on the work of the JTPF through two Communications. The first Communication presented a Code of Conduct on the Convention for the elimination of double taxation (the “Arbitration Convention”) to ensure that it would operate more efficiently. The second communication presented a Code of Conduct on documentation requirements for transfer pricing within the EU- the EU Transfer Pricing documentation (EUTPD.) The Code of Conduct on EUTPD sets out rules for the amount and type of documentation that Member States will request and accept for the purposes of their own transfer pricing rules.
3. Transfer pricing related disputes between a taxpayer and a tax administration frequently lead to double taxation and hence to disputes between tax administrations to relieve this double tax. While the Code of Conduct on the effective implementation of the Arbitration Convention adopted by Member States in December 2004 should in principle help to eliminate transfer pricing double taxation in the EU within a time frame of not more than three years, it would be highly desirable to avoid such disputes between tax administrations in the first place.
4. This third Communication therefore has as its main objective to prevent transfer pricing disputes and associated double taxation from arising in the first place by introducing Guidelines for Advance Pricing Agreements (hereafter: "APAs") within the EU. APAs are agreements between the tax administrations of EU Member States concerned defining how future transactions between related taxpayers established in two or more Member States will be taxed. The Guidelines are based on the best practice identified by the JTPF.
5. The Commission considers that APAs Guidelines are an efficient tool for dispute avoidance with valuable advantages for tax administrations and taxpayers. APAs will provide in advance certainty concerning the transfer pricing methodology and therefore simplify or prevent costly and time-consuming tax examinations into the transactions included in the APA; this should lead to savings for all parties involved in an APA.
6. These APAs Guidelines explain how Member States should conduct the APA process and provide guidance for taxpayers involved in the process. Following the guidelines will result in a quick and efficient resolution of the APA process and in turn should encourage the use of APAs in the EU, leading to more dispute avoidance and less double taxation.
7. The full report compiled by the JTPF is contained in a staff working document. Within the overall scope of dispute resolution and avoidance, the JTPF considered several possible procedures which might lessen transfer pricing burdens on taxpayers within the EU. These were simultaneous tax examinations, expert opinion or mediation, a system of prior notification, consultation or agreement and the possibilities for APA procedures.
8. These are generally considered as methods by which two or more countries combine efforts to audit taxpayers together. While the JTPF acknowledged that this might have attractions for Member States from a compliance perspective, the opportunities for resolving disputes this way were considered to be fewer than the opportunities for creating them.
9. The JTPF reflected upon the statement in the commentary to article 25 of the OECD Model Tax Convention that countries might seek an advisory opinion from an expert to help resolve double taxation cases. Experts from the tax administrations did not consider the idea of intervention by a third party expert as a useful tool to prevent double taxation in the light of the Arbitration Convention which already compels the resolution of cases through the medium of an independent arbitration panel.
Prior notification, prior consultation or prior agreement.
10. The JTPF examined the possibilities for a framework for prior agreement or at least consultation before tax administrations make transfer pricing adjustments. The inter-action could be limited to the mere notification of a transfer pricing adjustment (which could speed up dispute resolution), be extended to prior consultation between tax administrations before a transfer pricing adjustment was made final (which could again speed up subsequent dispute resolution or avoid any subsequent resolution ever becoming necessary) or use of a system of prior agreement (whereby a tax administration would have to agree to provide a corresponding adjustment to eliminate any double tax before the first adjustment was made final) to prevent a dispute from coming into existence in the first place.
11. The JTPF found that, while it might be possible to do all of the above under existing mechanisms, to develop effective mechanisms would be time consuming and might well require fundamental changes in domestic laws. The JTPF felt that this might be outside its remit and that its time and resources should be concentrated on developing APA procedures.
12. The Commission considers that a system of prior agreement would eliminate all double taxation within the EU and therefore is of the opinion that this issue could usefully be deepened in the future.
13. An APA is an agreement between tax administrations over the way in which certain transfer pricing transactions between taxpayers will be taxed in the future. Hence an APA often prevents the need for a dispute between tax administrations over the transactions included in the APA. APAs are an exemplary method of dispute avoidance.
15. Given the significant advantages of APAs, the JTPF felt that it was appropriate to identify best practices for the conduct of APA procedures in the EU. These are contained in the Guidelines in the Annex to this Communication.
What are the salient points of the EU APA guidelines?
16. The guidelines lay down procedures for an efficient APA process and detail the stages usually found in an APA and what should ideally happen at each stage.
17. These guidelines focus on bi and multilateral APAs because they are considered as the most efficient tool to prevent double taxation. However the Guidelines also include a section on Unilateral APAs.
18. The guidelines envisage a four stage process and describe what should happen at each stage.
19. APAs start with the taxpayers' decision to request an APA. The guidelines suggest an informal approach be made to all the tax administrations potentially involved and recommend what should be done in this informal stage to ensure an efficient resolution of the APA application. Details of the type of information that should be included in the formal application are provided on the grounds that, although each APA will be different, the type of basic information likely to be necessary is often similar from case to case.
20. Once the formal application is received, the guidelines describe what should happen for the efficient conduct of the process. APAs will require that each tax administration involved checks the application to decide whether the proposed transfer pricing treatment in the application is acceptable. The precise details of the transfer pricing treatment will also need to be negotiated and agreed between the tax administrations involved. Details of how these processes should be done are laid down in the guidelines.
21. APAs will require formal agreement between the tax administrations involved, so that they and the taxpayers involved are guaranteed certainty over the tax treatment of the transactions. The guidelines provide details over what should be in this formal agreement so that this certainty is given.
22. A typical timeline is provided in appendix of the guidelines to illustrate the conduct of the APA process.
23. The guidelines also discuss some often problematic areas which frequently arise during, or even before, APA procedures and detail ways in which these areas can be rendered less likely to impede an efficient resolution of the APA process itself. The JTPF concentrated on areas where experience has shown that the most problems arise: retrospective application of the tax treatment in the APA, fees and complexity thresholds (which could constitute an undesired barrier to the APA process) and the types and amount of transactions that should be covered by the APA.
THE ARBITRATION CONVENTION AND RELATED ISSUES.
24. The follow-up of its work on the Arbitration Convention is an on-going process for the JTPF. It is vital that Member States respect the terms of the Arbitration Convention and of the related Code of Conduct adopted in December 2004.
25. With regard to the state of play of the ratification process of the Accession Convention to the Arbitration Convention, at the end of September 2006, twelve Member States had ratified it and the other Member States had indicated that the Convention should be ratified in the coming months.
26. The JTPF has also monitored the implementation of the recommendation included in its first Code of Conduct related to the suspension of tax collection. At the end of September 2006, sixteen Member States have confirmed that they allow suspension of tax collection during the dispute resolution procedure and the other Member States have replied that they were preparing revised texts granting this possibility. This issue will need further monitoring in the future.
27. Finally an update of the 2005 questionnaire on pending mutual agreement procedure (MAPs) under the EU Arbitration Convention that was filled in by Member States tax administrations revealed that none of the 24 cases for which the taxpayer had made the request prior to 1 January 2000 was sent to an Arbitration Commission.
28. The Commission considers that the number of long outstanding transfer pricing double tax cases means that, for reasons that need to be further explored, the Arbitration Convention is not eliminating transfer pricing related double taxation in the EU as well as it is supposed to. The proper functioning of the single market is therefore impaired. The Commission intends to consider how this failing can be addressed. It might well be that an instrument that ensures a more timely and effective elimination of double taxation, is necessary from the perspective of the single market. The Commission also notes that the AC deals only with transfer pricing related double taxation and that the new material in Article 25 of the OECD Model Treaty and attached commentary goes further by offering treaty partners a binding, compulsory arbitration procedure for eliminating all double taxation.
29. Considering these recent achievements in transfer pricing within the EU and the need to ensure a monitoring of the implementation of the new tools but also to continue the examination of several issues, the Commission has decided to renew the JTPF for a new mandate of two years.
30. The JTPF has begun examining the potential new work programme for 2007-2008.
31. Under the current work programme of the JTPF, in particular penalties and interest related to transfer pricing adjustments still need to be examined.
32. In the future, no doubt dispute avoidance and resolution will continue to feature as they are of major importance to taxpayers and tax administrations.
33. The Forum should also assist the Commission in monitoring the implementation by Member States of the Codes of Conduct and the Guidelines issued on the basis of the JTPF conclusions. Indeed Member States will have to report on the implementation of the different instruments and on practical problems ensued from their implementation. This will allow the effectiveness of these instruments in the elimination of double taxation in connection with the adjustment of profits of associated enterprises to be assessed.
34. As regards the Arbitration Convention, the Commission having received additional feedback since the adoption of the Code of Conduct, points out the following issues where clarifications should be given to ensure a better functioning of the Convention: the deadline for the setting-up of the arbitration commission, a common understanding of the definition of a serious penalty, the possible extension of the scope to more than two Member States, the deadline to implement the final decision, the role of the taxpayer, what is precisely covered by a transfer pricing adjustment (for example is thin capitalization to be considered). The Commission has finally received comments arguing for the setting-up of a permanent and independent Secretariat.
35. The Commission congratulates the JTPF for its work and its contribution to a better environment within the EU for lessening the burden of transfer pricing rules in general and dispute avoidance and resolution procedures in particular. The JTPF achievements since October 2002 have lead to a number of improvements that have facilitated cross-border trade and therefore have improved the functioning of the Single Market.
36. With regard to the work achieved by the JTPF in the field of dispute avoidance and resolution procedures, the Commission fully supports the conclusions and suggestions of the JTPF on APAs. On the basis of this work the Commission has drawn up the attached Guidelines for APAs in the EU.
37. These guidelines constitute a worthwhile blueprint for APA processes across the EU. By following the guidelines, Member States will encourage the use of APAs which will lead to better dispute avoidance, fewer disputes and less double taxation. This will help achieve a removal of tax obstacles and the primary aims of the single market: a better investment and more competitive business environment, growth and jobs.
38. The Commission invites the Council to endorse the proposed Guidelines on APAs in the EU and invites Member States to implement quickly the recommendations included in the Guidelines in their national legislation or administrative rules.
39. Member States are invited to report annually to the Commission on any measures they have taken further to these Guidelines and their practical functioning. On the basis of these reports, the Commission will periodically review these Guidelines.
40. Article 25 (3) of the OECD Model Tax Convention permits countries to enter into Adavance Pricing Agreements (Hereafter APAs).
