Brilliant. Many well-deserved groans.
57 posts • joined 6 Nov 2013
What happens when a Royal Navy warship sees a NATO task force headed straight for it? A crash course in Morse
I can answer your main question - the level of profit probably is considered satisfactory for a limited risk distributor and shouldn't be considered a mark of commercial failure in any way.
If it's designated as such, then its goods and services will be transfer priced to achieve a low profit margin in that range. The idea being that the small level of profits are in line with the arm's length level of profits a 3rd party company would expect to earn if it had a business with such limited risks. Profits instead accrue to the entity taking all the commercial risk, presumably the US for Dell?
Re: PWC again eh?
There should be a good understanding of the underlying business processes by the auditors.
A good team for a large company will have regular updates with the business throughout the year, at least to plan the audit if nothing else, and larger companies often have mid-year mini audits of particular areas to smooth the process at year-end.
However, the auditors will have a full client book, so generally speaking downtime from one client is spent auditing other clients.
There's something odd about PwC in Japan - I don't recall the specifics, but it's actually a completely separate entity due to some local regulatory requirements.
Re: Lots of assumptions that we will even get WTO membership
Sadly not - the FT has an article here - we still need to do a ton of negotiating to benefit from WTO terms. Here's a google cache link to get round the paywall:
Re: On the radio this AM
He probably didn't mean this. Corporate Income Tax, CIT, or "income tax" is often used around the world to refer to something similar to our corporation tax. It's more of an Americanism than a deliberate attempt to conflate employee taxes with corporation taxes. You are quite correct that this is a common theme though and needs to be stamped on.
Re: Sony Updates
In their defence, they've just given us Marshamallow on the Z3 Compact which is now almost a two year old phone. My phone says it's got a March 2016 security patch level. They've also signed up to the open hardware programme, so they're better than many other phone manufacturers.
"Most modern devices and operating systems come with the option to enable inbuilt FDE."
Apart from Windows 8 home, for which Truecrypt cannot do full disk encryption when it's been set up with GPT partitions. Microsoft will gladly let you upgrade to the pro version for £100 though to use Bitlocker. :headshot:
60% of the 1,000 were found to be fully compliant with UK law (i.e. they were non-domiciles not liable to UK tax, beyond paying the flat rate charge).
The remainder HMRC prefers to get the lost tax, penalties and interest back without entering into complex court cases, where the outcome is uncertain, cost to the taxpayer very large and where the cash reward is considerably delayed. It's much harder to prove 'beyond reasonable doubt' that someone has committed fraud, then to get the taxpayer to pay up.
They're being pragmatic by only prosecuting in the most severe cases.
It’s not that the rules have deliberately been written to create loopholes for companies, it’s that it’s really, really difficult (read ‘practically impossible’) to write laws that cover every eventuality without having loopholes. Sit down with a tax lawyer and try and draft a ‘simple’ piece of legislation to accomplish a simple task. You’ll soon discover it’s incredibly difficult to cover every situation without making things very complex.
Our tax law is monstrously huge (several multi-inch volumes) – it’s impossible for there to be no loopholes. The government is trying to redress the balance by falling back on various ‘principles based’ anti-avoidance strategies, but those are subjective and open to interpretation by their nature.
The transfer pricing process does not only depend on a mechanical calculation of an arm's length price for particular products. There will also be a look at the overall entity, its risk profile and what an arm's length level of profit might be. So rather than looking at the pricing of individual components or products, an adjustment can be put through to arrive at a target profit margin based on the profile of the business.
A business that has nothing but product stores (UK) takes on much less risk than the other parts of the business that might invest billions in R&D, advertising to build up the brand etc. etc. (US)
It's therefore perfectly acceptable under the OECD guidelines to look at the risk profile of each, decide that the UK is engaged in activities with a comparatively limited amount of entrepreneurial risk and reduce its profits accordingly.
There is therefore nothing surprising (unless you're an ignorant politician) about a company undertaking sales activities that earns a comparatively low profit margin. You can bet that if Apple were to pander to the UK government and put more cost back into the the US (increasing UK profits) that they will soon get a knock on the door from the US tax authorities asking why profits have dropped over there.
It's symmetrical and it usually works, until politicians wade in without understanding the law and guidelines in place. They should be concentrating on pursuing misrepresentations, 'sham' companies where there is no substance and treaty abuses instead.
The water sticks to surfaces (i.e. faces, faceplates etc.) in zero g, it doesn't sink to the bottom. It should be possible to point the end of the snorkel to an 'empty' part of the helmet and breathe, if the area around your mouth is covered.
Unless it's just tied directly into the oxygen tank I guess.
Re: theft in plain sight.
Can you follow the trail from the known 'theft' wallet through to its final destination, when the thief tries to cash out into fiat currency? E.g. could the transaction history of a 'known bad' wallet be used to identify the thief at the point where they have to provide ID and involve a bank?
Re: Sort of
I wasn't the poster, but a quick google pulls up the following article which has some numbers in it.
I'm not qualified to judge who's right, but there are clearly instances here of radiation levels well above normal or routine levels. There's already 360,000 tonnes of radioactive water being held on site.
"From the coastline, through the towns of Okuma, Futaba and Namie, are huge patches of ground where the additional annual dose of radiation is more than 50 millisieverts. Natural background radiation, from cosmic rays and sources in the air and rock, reaches 2 to 3 millisieverts per year."
"A preliminary IAEA report in October on efforts to clean up the contaminated land was full of praise for the remediation work so far, and made a handful of gentle suggestions for improvement. Yet the work is far behind schedule in seven of 11 selected towns and villages; the deadline of March 2014 is now unachievable. This month, officials in Japan admitted for the first time that thousands of evacuees from the worst affected areas may never return home."
"In August, workers discovered that 300 tonnes of radioactive water had leaked from one of the tanks. The radiation emanating from the puddle left on the ground was enough to give a bystander the industry's five-year maximum permissible dose in just one hour. In October, half a tonne of contaminated water spilled on to the ground and may have drained to the sea, when tanks overflowed with rainwater."
"Radiation levels surged in seawater after the tsunami struck, with concentrations of caesium-137 recorded at 60 million becquerels per cubic metre near the plant. "
"We're not talking about levels that cause direct harm when I'm one kilometre offshore," says Buesseler. "But through the uptake into the seafood and fisheries, you end up having to keep those closed, and that's a billion dollar industry and a cultural loss for Japan."
Re: I don't understand
I watched a program on this once and, if memory serves, the beam diffuses by the time it reaches the aircraft i.e. it's not like trying to aim a dot through a windscreen, it's like trying to light it up with a torch.
From inside, the whole cabin was lit up (and you can see the beginnings of this in the article photo) - it means the pilots can't see out and wrecks their night vision. Obviously the power in some of the lasers is pretty high if 30-odd pilots have needed hospital treatment.