In taxation and accounting, transfer pricing refers to the rules and methods for pricing transactions within and between enterprises under common ownership or control. Because of the potential for cross-border controlled transactions to distort taxable income, tax authorities in many countries can adjust intragroup transfer prices that differ from what would have been charged by unrelated enterprises dealing at arm’s length; the OECD and World Bank recommend intragroup pricing rules based on the arm’s-length principle, 19 of the 20 members of the G20 have adopted similar measures through bilateral treaties and domestic legislation, regulations, or administrative practice. Countries with transfer pricing legislation follow the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations in most respects, although their rules can differ on some important details. Where adopted, transfer pricing rules allow tax authorities to adjust prices for most cross-border intragroup transactions, including transfers of tangible or intangible property and loans.
For example, a tax authority may increase a company’s taxable income by reducing the price of goods purchased from an affiliated foreign manufacturer or raising the royalty the company must charge its foreign subsidiaries for rights to use a proprietary technology or brand name. These adjustments are calculated using one or more of the transfer pricing methods specified in the OECD guidelines and are subject to judicial review or other dispute resolution mechanisms. Although transfer pricing is sometimes inaccurately presented by commentators as a tax avoidance practice or technique, the term refers to a set of substantive and administrative regulatory requirements imposed by governments on certain taxpayers. However, aggressive intragroup pricing – for debt and intangibles – has played a major role in corporate tax avoidance, it was one of the issues identified when the OECD released its base erosion and profit shifting action plan in 2013; the OECD’s 2015 final BEPS reports called for country-by-country reporting and stricter rules for transfers of risk and intangibles but recommended continued adherence to the arm’s-length principle.
These recommendations have been criticized by many taxpayers and professional service firms for departing from established principles and by some academics and advocacy groups for failing to make adequate changes. Transfer pricing should not be conflated with fraudulent trade mis-invoicing, a technique for concealing illicit transfers by reporting falsified prices on invoices submitted to customs officials. “Because they both involve mispricing, many aggressive tax avoidance schemes by multinational corporations can be confused with trade misinvoicing. However, they should be regarded as separate policy problems with separate solutions,” according to Global Financial Integrity, a non-profit research and advocacy group focused on countering illicit financial flows. Over sixty governments have adopted transfer pricing rules, which in all cases are based on the arm's-length principle; the rules of nearly all countries permit related parties to set prices in any manner, but permit the tax authorities to adjust those prices where the prices charged are outside an arm's length range.
Most, if not all, governments permit adjustments by the tax authority where there is no intent to avoid or evade tax. The rules require that market level, functions and terms of sale of unrelated party transactions or activities be reasonably comparable to such items with respect to the related party transactions or profitability being tested. Adjustment of prices is made by adjusting taxable income of all involved related parties within the jurisdiction, as well as adjusting any withholding or other taxes imposed on parties outside the jurisdiction; such adjustments are made after filing of tax returns. For example, if Bigco US charges Bigco Germany for a machine, either the U. S. or German tax authorities may adjust the price upon examination of the respective tax return. Following an adjustment, the taxpayer is allowed to make payments to reflect the adjusted prices. Most systems allow use of transfer pricing multiple methods, where such methods are appropriate and are supported by reliable data, to test related party prices.
Among the used methods are comparable uncontrolled prices, cost-plus, resale price or markup, profitability based methods. Many systems differentiate methods of testing goods from those for services or use of property due to inherent differences in business aspects of such broad types of transactions; some systems provide mechanisms for sharing or allocation of costs of acquiring assets among related parties in a manner designed to reduce tax controversy. Most governments have granted authorization to their tax authorities to adjust prices charged between related parties. Many such authorizations, including those of the United States, United Kingdom and Germany, allow domestic as well as international adjustments; some authorizations apply only internationally. In addition, most systems recognize that an arm's length price may not be a particular price point but rather a range of prices; some systems provide measures for evaluating whether a price within such range is considered arm's length, such as the interquartile range used in U.