41. An APA is an arrangement that determines, in advance of controlled transactions, an appropriate set of criteria (e.g. method, comparables and appropriate adjustments thereto, critical assumptions as to future events) for the determination of the transfer pricing for those transactions over a fixed period of time.
42. The APA should not agree precisely the actual profit which should be taxed in the future.
The APA should fix according to the arm's length principle arrangements for the determining the transfer pricing for the future transactions in the APA.
43. APAs must provide certainty for taxpayers and tax administrations. The precise way this can be done can vary depending on the law of the Member State in which the taxpayer pays tax.
44. At all times, the taxpayer is subject to the usual rules of the tax administration. Where there is an APA, a tax administration still has the right to conduct an audit. However, under normal circumstances, the audit is carried out only to check and monitor the APA by reviewing the terms and critical assumptions underlying the APA.
46. Tax administrations should be able to draw upon all of their skill and adequate resources to conduct an APA.
APA programmes should be centrally co-ordinated.
Tax administrations should carry out two broad roles to deal with an APA application: firstly, evaluating the application and secondly negotiating an agreement with the other tax administration.
47. The negotiations between tax administrations should be conducted by the Competent Authorities (Hereafter CAs). It is the CA's responsibility to ensure that the roles of checking and evaluating the APA and negotiating with other countries are carried out. This applies even if the CA calls upon other parts of the tax administration to provide specialist knowledge.
48. It is up to the taxpayer to initially decide which transactions should be included in an APA application.
The tax administration can review the application and modify or reject it.
The tax administration should accept the application where all requirements have been met.
In practice, taxpayer and tax administration should work together to establish mutually acceptable terms and conditions for an APA.
49. Domestic considerations will legitimately affect how a tax administration runs its APA programme.
50. Rules on fees and complexity thresholds can be used by tax administrations to ensure APAs are only made available where they are considered appropriate by those tax administrations.
51. It is for Member States to decide if a fee system is appropriate.
A fee should not be a precondition for an efficient service which should be provided as a matter of course.
52. If they are used, fees should be charged by reference to a lump sum amount as a pure entry fee and/or linked to the extra costs incurred by the tax administration as a result of the APA.
53. Fees are particularly appropriate where without a fee a tax administration would be unable to have an APA programme. But they should not be set so high so as to be a disincentive to apply for an APA.
54. If complexity thresholds are to be used, they should be used as a guide to whether an APA is appropriate and they should be dependent on the facts and circumstances of the case so not to be too prescriptive.
Complexity thresholds should be operated consistently for all taxpayers.
55. The likely attitude of other tax administrations directly involved in any APA should also be a factor in the operation of any complexity threshold: a threshold could be lowered where other tax administrations are willing to accept an APA application.
Whether a complexity threshold will operate to deny a taxpayer entry into an APA programme should be discussed at any pre-filing meeting.
56. The number or size of transactions should not constitute an infallible guide to uncertainty or transfer pricing risk. Complexity thresholds should take into account the relative size and transfer pricing risk (to the taxpayer) of the transactions.
57. Where a Multinational Enterprise uses the EU Transfer Pricing Documentation (EUTPD), this will serve as a useful basis for any APA application.
Useful additions can be any transfer pricing policy documentation on which the application is based and any reports received on which the application relies. Documentation requirements should not be unduly onerous for taxpayers but the tax administration must be given the opportunity to fully evaluate the transactions included in the APA.
Appendices A and B provide a list of documentation that is likely to be of use for any APA application. What is actually required in the formal application should be agreed at the pre-filing stage.
58. The specific information necessary to monitor the application of the APA should always be agreed upon as part of the APA negotiation. The taxpayer must maintain documentation throughout the APA so that the tax administration can monitor the way the APA is applied.
59. Tax administrations and taxpayers should work together in as cooperative a manner as possible to ensure that the APA is conducted as efficiently as possible.
64. The pre-filing meeting should allow all parties to assess the likely success of the APA. The tax administration should be provided with sufficient information to permit this assessment. This information should at least describe the activity and transactions to be covered, the taxpayers concerned, the preferred methodology, desired length of the APA, any rollback and the countries to be involved.
The pre-filing stage must allow the tax administration to make a reasoned judgement on whether the application will be acceptable.
Taxpayers should approach the tax administrations as early as possible once they are clear about their intended actions when considering an APA.
65. Tax administrations might consider anonymous approaches from taxpayers but nothing binding can be agreed on an anonymous basis. At any rate, the taxpayer's intentions should be relatively fixed for the anonymous meeting and as such an anonymous approach should not be a protracted process.
66. The tax administration should give a clear indication as soon as possible whether a taxpayer's subsequent formal application is likely to be accepted and also indicate, where possible, which aspects might be more controversial.
67. The taxpayer should approach all of the Member States directly involved in the envisaged APA. Where more than one tax administration is consulted, the same information should be provided to each (this should apply throughout the APA process).
68. As part of the pre-filing stage, CAs should consult with one another where necessary. Where such a consultation is deemed necessary, it should take place as quickly as possible.
In the pre-filing stage, the taxpayer and tax administration should discuss what documentation should be included with the formal application. Any complexity threshold should also be discussed. The tax administration should also use the pre-filing stage to influence the content of the application where this will aid an efficient outcome of the application.
69. Formal application for an APA should be made as early as possible in relation to the years to be covered by the APA and in particular soon after any informal approach. The taxpayer should make the formal application to the tax administration where it pays tax and at the same time to all other countries concerned. Where Member States have different administrative or legal procedures concerning APAs, it is the taxpayer's responsibility to ensure that all applications are made in time. The tax administration should endeavour to tell the taxpayer as soon as possible whether the application for an APA has been formally accepted for processing and to request as soon as possible any further documentation necessary to evaluate the APA and to formulate a position.
70. In the initial formal application, the taxpayer should try to enclose all relevant information necessary for the tax administration to evaluate the application and to come to a view about the methodology that will be used later to calculate the arm's length price. Appendices A and B contain details of the type of information that might often be necessary in all instances but is not necessarily a minimum and is not the maximum. The precise information necessary for the formal application should be tailored to the specific case.
71. A tax administration has the right to ask for supplementary information to evaluate the APA application.
72. The aims of the evaluation and negotiation are distinct even if it might sometimes be appropriate to carry out these tasks partly together. A balanced approach should be adopted to ensure that the evaluation takes place as quickly as possible and the negotiation begins as soon as possible.
In the evaluation, the tax administration should formulate its preferred terms and conditions for the APA. The negotiation with the other tax administrations concerned should resolve any differences which arise between tax administrations so that one set of terms and conditions can be provided to all the taxpayers involved.
73. As soon as possible after a formal application is received, the CAs of the tax administrations concerned should contact one another and establish a timetable for the APA. The taxpayer should be involved in the creation of the timetable and a model timetable is contained in Appendix C. In multilateral APAs, the CAs could agree that one CA takes the lead in organising the procedure.
74. The taxpayer should help the tax administration to evaluate the application through the provision of information. The evaluation should be completed as soon as possible to allow negotiation to be started.
75. Tax administrations should make every effort to keep the burden of the evaluation to a minimum by requiring only pertinent information; taxpayers must in turn provide any information requested as quickly as possible. It should be possible to agree what information is relevant.
76. All information provided to one tax administration should also be provided to the other tax administrations involved. Details of what information has been requested should also be exchanged. A convention should be established for each APA to say whether the taxpayer or, exceptionally, the tax administration through exchange of information will do this.
77. Where a tax administration forms an evaluation different from the taxpayer's application, then its evaluation should be discussed with the taxpayer.
78. As part of the evaluation process, the tax administration should try to obtain the tax payer's agreement with the position of the tax administration. It is advantageous for tax administration and taxpayer to work together to keep the proceedings on track to a mutually acceptable conclusion.
79. Tax administrations and taxpayers should work together in an APA to minimise any delay, in particular by making timely requests for necessary information and supplying information in a timely manner. Tax administrations should always consider making joint/common requests for information when this will further minimise delays.
80. As soon as its evaluation is complete, a tax administration should endeavour to begin negotiations and, if necessary, the other tax administration involved should endeavour to complete its own evaluation so that negotiations can begin.
81. The evaluation stage should involve CA inter-action where this will aid reaching an APA. Provisional agreement should be reached where possible. However, it is preferable that a tax administration has in mind at least a preliminary evaluation before actual CA negotiations begin.
82. If it would aid the APA procedure, preliminary negotiations should begin before the evaluation is finalised but this should not permit tax administrations to inappropriately postpone finalizing the evaluation.
83. For most APAs, each CA should produce a position paper containing the tax administration's evaluation. The formal exchange of positions should take place with an exchange of CA position papers. This should be done as soon as possible after the application is received.
84. Where appropriate, CAs do not need to exchange position papers if this makes the APA process more efficient and faster. But in most cases having all CAs prepare position papers before full negotiations begin will help to identify and thus resolve any disputes quickly and efficiently. Where one CA has prepared a position paper, any other CA involved in the negotiation should at least set out what disagreement exists.
85. The contents of a position paper should set out the view of the tax administration involved in the APA. Appendix D lists some of the details that are likely to be necessary in a CA position paper.
86. Negotiations should be started by the sending of CA papers. A timetable should be agreed for the negotiations. Taxpayers should be kept informed of all significant developments.
If the CAs agree, taxpayers should be allowed to attend CA meetings to address factual matters by making a presentation.
87. If beneficial, CAs should arrange regular meetings to keep the whole APA programme up-to-date but this should not impede arranging and conducting meetings on individual cases.
88. The formal APA should be given effect by formal agreements between the tax administrations involved (in a multi-lateral APA there could be one agreement between all tax administrations or a series of bilateral agreements between each tax administration).
All agreements should detail the terms and conditions of the APA.
89. These agreements should give certainty to those involved in the APA and provided the relevant terms of the APA are met, then the transfer pricing for the transactions will be as determined in the APA and that the transactions will not be subject to a different interpretation by the tax administration. Tax administrations should ensure that they are able to provide this certainty.
90. Appendix E contains information which is likely to be necessary for all APA formal agreements.
Transac tions and Participants in the APA.