S. regulations. Significant deviation among points in the range may indicate lack of reliability of data. Reliability is considered to be improved by use of multiple year data. Most rules require t
Compton/Woodley Airport is a county-owned public-use airport located two miles southwest of downtown Compton, in southern Los Angeles County, California. The FAA's National Plan of Integrated Airport Systems for 2007–2011 categorized it as a relief airport, it is used for general aviation as an alternative to Los Angeles International Airport, situated about 8 miles to the west. Colonel C. S. Smith landed in an open field near the town of Compton in June 1924. Colonel Smith felt the field, owned by the local school board, would make an ideal airport location and negotiated for the airport's founding. Between 1924 and 1936 the airport and its land passed through several hands until Earl Woodley took over the lease in 1936, he purchased additional adjacent land to allow for a crosswind runway. During the war years of 1941 to 1946, civilian flying was restricted and the airport was used by the military as a truck depot. After the war, Mr Woodley resumed operations and became owner of the land; when Mr Woodley died in 1962, the airport was threatened with closure when it was purchased by an investment company.
Pilot groups, the mayor of Compton, the entire Compton City Council encouraged the Board of Supervisors to condemn the land and allow the county to purchase it. In June 1966 the entire airport property of 77 acres was purchased for $2,948,883. Compton/Woodley Airport covers 77 acres and has two asphalt runways, each 3,322 x 60 ft. In 2012 the airport had 66,000 general aviation aircraft operations, averaging about 180 per day. 175 aircraft are based at this airport: 151 single-engine aircraft, 14 multi-engine aircraft, 1 jet aircraft, 8 helicopters, 1 glider. The Compton Airport is mentioned in the opening bars of Dr. Dre's "Big Ego's" on his multi-platinum album 2001. Compton Airport is featured in Airline episode 46 when Robin Petgrave, the founder of the flight school Tomorrow's Aeronautical Museum, was delayed which resulted in his giving a cast member's son a plane ride at Compton Airport with his flight school. City of Compton web site Los Angeles County Department of Public Works - Compton/Woodley Airport Resources for this airport: FAA airport information for CPM AirNav airport information for KCPM ASN accident history for CPM FlightAware airport information and live flight tracker SkyVector aeronautical chart for KCPM
Communist Party of India (Marxist)
The Communist Party of India is the largest communist party in India. The party emerged from a split from the Communist Party of India in 1964; the CPI was formed at the Seventh Congress of the Communist Party of India held in Calcutta from 31 October to 7 November 1964. As of 2018, CPI is leading the state government in Kerala and having elected members in 8 state legislative assemblies including Kerala, West Bengal, Himachal Pradesh, Odisha, Jammu & Kashmir, Rajasthan, it leads the West Bengal Left Front. As of 2016, CPI claimed to have 1,048,678 members; the highest body of the party is the Politburo. CPI emerged from a division within the Communist Party of India; the undivided CPI had experienced a period of upsurge during the years following the Second World War. The CPI led armed rebellions in Telangana and Kerala. However, it soon abandoned the strategy of armed revolution in favour of working within the parliamentary framework. In 1950 B. T. Ranadive, the CPI general secretary and a prominent representative of the radical sector inside the party, was demoted on grounds of left-adventurism.
Under the government of the Indian National Congress party of Jawaharlal Nehru, independent India developed close relations and a strategic partnership with the Soviet Union. The Soviet government wished that the Indian communists moderate their criticism towards the Indian state and assume a supportive role towards the Congress governments. However, large sections of the CPI claimed that India remained a semi-feudal country, that class struggle could not be put on the back-burner for the sake of guarding the interests of Soviet trade and foreign policy. Moreover, the Indian National Congress appeared to be hostile towards political competition. In 1959 the central government intervened to impose President's Rule in Kerala, toppling the E. M. S. Namboodiripad cabinet; the relations between the Communist Party of the Soviet Union and the Communist Party of China soured. In the early 1960s the Communist Party of China began criticising the CPSU of turning revisionist and of deviating from the path of Marxism–Leninism.
Sino-Indian relations deteriorated, as border disputes between the two countries erupted into the Sino-Indian War of 1962. The basis of difference in opinion between the two factions in CPI was ideological – about the assessment of Indian scenario and the development of a party programme; this difference in opinion was a reflection of a similar difference at international level on ideology between the Soviet and Chinese parties. The alleged'right wing' inside the party followed the Soviet path and put forward the idea of joining hands with the ruling party – Indian National Congress. Whereas the faction of CPI which became CPI referred to this as a revisionist approach of class collaboration, it was this ideological difference which intensified, coupled with the Soviet-Chinese split at the international level and gave birth to CPI. Hundreds of CPI leaders, accused of being pro-Chinese, were imprisoned. Thousands of Communists were detained without trial; those targeted by the state accused the pro-Soviet leadership of the CPI of conspiring with the Congress government to ensure their own hegemony over the control of the party.