91. It is up to the taxpayer to initially decide which transactions and which group entities he wants to have included in the APA. But it is the decision of the tax administration whether it accepts the taxpayer's application.
92. It is important that tax administrations are as flexible as possible in allowing the taxpayer to include what he wishes in the APA. It is recommended that the taxpayer's logic for excluding as well as including companies and transactions is explained in the application.
93. A tax administration should exchange information (EOI) spontaneously (subject to any domestic law limitations) with another tax administration which the first tax administration feels should be included in the APA. The taxpayer would need to be consulted about which tax administrations to involve in the APA since the taxpayer's agreement to the terms and conditions of the APA needs to be obtained.
94. The taxpayer should describe in the application the assumptions on which the ability of the methodology to accurately reflect the arm's length pricing of future transactions are based.
95. Critical assumptions are by their nature vital to the APA and should be drafted carefully to ensure the capability of the APA to reflect arm's length pricing.
96. Taxpayers and tax administrations should attempt to identify critical assumptions that are based where possible on observable, reliable and independent data.
97. Critical assumptions should be tailored to the individual circumstances of the taxpayer, the particular commercial environment, the methodology and the type of transactions covered.
98. Critical assumptions should not be drawn so tightly that certainty provided by the APA is jeopardised but should encompass as wide a variation of the underlying facts as those involved in the APA feel comfortable with.
99. The APA agreement should include parameters for an acceptable level of divergence for some assumptions in advance and only if these parameters are exceeded should a renegotiation become necessary.
100. Taxpayers should inform their tax administrations if critical assumptions are not met.
All those involved in the APA should consult with each other to examine the reasons why a critical assumption has not been met and to see if the APA methodology is still appropriate.
An attempt should be made renegotiate the APA if at all possible.
101. Rollback – when provided for in domestic legislation –can be considered where it will resolve disputes or remove the possibility of disputes in earlier periods.
102. Rollback should only be a secondary result of the APA and should only be carried out where it is appropriate to the facts of the case. Similar facts and circumstances to those in the APA should have existed for previous periods in order for rollback to be appropriate.
103. Rollback of the APA should only be applied with the taxpayer's consent.
104. A tax administration has recourse to the usual domestic measures if, as part of the APA process, it discovers information which would affect the taxation of earlier periods. But tax administrations should advise the taxpayer of any such intended action to give the taxpayer the opportunity of explaining any apparent inconsistency before making a tax re-assessment concerning previous periods.
106. Although there may be circumstances where the taxpayer has good reasons to believe that a unilateral APA is more appropriate than a bilateral, bilateral APAs are preferred over unilateral APAs. Where a unilateral APA may reduce the risk of double taxation to some degree, care must be taken that unilateral APAs are consistent with the arm's length principle in the same way as bilateral or multilateral APAs.
107. In the first instance the taxpayer has the right to decide whether a unilateral or bilateral APA is required.
108. The option of including another MS in the APA could be considered by the MS preparing for a unilateral APA. Taxpayers however should not be forced into a bilateral APA.
109. Tax administrations are entitled to turn down requests for unilateral APAs where the tax administration feels that a bilateral or multi-lateral APA is more appropriate, or feels that no APA at all is appropriate.
111. With the "Code of Conduct" (Business Taxation), Member States have committed themselves to spontaneously exchange details of concluded unilateral APAs. The Exchange of Information (EOI) should be made to any other tax administration directly concerned by the unilateral APA and should be done as swiftly as possible after the conclusion of the APA.
Appendix A – A list of the type of information that is likely to be necessary with the formal application for a bilateral or multilateral APA.
The actual information will vary depending on the facts of the case and would need to be discussed between the taxpayers and tax administrations, ideally at the pre-filing meeting.
This information can be considered as two broad types: information about the past –historical information – which might already exist in some format but will need to be compiled for the APA and information that may need to be created specifically for the APA.
When considering historical information, MS should keep in mind that APAs concern the future and that historical information may have less relevance for future periods. That said, historical information will be necessary to place the APA in perspective and to allow better judgements about the future to be made.
The pre-filing stage is a useful time for tax administration and taxpayer to decide what information should accompany the formal application. The aim should be to strike a balance between the tax administration having enough information to consider the application properly and the taxpayer not being required to produce unnecessarily onerous amounts of information.
In all cases the tax administration has the right to require further information and the taxpayer has the right to submit further information.
113. Names and addresses of all associated enterprises (including all permanent establishments) in the APA.
114. A group structure showing all entities involved in the trade of the enterprises in the APA.
115. An analysis of industry and market trends which are expected to affect the business. Any marketing or financial studies for the business which lead to this expectation should also be provided where relevant. An outline should be provided of the business strategy expected to be used for the period of the APA and, where different, of the strategy employed for previous periods. This might include projections used in the plan for the future, management budgets, information on expected business trends and competition, future marketing, production or R&D strategy. Details of who has the power and responsibility of developing and dictating business strategy could be provided.
116. The period for which the taxpayer desires that the APA should apply, including any request for rollback.
118. The reason why the taxpayer feels an APA is appropriate for these particular transactions.
119. The critical assumptions integral to the APA.
121. A review of the five OECD comparability factors including comparables and any adjustments made to achieve comparability.
123. A demonstration by reference to financial information of how the proposed methodology is to be implemented.
124. A list of any APAs already entered into by any of the associated enterprises involved in the APA which relate to the same or similar transactions if not already available to the tax authorities.
126. the three years statutory accounts.
127. an analysis of product/service lines showing gross and net margins with associated costs for the products/services to be included in the APA, if available and useful.
128. A list of any legal agreements between any associated enterprises which affect the transactions in the APA. For example, licence agreements, purchase agreements, distribution agreements, R&D service agreements.
129. For any years where a rollback is requested – where possible in domestic law - details of the tax position of each entity involved for these years, e.g. tax return agreed, submitted but not agreed, submitted and under audit etc., together with details of any MAP process still open and an analysis of the time limits laws in place in each relevant jurisdiction to show whether years of assessment are capable of being adjusted.
The functional analysis is the key tool for any transfer pricing work. The contents should be tailored to the specific taxpayer and the transactions in the APA. Dependant on the situation, the APA application should also show to a certain extent which entity carries out what functions in the overall business of the MNE. Tax administrations however should keep in mind that they are not evaluating transactions which are not in the APA. This information will have to be sufficient for them to understand both ends of the transactions under review.
All the activities relating to the transactions covered by the APA should be described (Research and development, manufacturing, distribution, marketing, the type of service activity carried out, etc.) The economic and entrepreneurial worth of these activities should be made clear along with details of how these activities inter-act with those carried out by other group entities. The market and the level in the market place of the entity should be described, along with the type of customer, what product is sold, how it is developed or acquired, who it is acquired from and sold to.
The risks assumed by the entity with regard to the transaction s in the APA should be described and assessed. Typical risks might include product, technological, obsolescence, market, credit, foreign exchange and legal.
The amount and type of working capital, tangible and intangible assets utilised in the APA should be described. Again the relative importance of these in the trade should be analysed if possible.
There will be further details necessary if intellectual property right (IPR) is used in the transactions in the APA. Information should be provided on how the IPR was created within the group or acquired by the group. It should be made clear which entity now owns the IPR and how it came to do so, how it is utilised and what value it adds to the business.
Every APA is different; therefore, there are inherent dangers in stipulating a common timetable for every APA. Best practice is for all parties to formulate a timetable as early as possible once the APA application has been received. Tax administrations can help keep the time to negotiate an APA as short as possible by examining information quickly and efficiently; taxpayers can help to keep the time to negotiate an APA as short as possible by providing complete information quickly. The timetable below is illustrative , but contains all the stages typically found in APAs.
An informal approach is made by a taxpayer to two tax administrations, requesting an APA. The tax administrations listen to the statements made and indicate whether the particular case merits an APA. The tax administrations consult with one another to ensure both will agree. Each has brief discussions with the taxpayer over what information should be provided in the first instance and explores what methodology will be appropriate.
The formal application is received by each tax administration. The CAs establish in month 1 a timetable to evaluate and negotiate the APA. Both tax administrations conduct an initial review independently and issue information requests if necessary.
Tax administrations continue to evaluate independently with the full cooperation of the taxpayers. A first full face to face meeting could take place with a presentation to all involved parties by the taxpayer. The CAs consult as appropriate. The taxpayer is involved in this evaluation and is consulted. By the end of this period each tax administration has formulated its position. The CAs are able to exchange position papers. They agree to meet to discuss these in Month 14.
Discussions occur between CAs. Further clarifications are obtained from the taxpayer who is kept informed of the CA negotiations.
The CAs reach agreement. The taxpayers are consulted and indicate their agreement.
The APA is formally agreed between the CAs. Formal documents are exchanged. The taxpayers receive assurances that the APA is acceptable.
More complex cases may take longer, but, with the cooperation and planning of all parties, the time taken to conclude an APA should be kept to a minimum.
Since each case will be different position papers will vary. But below is general guidance which should be applicable for the contents of all position papers. The key to concluding an APA procedure without unnecessary delay will always be to commence CA negotiations most often through a position paper as soon as possible after the application is received.
130. The conclusion of the CA together with a rationale. This should include details of the preferred methodology and the reasoning for this.
131. Reasons for any rejection or modification of the taxpayer's initially preferred method.
132. Details of the facts considered as most relevant in forming the above conclusion. If relevant, special consideration should be given to any facts which came to light during the APA process as opposed to in the original application.
133. Details of the critical assumptions that the APA will be dependent on.
134. A position on any retrospective element and on the future length of the APA.
135. Suggestions on how the APA should be monitored.
136. A description of the Treaty law and domestic law that will govern the APA and provide certainty for the taxpayer.
137. The duration of the APA and day of entry into force.
138. Details of the methodology acceptable for determining transfer pricing and the critical assumptions (see appendix F) that must be followed for the APA to apply.
141. An agreement of what documentation is to be maintained throughout the APA to allow monitoring to take place, for example an annual report.
142. Any agreement on any retrospective treatment.
143. Any circumstances which will require the APA to be revised.
152. the enterprises that will operate in each jurisdiction and the form in which they will do so.


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Connecting cultures through the arts. Engaging projects that in essence tell stories.
Would you like to help? Even a small contribution can make a difference. We are already working towards our next project: a contemporary art exhibition with work by Greek and Italian artists.
Secure transaction via PayPal by accessing your personal account and clicking on “send money to family and friends”, you will need to enter our email address info.orasi [at] gmail.com (you will bear the transaction fee).
Secure transaction via PayPal by clicking on the donate button below (in this case a transaction fee will be detracted by the donated amount).

industry_corpus2: Film & Entertainment


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Buses carry up to 50 people and occupy less road space than 50 cars carrying one passenger each.
During the morning peak, the bus lane on the Sydney Harbour Bridge takes more people to the city than all of the other city bound lanes combined.
Bus and bus only lanes, bus bays and bus 'B' signals.
Colouring all bus lanes red (excluding the M2 motorway bus lanes).
A public transport priority traffic signal system.
‘B’ signals are a special type of traffic signal which apply only to buses.
They are are generally attached to normal traffic signals and appear as a red or white ‘B’ on a black background.
‘B’ signals give buses priority by allowing them to pass traffic that is queued at the intersection or make special bus-only turns.
Before the normal traffic signals change to green, the ‘B’ signal changes from red to white and only buses are legally allowed to proceed. When the normal signals turn green the other vehicles can then move off.
Roads and Maritime Services has successfully trialed this system which can alter the sequencing and timing of traffic signals to give priority to buses.
The system uses technology such as global positioning satellites and roadside antennae to deliver information about the bus and its location. This information is used to forecast the arrival time of the bus at traffic signals ahead.
Allow the bus to maintain its scheduled timetable.
Give bus passengers a more reliable service.
Allow bus operators to schedule their buses more efficiently.
The same technology can be used to forecast arrival times at bus stops, with the potential to provide passengers with real-time information about the arrive of their bus.
The concept has been trialed on Sydney's Northern Beaches and will be refined for more widespread use.

industry_corpus2: Transportation


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The extent to which we believe in free will can determine our sense of self – how we feel about ourselves, the world, and our place in it. Diminishing our free will can trigger depression, anxiety and lower self-esteem. That’s according to a study published in Social Psychological and Personality Science.
Researchers at Texas A&M University worked with two groups of 300 participants, giving them tests to examine the relationship between free will and sense of self, and between free will and authenticity. They discovered that people with low free will showed “greater feelings of self-alienation and lower self-awareness” as well as lower authenticity compared with the group who had higher free will.
My experience of working with clients in therapy bears out these findings. People can feel depressed, depleted and hopeless when they feel they have no choice over aspects of their lives. This can put them in a victim position from which they feel unable to escape. Things get ‘done’ to them, and they have little sense of any agency over their own lives. The process of being in therapy can help identify options, and instil a belief that they are in charge of their own lives. Sometimes that can start with a very small step, and gradually they can make more decisions in alignment with who they truly are – instead of looking to external factors for encouragement or validation.

industry_corpus2: Health & Medicine


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Nintendo Switch Only today $299.99!
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ROG Strix GL753 has been newly redesigned for 2017 with a sleek and aggressive styling on the chassis and an ROG Aura Keyboard.
ROG Strix GL753 comes with Windows 10 Home pre-installed and Microsoft DirectX 12 support.

industry_corpus2: Gaming


text:
Definition - What does Access Control Facility (ACF2) mean?
The system status is monitored continuously and completely, and any access attempt is logged so it helps to identify potential intruders, and allows for the identification and analysis of changes and trends in the use of the system.
Access Control Facility was originally developed by Barry Schrager, Scott Krueger and Eberhard Klemens in 1978 at London Life Insurance based in London, Ontario. The discretionary access control system was developed for the VSE, MVS, and VM operating systems. It was originally developed as a response to IBM’s RACF product developed in 1976 as an answer to the 1974 SHARE Security and Data Management project.
The North American marketing rights for the software were acquired by Cambridge Systems, who then added the "2" to the ACF name in order to differentiate it from the prototype and from the competition’s ACF/VTAM (IBM).
Quiet Mode - Only data set rules are disabled.
Rule Mode - Individual access rules are defined.
Log Mode - Access is permitted but still logged.
Abort Mode - This is the default mode where ACF2 bars access, logs, and issues messages.
Warn Mode - Access is allowed but issues warnings.

industry_corpus2: Computing & Telecommunications


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Solangelee began her media carrier in 1996 in Puerto Rico and later joined the Univision family in South Florida in 2001. She was just named by People Magazine one of the most powerful Latin women in entertainment. In her current role she oversees the content of daily live shows, in-house productions, and the network’s special projects. In her role she supervises a team of 80 journalists, anchors and producers, camera and editing professionals and technical crews.
She oversees the creation of original content and restructuring of pre-existing content. Prior to this position, Solangelee was Director of Special Projects for the network’s coverage of events such as the elections in Latin America, 2010 FIFA World Cup, and other history marking stories. Solangelee was Senior Executive Producer of one of the leading news shows Primer Impacto for over eight years. Her diverse production roles throughout the years have exposed her to the various components of television production, for the delivery of both news and entertainment content.
As a bilingual media professional, she received a Bachelor of Arts degree in communications and journalism from the University of Sacred Heart, San Juan, Puerto Rico. Solangelee currently resides in Miami, Florida with her husband.