In 1962 Ajoy Ghosh, the general secretary of the CPI, died. After his death, S. A. Dange was installed as the party chairman and E. M. S. Namboodiripad as general secretary; this was an attempt to achieve a compromise. Dange represented the rightist faction of the party and E. M. S; the leftist faction. At a CPI National Council meeting held on 11 April 1964, 32 Council members walked out in protest, accusing Dange and his followers of "anti-unity and anti-Communist policies"; the leftist section, to which the 32 National Council members belonged, organised a convention in Tenali, Andhra Pradesh 7 to 11 July. In this convention the issues of the internal disputes in the party were discussed. 146 delegates, claiming to represent 100,000 CPI members, took part in the proceedings. The convention decided to convene the 7th Party Congress of CPI in Calcutta the same year. Marking a difference from the Dangeite sector of CPI, the Tenali convention was marked by the display of a large portrait of the Chinese Communist leader Mao Zedong.
At the Tenali convention a Bengal-based pro-Chinese group, representing one of the most radical streams of the CPI left wing, presented a draft programme proposal of their own. These radicals criticised the draft programme proposal prepared by M. Basavapunniah for undermining class struggle and failing to take a clear pro-Chinese position in the ideological conflict between the CPSU and CPC. After the Tenali convention the CPI left wing organised party state conferences. In West Bengal, a few of these meetings became battlegrounds between the most radical elements and the more moderate leadership. At the Calcutta Party District Conference an alternative draft programme was presented to the leadership by Parimal Das Gupta. Another alternative proposal was brought forward to the Calcutta Party District Conference by Aziz ul Haq, but Haq was banned from presenting it by the conference organisers. At the Calcutta Party District Conference 42 delegates opposed M. Basavapunniah's official draft programme proposal.
At the Siliguri Party District Conference, the main draft proposal for a party programme was accepted, but with some additional points suggested by the far-left North Bengal cadre Charu Majumdar. However, Harekrishna Konar forbade the raising of the sloga
Malayan Communist Party
The Malayan Communist Party known as the Communist Party of Malaya, was a political party in the Federation of Malaya and Malaysia. It was founded in 1930 and laid down its arms in 1989, it is most known for its role in the Malayan Emergency. In April 1930 the South Seas Communist Party was dissolved and was replaced by the Communist Party of Malaya. While its primary responsibility was Malaya and Singapore, the party was active in Thailand and the Dutch East Indies, which did not have their own Communist parties; the party operated as an illegal organisation under British colonial rule. In June 1931, many party leaders were arrested after a Comintern courier was intercepted by the police, sending the party into disarray. Information extracted from the courier indicated at this point there were 1,500 members and 10,000 sympathisers. Despite this setback, the MCP gained influence in the trade union movement and organised several strikes, most notably at the Batu Arang coal mine in 1935, they set up workers' committees at some workplaces.
These committees, the strikes, were promptly crushed by troops and police. Many ethnic Chinese strikers were deported to China, where they were executed by the Chinese Nationalist government as Communists. After Japan invaded China in 1937, there was a rapprochement between the Malayan Guomindang and Communists, paralleling that in China. Under the wing of the Guomindang, the MCP was able to operate more easily. Anti-Japanese sentiment among Malayan Chinese gave the party with a great opportunity to recruit members and raise funds under the banner of defence of China. At this time, the party was infiltrated by an apparent British agent, Lai Teck, who became Secretary-General in April 1939. Despite this severe security breach, the Party continued to operate effectively. By mid-1939 it claimed about half in Singapore; the MCP was headed by a Central Executive Committee of twelve to fifteen members. About six of these were appointed to the Political Bureau which ran the party when the C. E. C was not in session.
Each State was in turn subdivided into several Districts. The smallest unit of organisation was the Party cell, which consisted of the members from one workplace or village. Large Party Congresses were held on an occasional basis. On 8 December 1941, the Japanese Empire invaded Malaya; the British colonial authorities now accepted the MCP's standing offer of military co-operation. On 15 December, all left-wing political prisoners were released. From 20 December the British military began to train party members in guerilla warfare at the hastily established 101st Special Training School in Singapore. About 165 MCP members were trained; these fighters, scantily armed and equipped by the hard-pressed British, hurriedly dispersed and attempted to harass the occupying army. Just before Singapore fell to the Japanese on 15 February 1942, the party began organising armed resistance in the state of Johore. Soon four armed groups, which became known as'Regiments', were formed, with 101st STS trainees serving as nuclei.