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DESCRIPTION: The sequel of the addictive and challenging motorcycle stunt game Moto X3M 2! New dangerous obstacles and new bikes for upgrades. Have your dose of adrenaline rush and unlock all the achievements and be on top of the leaderboard!
INSTRUCTIONS: You arrow keys to play.


text:
Over the last eight years, I have had the opportunity and honor to have photographed President Barack Obama either during his visits to Philadelphia or during my travels to the White House.
The feeling really can’t be described in words, but the chance to take photos of the most powerful man in the world gives you a sense of humbleness and happiness. I remember the first time I went to the White House was back in 2009.
The Philadelphia Phillies had just won the World Series so I applied for credentials to cover them when they visited the White House. To my surprise, I was approved to cover the event. So I made the trip to Washington, DC and I almost missed my chance.
Other than me flying down I-95 and the beltway at an undisclosed rate of speed (insert 5th Amendment speech here), I was not too familiar with the city and wound up walking to the opposite side of the White House.
After a few minutes and help from security, I was told which way to go. Running around the corner and just making it to the gate I showed my ID and was given my credential.
It was like holding an uncut diamond or holding the winning lottery ticket in my hands. What I didn’t realize until later was that the wealth was not only seeing my favorite team being honored for their hard work on the field, but I was a part of history by listening to the speech of the first African-American president in the history of the United States.
Click after click, I just kept taking photos of the team and Barack. Before I knew it the event was over. Back to reality. Before I left the South Lawn I had to take a photo just to show that I was there.
Through the years, whether it was at the airport, a middle school, at the Benjamin Franklin Parkway or at the White House, his presence and messages of hope and pride made you believe that what he wanted to do for our country was genuinely sincere.
Other than the Air Force One flight delay in Newark, NJ where I was rewarded with official presidential matchbooks, my greatest memory of the President and me was during one visit to Philadelphia.
I stopped taking photos and just watched the president walk off the plane and onto the tarmac. Everyone was quiet, snapping photos or getting a video feed ready.
Everyone on the riser looked at me and I didn’t know what to say. Deep inside, I was filled with pride that this Colombian-born Philly native had a brief presidential moment to remember for a lifetime.
To President Obama I say thank you for your years of service to this country. You did all you could despite odds and opposition to truly make this country great. You also gave me that extra spark in my craft to truly believe that dreams can come true. If you need some post presidential photos done, I’m there!

industry_corpus2: Politics & Administration


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I don't mind so much when your kids make noise in restaurants. It usually brings a little smile to my face because I know you're raising a family and hopefully, in some small way making the world a better place by trying to be good parents.
I do mind when you smack your five year old kid across the face and proceed to tell him "I hit you so you'll know who's in charge".

industry_corpus2: Hospitality & Catering


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The 2019 Lexus Ct Mpg has a lot going for it, including a hybrid model, but you’d be wise to cross-shop its rivals as well. Additional new features for the 2019 Lexus Ct Mpg include a heated steering wheel, and optional heated and power operated front seats on lower-trim models with cloth upholstery. Front-wheel drive is standard and all-wheel drive is optional. In addition to the gas-only model, the 2019 Lexus Ct Mpg is also available as a hybrid with all-wheel drive as standard.
In a 2018 comparison test that included the other cars, the 2019 Lexus Ct Mpg placed fifth. Handling also proved to be another 2019 Lexus Ct Mpg weak spot and we found the steering to be numb.
The 2019 Lexus Ct Mpg, on the other hand, is a better package, as we noted in a 2017 First Test, thanks to its smooth powertrain and well-calibrated brakes that smoothly transition between regenerative and mechanical braking. However, since it isn’t a plug-in hybrid, the 2019 Lexus Ct Mpg doesn’t have much EV mode range and can only travel around 0.5 miles on electricity.A rear view camera with rear parking sensors is now standard on all models.

industry_corpus2: Automobiles


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We provide daily backups that are kept offsite and you will have backups from the past 7/30 days. We give you full, unrestricted access to your Guppy backups via our web-based 1-click Restore Manager. Moreover, our 24/7 technical support is always ready to give you a hand if you need help restoring your Guppy website and that comes at no extra cost.
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Women In Design is a student group at the Graduate School of Design at Harvard. In March 2013, WID initiated a petition to grant equal recognition to Denise Scott Brown, for her exclusion from the Pritzker Prize, which her equal partner Robert Venturi won in 1991. The campaign has generated a huge amount of discussion throughout the design world with regards to the changing nature of the profession and the increasingly collaborative nature of architecture. In June 2013, in direct response to the mass amount of support the petition generated, the AIA passed a motion to expand the AIA Gold Medal to include more than one recipient in support of joint creativity. Read more about the Campaign here.
Women in Design has over 10 years of history at the GSD, and has organized lectures panels and a diverse range of events supporting the work of women in design. A re-launched in Spring 2013 began with Billie Tsien, Principal at Tod Williams Billie Tsien Architects, who joined the group for an intimate discussion. The group has also organized events with designers including Patricia Patkau, Canadian architect and co-founder of Patkau Architects. In collaboration with the Loeb Fellowship Program, WID hosted Loeb Fellow Cathleen McGuigan, editor-in-chief of Architectural Record, whose brilliant lecture titled “Women and the Changing World of Architecture,” can be viewed here.

industry_corpus2: Subject Education


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I’ve been reading some really good, thought provoking blogs today about learning and learning theory.
I started with Nick Shackleton-Jones’ post on a Unified Learning Theory http://bit.ly/c3H9YZ. Nick picks up on the recent spat about Learning Styles see our blog http://goodpractice.com/blog/learning-styles-its-a-bit-more-complicated-than-that/ and uses that to present the need for a more unified research based theory of learning. I couldn’t agree more with the need for the research and I’m looking forward to reading his ideas and findings very soon.
Our own input to this wider research started with the survey we did on How Managers Learn (in their own words) and we’ve made the underlying data available from the same link.
The second blog that added to my thinking was Michael Eury’s Exploring the Learning Landscape. I enjoyed this because it gave me a new perspective on informal learning and the way we can map learning onto our current environment to get a feel for what we are covering and where the ‘deserts’ are. The use of the axis of Structure and Control is interesting, as are his views on the motivation of the learner.
These are both really useful posts in helping to develop new ideas and I need to consider them further to see how I integrate them more fully into my own thinking. I know I’ll want to start with performance outcomes and work back from there as I outlined in Exploring the Performance Landscape. In terms of research I’d like to specific organisational research developed as I think that whilst there is cross-over to education the practical need to do something with the learning in terms of perfromance brings a different dynamic that cannot be ignored. I’d like to see this linked to performance outcomes rather than learning outputs. This takes the research into a range of fields beyond the narrow field of learning into a range of areas from communication, organisational culture, performance management, reward, leadership and so on. If learning in organisations is about improving performance outcomes then I think we need to develop a unified performance theory and then practice. Easy said and I know very complex due to the situational aspect of performance, but research rather than theory must be the starting point.


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Personal photos have increased dramatically due to the proliferation of smart phones and digital cameras. How to manage and retrieval relevant photos from a large-scale personal photo collection becomes a practical and important issue. Traditional text-query based image retrieval largely relies on the offline generated tags for each photo in the album, which is not effective if the user’s text query does not match the pre-defined tags.
Thus, this project calls for solutions that can allow a user to freely use natural language to communicate with the photo search engine to find the relevant photos that he wants. Specifically, we expect the solution is able to: 1) allow the user to use a phrase, or a sentence as query; 2) retrieval the relevant photos in a fast manner.
Image retrieval, natural language processing, feature embedding, deep learning.


text: New 2017 Kia Cerato for sale in Dubai. Available from Strong Auto FZE. Automatic transmission, 4 cylinder engine, 16″ wheels and black interior. Never driven, GCC specs.


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Water Dispenser price in Nepal: In this busy everyday life everyone would want to have done their basic day to day things promptly, and effortlessly because there is no waiting and losing of valuable time for small stuffs. Then why would someone struggle to fill up water bottles with difficulty or wait for water to boil? Water dispenser is something that dispenses both normal and hot water so that you can now dispense water normally saving your most precious time that could be wasted in waiting for long time to boil water or you yourself taking long to fill the water bottle. If you have finally made up your mind about buying water dispenser but are confused about which one to buy? Or where to buy from? at least price? Okdam.com it all sorted out. We offer you best water dispensers in Nepal at low prices, where you can find wide variety of best water dispensers from world’s leading companies with no features and specifications hidden.
Now you can compare and choose the best among varieties of water dispensers from our online store for convenient and hassle-free shopping. Water dispensers are suitable for any small or big organizations, shops, restaurants, café, school, households and different other areas and provide constant supply of fresh, hot or cold water easily than ever before. Revive, replenish and revitalize your place with wide range of water dispensers from top brands like Baltra, Home Glory, CG, Samsung, LG, Tata, Electron, Kent, Livpure at low prices at okdam.com which has been serving as leading online store in Nepal. Hurry up and find best quality hot cold water dispensers in Kathmandu, Nepal at Okdam at affordable prices where we are working hard to provide best online shopping experience in Nepal with best quality products at low prices.

industry_corpus2: Manufacturing


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NICE, FRANCE — Mel Dark rolls a baby stroller with her new-born daughter into an Irish bar and greets me with a hug. It is the first time we have seen each other in more than five years and the meeting begins with a grim recounting of what occurred just hours earlier. Dark, a former Torontonian, and her young family have made Nice their home for the past two years. Drawn to the heart of the French Riviera by the scenery, calm pace of life and less expensive cost of living, Dark contemplates the terrorist attack on Bastille Day and remains resolute.
“We just have to go about life as usual. I get the sense the city is determined to do that,” says the accomplished copywriter who is part of a vibrant expatriate community in Nice.
A day after a maniacal driver plowed a truck into a crowd of revellers celebrating the French national holiday, the streets of Nice were not what many outside of the city might expect. It was calm and very much business as usual. Police and army officers occupied parts of the city — including squares, parks and popular promenades — and lots of media took up residence outside of Le Meridien Hotel on the waterfront, sight of the attack.
But cafes, restaurants and beaches had a lot of people. Maybe not as much as usual, but the city on the Baie des Anges, which feeds into the Mediterranean Sea, was far from demoralized by the actions of one thug. Tourists, however, have not exhibited the same resolve.
Dark rents a studio apartment through Airbnb and says her guests who had been scheduled to arrive on July 14 cancelled. A hotel worker I spoke to said many properties reported cancellations (though arriving journalists took up the rooms, limiting the loss of revenue).
France is the most visited destination in the world. An honour that reflects its cultural significance to the world, its ability to deliver extraordinary experiences, and the ease and comfort which with people from around the globe usually feel when they are in the nation.
The reputation has been built up through decades and the latest terrorist attack on France won’t stop many from coming. In 2015, the nation reported a 4 per cent increase in tourism from the previous year, attracting 85 million tourists who accounted for 150 billion euro ($215 billion CAD) in revenue.
David Scowsill, president and CEO of the World Travel & Tourism Council (WTTC), expressed the importance of the country in the global tourism market.
It is a sentiment that concerned citizens everywhere should adopt, I think. The less we travel, the less we understand our cultures and our distinctiveness, the less we are able to collaborate and evolve, the less we are able to enjoy the joys of being alive on this earth. The less we travel, the less we live. Terrorists want to paralyze you with fear. When you travel, you do as Dark and the citizens of Nice are intent today on doing — proving you can make a statement simply by going on with life as you want to live it.

industry_corpus2: Travel & Geography


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Submitted by Cougary on Tue, 08/14/2007 - 09:54.
My name is John. 'Cougary' is because I'm a fan of the Keighley Cougars RFL team. They're no great shakes these days, but I love them.
Submitted by theRat on Mon, 06/11/2007 - 14:54.
I'm not that active, more of a lurker. Still, my name is Raul Gonzalez.
Hey, lurkers are people too.
Submitted by Richard Adler on Mon, 06/11/2007 - 20:55.
Submitted by kelson.philo on Mon, 06/11/2007 - 11:48.
Submitted by sim on Sun, 06/10/2007 - 12:55.
Submitted by kybernetikos on Sat, 06/09/2007 - 18:44.
folks call me 'kyb' when kybernetikos is too long.
Submitted by paulbhartzog on Sat, 06/09/2007 - 16:30.
Call me Zog or call me later, either way.
No, really, Paul is fine. Name's Paul B. Hartzog.

industry_corpus2: Sports


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Harvey Mason Jr. has (probably) done more in his life than you have. The 6-time Grammy winner is one half of The Underdogs, a production duo that has written and produced songs for Whitney Houston, Britney Spears, Jennifer Hudson, Justin Timberlake, and Toni Braxton. Mason also oversaw the musical production of Straight Outta Compton, Pitch Perfect 2, The Wiz and a lot more, and on top of all that, he was a guard for the Arizona Wildcats who played alongside Steve Kerr, Sean Elliott, and Kenny Lofton and made a Final Four under coach Lute Olson.
On this edition of the FTW Podcast, Mason joins to talk to me about the Grammys (which are live this Monday night on CBS), the state of music in 2016, what it was like playing with Steve Kerr, the problems with AAU basketball and how it’s stunting the development of young basketball players, why Lute Olson was such an incredible coach, Kanye West, TV musicals … We talked about a lot.


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I have a 1.5 year old child who came with petechiae (small skin bleeds) around 15 days back. On presentation the platelet counts were ~ 20,000 and we diagnosed the child as ITP (Immune Thrombocytopenic Purpura). The platelet counts improved dramatically after IVIG infusion, and we discharged the child after 2 days. Unusually, the child came back to us after 15 days with recurrent symptoms and again the Platelet counts were ~ 20,000. At this point of time I discussed the case with a Pediatric hemato-oncologist in PGIMER, and was told that nowadays they have become very liberal in NOT treating cases of ITP. According to him, even platelet counts as low as 5-10,000 may not need treatment unless they have active mucosal bleeding, since the risk of serious bleeds remains very low in children with acute ITP. This is certainly something that I was not aware of. In fact he went on to say, that ITP has now probably become a disease of the mind... in the mind of the patient, and in the mind of the doctor. He did agree that this approach was probably difficult for an individual doctor in Private Practice to adopt, but believes that this is the scientifically accurate approach.
Here is an interesting article that I found related to recurrent ITP.
Recurrent idiopathic thrombocytopenic purpura in childhood.
Haemophilia Center-Haemostasis Unit, Aghia Sophia, Children's Hospital, Athens, Greece.
Idiopathic thrombocytopenic purpura (ITP) is a common haematological disease during childhood, that usually has a benign course; however, literature on the recurrent form of the disease (rITP) is limited.
rITP was characterized by intermittent episodes of thrombocytopenia (TP) followed by periods of recovery, unrelated to therapeutic intervention. We retrospectively reviewed features of patients with rITP, diagnosed and systematically followed up at our center, during the period 1975-2004.
Forty-eight of 795 children with ITP (6.0 %) presented with rITP. The majority of patients (68.8%) had only one recurrence, whereas only one patient had four. A time interval between two episodes longer than 3 months (up to 96) was identified in 2/3 of episodes and less than 3 months in 1/3. The initial episode and the first recurrence mostly shared features of acute ITP; however, 22.9% of the episodes appeared with a chronic self-limited course. Bleeding manifestations were rare (18.6% of episodes) and mild, and they tended to occur in severely thrombocytopenic patients, mainly at the onset of the initial episode; intracranial hemorrhage (ICH) occurred in a toddler with short duration thrombocytopenia. Intravenous gamma globulin (IVIG) or corticosteroids were administered in 24.5% of episodes. None of the patients needed splenectomy. Conclusion: rITP is a rare, mild, self-limited type of ITP, although ICH may occur in a profoundly TP child. Recurrence may occur close or far apart to a previous isolated TP episode. The duration of episodes varies considerably from patient to patient and from episode to episode in the same patient. The pathogenesis of rITP still remains unclear.
Pediatr Blood Cancer. 2008 Aug;51(2):261-4. doi: 10.1002/pbc.21569.
Comments: What I found interesting was the fact that 6 % kids with ITP would have recurrence, and 1/3rd would have recurrence within 3 months. Also rITP has a good prognosis in general, and serious bleeds are very rare. I believe that it is important to counsel parents regarding the uncommon risk of recurrent thrombocytopenia in this situation, especially when expensive treatment like IVIG is given to the patient.


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The Littlite Anser Dual LED is specifically designed for microscope illumination, and is also an excellent choice for any application requiring strong, even illumination. The two gooseneck LED lights can be positioned to illuminate from multiple sides eliminating shadows.
The Littlite Anser Dual LED has two 3-Watt LEDs to provide a warm and consistent light source without generating excessive heat. The compact weighted base with built-in dimmer takes up very little space on your desk or work bench.
Available in standard output or Spot version with a tighter light output (at 12″ or greater).
AN-DL12-LED-3W-DUAL – ANSER DUAL LED Light with built in dimmer and two 12″ goosenecks.
AN-DL18-LED-3W-DUAL – ANSER DUAL LED Light with built in dimmer and two 18″ goosenecks.
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AN-DL18-LED-SPOT-3W-DUAL – ANSER DUAL LED Light Spot version with built in dimmer and two 18″ goosenecks.

industry_corpus2: Technology & Research


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Hotels.com currently has plenty of hotels in Ashtown that you can book from the comfort of your home!
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text:
Special Counsel Julie M. Watson and Paul A. Stewart, Managing Director at PASCO Ventures LLC co-instructed a course on negotiation at the Licensing Executives Society (LES) University program "Business Development in IP Licensing" on Thursday, July 20, 2017.
The first portion of the course covered principles and strategies for effective negotiations. Ms. Watson and Mr. Stewart instructed on negotiation concepts including best practices for use of term sheets.
The second portion of the course provided attendees the opportunity to put the principles into practice through a negotiation exercise based on the foundational concepts taught by Ms. Watson and Mr. Stewart.
For more information on LES University, held on July 17 - 21, 2017, click here.


text:
Matier & Ross Feb. 7, 2018 Updated: Feb. 7, 2018 6 a.m.
Congresswoman Nancy Pelosi (left) embraces acting Mayor London Breed at Pelosi's annual New Years celebration at the Golden Gate Club in San Francisco, California, on Sunday, Jan. 14, 2018.
In another move to “level the playing field,” London Breed’s mayoral rivals are calling for the Board of Supervisors president’s designation as “acting mayor” to be struck from the June ballot.
“It’s not correct, and I believe she had a duty and obligation to change it,” said mayoral candidate and former Supervisor Angela Alioto.
Jim Stearns, a consultant for former mayoral candidate and ex-state Sen. Mark Leno, said the campaign might go to court to challenge Breed’s “grossly misleading ” job description.
Breed was both acting mayor and a district supervisor when the filing deadline for the June 5 mayoral election closed — a dual position she still held when the window for public review of the job titles ended Jan. 22. The next day, her supervisor colleagues chose Mark Farrell to be mayor until June.
Breed initially asked to be designated only as acting mayor, but after discussion with Elections Director John Arntz, the dual title “supervisor/acting mayor” was agreed on.
The progressive supervisors who chose Farrell worried that letting the moderate Breed remain acting mayor would give her the advantage of incumbency in the mayoral race. Her rivals still feel that way, now that she’s a “former” acting mayor.
The ballots don’t go to the printer until late March, giving everyone plenty of time to take the matter before a judge.
Because so far, Breed isn’t budging.


text:
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industry_corpus2: Finance & Economics


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Dear lovely people, the continued existence of our beloved Mandril is at risk! The 5 year contract that was established in 2014 to use the space in Cabergerweg 45, is ending in November 2019. We are fighting for a contract renewal so that we can continue being an open space for creative expression, collaboration, and political engagement.
One way of contributing to the continued existence of the Mandril Cultural and Political Center is through this online petition. If you care about the Mandril and the continuation of this vibrant project sign & share this petition! We need you!!! Sign this petition to show that you support and value this self-organized, autonomous cultural freezone – a space of empowerment, creation, education, connection, and inspiration.
As some of you might know, the Mandril will soon get evicted – on the 1st of April we (the MCPC and the people who live here) must have left the building.


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CHAPTER 4. Hemodynamic Disorders Thromboembolic Disease Shock. Overview. Edema Hyperemia and Congestion Hemorrhage Hemostasis and Thrombosis Embolism Infarction Shock. Fluid Compartments. Goldman: Cecil Textbook of Medicine, 22nd ed. Body Fluid Compartments. Walter B Cannon.
Goldman: Cecil Textbook of Medicine, 22nd ed.
An embolus is a detached intravascular solid, liquid, or gaseous mass that is carried by the blood to a site distant from its point of origin.
An infarct is an area of ischemic necrosis caused by occlusion of either the arterial supply or the venous drainage in a particular tissue.
cytokine-induced secondary effectors (e.g., nitric oxide) become significant.
LPS at higher doses also results in diminished endothelial cell production of thrombomodulin and TFPI, tipping the coagulation cascade toward thrombosis.
recombinant activated protein C (aPC, which acts as an anticoagulant) has been approved by the FDA.


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The murder of 17 people by French-born Islamic extremists has focused attention on the economic and social marginalization of Muslims in France. The country has five million Muslims - the largest number in Europe - and many of them inhabit the low-income, high crime banlieues of Paris, which are routinely stigmatized as “no go areas”. The Charlie Hebdo attackers - the brothers Saïd and Chérif Kouachi - spent their young adulthoods in these bleak, high-rise housing estates, where unemployment rates hover around 25%. Orphaned at an early age and poorly educated, the Kouachis worked in soulless menial jobs and got involved in petty crime. They were perfect targets for preachers of extremist ideologies. Meanwhile, Amedy Coulibaly, who killed a police officer then several more hostages in a Paris supermarket, also lived in a Paris banlieue and was imprisoned for petty thefts.
The concern is that these disenfranchised areas of French cities will incubate more and more terrorists. There is evidence that a growing number of French Muslims feel alienated from society and are turning to jihadist causes. More than 1,000 French citizens have left, or plan to leave, to join jihadist groups in Syria or Iraq, according to the French Interior Ministry. This is more than any other European nation.
Meanwhile, France’s prisons are full of Muslims. Although only 8% of the French population are from a Muslim background, they make up 60% of prisoners. By comparison, in England and Wales, Muslims account for 14% of the prison population and 5% of the population nationwide, according to Home Office statistics.
Prison is the major breeding ground for jihadists in France. Chérif Kouachi was radicalized during his time at Fleury-Mérogis prison, south of Paris in 2005-06. Whilst serving time, Chérif met Djamel Beghal, a jihadist convicted for attempting to bomb the US embassy in Paris in 2001. Beghal also influenced Amedy Coulibaly during a stint in prison. Coulibaby later said in a secret 2007 video that prison was “the best school for criminality”.
Pamela Jackson, a US professor of sociology and co-author of Benchmarking Muslims Wellbeing in Europe, says the French state has done little to tackle discrimination.
Jackson says other European nations have been more proactive. She points to the work of the Canadian political philosophers Keith Banting and Will Kymlicka whose Banting/Kymlicka Multicultural Policy Index compares the inclusion policies of 21 Western countries. On eight indicators, countries are rated 0, 0.5, or 1.0. When the eight scores are added up, the UK has an overall mark of 5.5, way ahead of Germany on 2.5 and France on 2. Most significantly, France scored ‘0’ on six criteria. The total French failures were on constitutional affirmation, school curriculum, media, dress code exemptions, affirmative action and bilingual education. “In France, minorities can’t catch a break. They don’t fit in and the state is not about to make a place for them. Majority group members both contribute to this approach and learn from it,” said Jackson.
In the French workplace, too, there is clear evidence of religious, as opposed to racial, prejudice against Muslims. One study from the Stanford political scientist David Laitin, and his colleagues, showed that a Christian citizen with an African heritage was two-and-a-half times more likely to get called for a job interview than an equally qualified Muslim citizen from the same ethnic background. This US study was important because France’s “laïcité” laws don’t allow the state to collect data on minorities, making it difficult to expose discrimination.
Laitin had to be ingenious to collect the data on workplace prejudice. The team designed a test in which fictional job candidates competed for the same position requiring advanced education and lots of experience. The names on the CVs reflected different religious and national backgrounds. “Marie Diouf” suggested a French-Senegalese with a Christian name, while “Khadija Diouf” appeared to be a French-Senegalese with a Muslim name.
The CVs for the Dioufs were identical except for their first names and the addition of a few activities indicating their religious backgrounds: For example, Khadija had worked for Islamic Relief, whereas Marie had worked for Catholic Relief. These two competed against a third candidate, “Aurélie Ménard”, who sounded like a descendant of a well-established French family. The researchers used the false CVs to apply for 300 advertised jobs, making Khadija and Aurélie compete for one set of positions and Marie and Aurélie compete for another. For every 38 call-backs for Khadija, Marie got 100 call-backs - two-and-a-half times more.
But the vast majority of French society is unaware of such discrimination towards Muslims. They are shielded by a complacent media and a government that refuses to acknowledge the problem. Surveys show that 69% of citizens are under the illusion that French society is “sufficiently open and welcoming towards Muslims”.
Part of the issue, Professor Laitin says, is that Muslims are on average less secularized and possess more conservative attitudes to women than the average French person. “The characteristics that differentiate Muslim immigrants from rooted French society, and from otherwise matched Christian immigrants, are – in their grotesquely exaggerated form – precisely those that the French associate with Jihadists: The insistence that religious principles should be the foundation of governance, and the repression of women. This false equivalency between ‘Muslim” and ‘Jihadist’, and thus the irrational discrimination that the French harbour against Muslims, will likely only be reinforced by events like the double massacre perpetrated by those claiming to act in the name of Islam,” he said.
Laitin says that both the media and the French Government have a role to play in tackling prejudice. To date, the French media has tended to shy away from analyzing Islamophobia and the major newspapers showed no interest in Laitin’s studies of discrimination in the workplace. But if the media were to change tack and begin to broadcast the prejudicial tendencies of French society, it could lead to greater self-awareness and changes in behaviour.
Meanwhile, he says, the French Government has to close the educational gap between middle-class French suburbs and the banlieues. French schools are failing to achieve what the French call “l’égalité des chances” (equal opportunities). According to the Programme for International Student Assessment (PISA), which evaluates the performance of 15-year old students in literacy, mathematics, and science in more than 70 countries, the difference between the best and worst performing students is higher in France than in many other industrialized countries.
Professor Jackson says it is also vital to end the police discrimination against Muslims in the banlieues. They contribute to higher levels of distrust of the police among Muslims than in any other European nation.
Jackson would also like to see the French Government begin to collect official data on ethnicity, race and religion. “Not keeping such data on individuals who come before the courts prevents the study of fairness in the justice system and is another example of institutional discrimination. It allows harsher sentencing for minorities to continue. The policing of even minor drug-related offenses is focused on minority neighbourhoods and stiffer sentences are conferred on minorities for a variety of reasons - the quality of the neighbourhood they would return to, the home situation, and the sense even among social workers that minorities are less trustworthy,” she said.
But Professor Jackson fears that the French Government’s reaction to the terrorist atrocities in Paris has not been sympathetic enough to the plight of the country’s Muslims. “The Government is framing the killings as indicative of the ‘problem of Muslim extremism in France’, rather than as a consequence of widespread institutional discrimination contributing to the segmentation of people of colour in France.


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A newlywed couple move into their new house.
Another few days go by, and it’s raining pretty hard. The wife finds a leak in the roof.
“Oh, I had a handyman come in and fix them,” she says.
“Great! How much is that going to cost me?” he snarls.
“Uh, well, what kind of cake did you make?” asks the husband.

industry_corpus2: Real Estate & Construction


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Exposure control - digital-photography.com - Digital photography and Nikon DSLR cameras. More focused.
„Exposure control“ is the selection of a specific combination of exposure time, aperture and ISO sensitivity that provides an exposure matching the result of the exposure metering and a possible additional exposure compensation.
Program Auto: The camera chooses both exposure time and aperture.
This can be done using a generic mapping or optimized for certain shooting situations if you use so called scene modes, e.g. towards shortest possible exposure times for sports, small f-numbers for small depth-of-field for portraits etc.
This mode is either named with a symbol P or digital cameras apply it as part of a fully automated operation mode or scene programs („AUTO“ or „SCENE“ in the example on the right)..
But this does not mean that you cannot take any influence: At advanced cameras you can shift the combination of exposure time and aperture manually if you do not like the suggested values.
Shutter priority: The camera chooses an aperture for an exposure time that you have selected.
Nikon and Sony use an S for this mode, Canon Tv („time value“).
If the exposure time you have selected would require an aperture that your lens cannot provide, your picture would get under- or overexposed.
Aperture priority: The camera chooses an exposure time for the aperture that you have selected.
Nikon and Sony use an A for this mode, Canon Av („aperture value“).
Accidental under- or overexposures will normally not happen in this mode as the range of exposure times is large enough to find a suitable one for your aperture.
Manual control: The camera sets neither exposure time nor aperture automatically. You have to set both yourself however the camera will normally display an indication how much the exposure you have set is brighter or darker than the automatically selected one.
The common labeling for this mode is easy to remember, an M.
The logic how a digital camera will adjust the ISO sensitivity automatically may also differ from camera to camera. Common options are that the ISO sensitivity is increased when the exposure time gets too long or that it is integrated in the rules of a scene mode.


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What is Safe Mode in Windows? What are different types of Safe Mode?
In this post, we will see what is Safe Mode in Windows and what are the different types of Safe Mode – like Safe Mode, Safe Mode with Networking & Safe Mode with Command Prompt and what they mean.
Most Windows users may be familiar with the Safe Mode, as it is often required when you need to diagnose or troubleshoot Windows problems. We have already see how to start Windows 10 in Safe Mode and how to directly reboot Windows in Safe Mode. Now let us take a look at what Safe Mode means and the types of safe Mode that Windows OS offers.
When you start Windows in Safe Mode, the operating system only loads those minimum set of Drivers, files, and applications that are required for it to load.
Let us take a look at these three in details.
When you boot in Safe Mode – the very basic configuration is loaded. You boot into a black desktop, and you may find that your fonts and icons look big and are not sharp. This is because only the very basic drivers are loaded. You will have access to your Start Menu, as well as Mouse and Keyboard, and you will also be able to access your files. You will also see Safe Mode written on all four corners and your Windows version number in the top center. If you wish to use System Restore or run your antivirus scan to remove malware, which is often the case with most home users, this is the best mode to boot into. Apart from this function you also get access to other built-in Windows tools, like Command Prompt, PowerShell, Computer Manager, Device Manager, Event Log Viewer, etc.
TIP: You can add Safe Mode to Boot Menu options in Windows 10.
When you boot in Safe Mode with Networking, you are taken to your desktop. One extra set of drivers – and those are the networking drivers that get loaded. This allows you to connect the computer to your network or the Internet. It is recommended that one not surf the web in Safe Mode as your system is in a vulnerable and unprotected state.
When you boot into Safe Mode with Command Prompt, you do not boot in the Windows GUI. You are directly given access to an open Command Prompt window. Since you do not get access to your desktop and start menu, usually only experts who need to carry out some advanced troubleshooting use this mode.
There are some other posts about the Safe Mode on this website. Do take a look at them too.
Hope this answers your questions about the Safe Mode in Windows OS.
Andy, after the Anniversary Update for Windows 10, a few days later, I started up my PC and was in Safe Mode! I didn’t make my PC go into Safe Mode, it was just there. I did all of the normal things, like checking Device Manager, the Registry and so forth. Nothing seemed out of order. I could not get out of Safe Mode. I had upgraded to Windows 10 Pro 64Bit, as a free upgrade. To get out of Safe Mode, I had to reinstall Windows 7 Pro 64Bit, since, none of my System Restores would work in Safe Mode.
So, here I sit using Windows 7 Pro 64Bit and I can not upgrade back to Windows 10 Pro 64Bit without making full payment for the Windows 10. Needless to say, I am not pleased and I miss Windows 10. Is there anyway I can get Windows 10 Pro 64Bit back??? My Windows 10 was activated, so Microsoft has that on record.
Please help me and others who may have had the same thing happen to them. Writing an article or telling where there is an article about retrieving Windows 10 (Home, Pro, Ultimate), after the free upgrade period has ended.


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The battle between Lamias and Vampires reached its ending when Berserkers were thrown into the battlefield. Lamias are vanquished. Prisoners are transferred into the Satanik holds. An important ball is organised to celebrate Vampire's victory. Henrich, who is very disturbed since his reunion with Rebecca, finds himself having a hard time to accept the ritual offering of his former lover at Dracula's first bloodletting.
There are other prints of this regular volume without notable differences to my knowledge.
This fourth volume has also been sold in a slipcase edition with volume 5 and 6 (regular volumes inserted in a limited illustrated slipcase).
There is also a 'Tirage de Tête' of this volume (French deluxe oversized limited edition), published in October 2003.

industry_corpus2: Literature & Emotions


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The theme of our June issue "The Power of the People" refers to the ability of people to create change as well as the fact that electrical power, which only a few years ago seemed to be the property of the utilities, is now perceived to be the power of the people.
The Power of the People is positioned to create radical change in our industry. This is fueled by our need for sustainable buildings, plus the rapidly evolving smart grid with its need for clean energy, and the availability of innovative people from a down turned economy encouraged by the governments created by the people.
Our feature articles speak well to this radical change its management and presentation.
Future of Building Automation with IP Version 6 & cloud networking Alper Uzmezler, BAS Services & Graphics, LLC.
240 And Counting�. The number of speakers at ConnectivityWeek has now surpassed the total number of attendees at the first BuilConn Anto Budiardjo, President & CEO, Clasma Events Inc.
I am extremely pleased at the response and depth of our winning www.YoungEnergy.org authors who have provided a show of their power to change our industry. Be sure to read their interviews.
Pillars of a Third Industrial Revolution Drew Johnston, Development of a Smart Grid Brad White.
Although I did not invent Building Automation, I was there when it happened. I saw hardwired logic machines give way to mini computers with dumb panels. In 1975 I was involved with a evolutionary, possibly the first distributed computerized Direct Digital Control system for a large University Campus. So I am extremely pleased to go to the silicon valley as a reinvented digital dinosaur and be part of the Reinvention Convention for Building Automation and beyond. For a sneak preview of my track Reinventing Building Automation plus more ConnectivityWeek previews click here.
Did you catch this article in Wired Magazine? 7 Ways to Fix the Grid, Now or What is the Smart Grid, Anyway? in Fast Company? It is amazing to see the content that usually appears on AutomatedBuildings.com being part of an international social IP magazine. The Keynote speakers for the reinvention event are from Google and "Bob" the inventor of Ethernet so you can see our reinvention resides with Internet Protocol.
I usually single out feature articles and interviews but our May issue has so much excellent content I recommend that you return to the home page www.automatedbuildings.com and review all articles, interviews, columns, previews, and reviews. Just reading the titles and pull quotes is an education, and all speaks to change and reinvention.

industry_corpus2: Power & Energy


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AUSTIN, Texas (AP) — Austin police say a driver has been charged with reckless driving after he was clocked doing 117 mph during rush hour.
Police say Etman Samghezli had been involved in an earlier wreck but left the scene.
Court records reviewed by Austin TV station KXAN (http://bit.ly/1KzxMB7 ) show police spotted his car as it was racing through traffic Friday evening. The speed limit on the freeway where he was driving is 65 mph, putting him 52 mph over the limit.
Officers say once they pulled him over, they found a passenger in his car was five months pregnant.

industry_corpus2: Law & Justice


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This Mequon family wanted to update their backyard with an elegant and functional space. They contacted the Mequon landscaping contractors at Oberndorfer Landscape Development. They discussed their ideas and what they wanted their backyard to look like with our experienced professionals and decided a fieldstone patio with a brick border would best complement their red brick home, while the natural coloring of the fieldstone complements the home colors.
Our Mequon landscapers began work immediately. We use high quality tools and materials which last through daily wear and tear, and the constantly fluctuating Wisconsin temperatures. The finished result is a visually appealing backyard patio which will be a popular gathering place for friends and family to relax and unwind. Our team provides high quality installation services at affordable prices. When you’re ready to bring your backyard dreams into reality, rely on the Oberndorfer Landscape Development team.
Contact the Mequon landscaping contractors to begin building your dream backyard today.