In March this force was dubbed the Malayan People's Anti-Japanese Army and began sabotage and ambushes against the Japanese. The Japanese responded with reprisals against Chinese civilians; these reprisals, coupled with increasing economic hardship, caused large numbers of Malayan Chinese to flee the cities. They became squatters at the forest margins, where they became the main source of recruits and other assistance for the MPAJA; the MPAJA consolidated this support by providing protection. O'Ballance estimates that in mid-1942 the regimental strengths were about 100 in the first Regiment, 160 in the 2nd, 360 in the 3rd, 250 in the 4th. At this time a 5th, 6th, 7th Regiment were formed; this army, which included women, was conceived as both a military and political force, along Maoist lines. When Singapore fell, Lai Teck became their agent. On 1 September 1942, acting on his information, the Japanese launched a dawn raid on a secret conference of more than 100 MCP and MPAJA leaders at the Batu Caves just north of Kuala Lumpur, killing most.
The loss of personnel forced the MPAJA to abandon its political commissar system, the military commanders became the heads of the regiments. Following this setback the MPAJA avoided engagements and concentrated on consolidation, amassing 4,500 soldiers by Spring 1943. From May 1943, British commandos from Force 136 infiltrated Malaya and made contact with the guerillas. Early in 1944 an agreement was reached whereby the MPAJA would accept some direction from the Allied South East Asia Command and the Allies would give the MPAJA weapons and supplies, it was not until the spring of 1945, that significant amounts of material began to arrive by air drop. Japan's surrender on 15 August 1945 caught the combatants in Malaya by surprise; the first British contingent of reoccupation troops did not arrive until 3 September. The Japanese garrison withdrew from the countryside, leaving a power vacuum, filled by the MPAJA. In many places Chinese areas, they were greeted as heroes as they emerged from the forest.
The British recognised the MPAJA's authority. The guerillas, seized Japanese arms and recruited forming an 8th Regiment and lifting their armed strength over 6,000. At the same time they launched reprisals against collaborators in the Malay police force and the civilian population and began to forcibly raise funds. Many in the rank and file advocated revolution; the cautious approach which favoured Lai Teck and a majority of the
Coalition for Melilla
Coalition for Melilla is a political party in the Spanish city of Melilla. The party was formed shortly before the 1995 municipal regional elections of Melilla, as a split from the Spanish Socialist Workers' Party which had a strong electoral implantation among Muslim voters. At the 1995 municipal elections, CPM won five seats, as many as the PSOE, the People's Party (PP won 14. Three years in August 1998, there was a split in the PP and a new municipal executive was formed against the PP, including the CPM, with its leader Mustafa Aberchán entering it with the Environment portfolio. In 1999, Mustafa Aberchán, running on the Coalition ticket, became the first Muslim mayor of Melilla due to PSOE and Independent Liberal Group backing. At 2007 elections for Melilla Assembly, the party came second after PP. CxM was federated with United Left from June 2008 to September 2013. Shireen Hunter. Islam, Europe's second religion: the new social and political landscape. Greenwood Publishing Group, 2002. ISBN 0-275-97608-4, ISBN 978-0-275-97608-8.
Powdery mildew is a fungal disease that affects a wide range of plants. Powdery mildew diseases are caused by many different species of fungi in the order Erysiphales, with Podosphaera xanthii being the most reported cause. Erysiphe cichoracearum was reported to be the primary causal organism throughout most of the world. Powdery mildew is one of the easier plant diseases to identify, as its symptoms are quite distinctive. Infected plants stems; the lower leaves are the most affected, but the mildew can appear on any above-ground part of the plant. As the disease progresses, the spots get larger and denser as large numbers of asexual spores are formed, the mildew may spread up and down the length of the plant. Powdery mildew grows well in environments with moderate temperatures. Greenhouses provide an ideal temperate environment for the spread of the disease; this causes harm to agricultural and horticultural practices where powdery mildew may thrive in a greenhouse setting. In an agricultural or horticultural setting, the pathogen can be controlled using chemical methods, bio organic methods, genetic resistance.
It is important to be aware of powdery mildew and its management as the resulting disease can reduce important crop yields. Powdery mildew fungi can only reproduce on their living cell host and reproduce both sexually and asexually. Sexual reproduction is via a type of ascocarp where the genetic material recombines. Powdery mildew fungi must be adapted to their hosts to be able to infect them. Within each ascocarp are several asci. Under optimal conditions, ascospores are released to initiate new infections. Conditions necessary for spore maturation differ among species. Asexual reproduction is. Powder mildew fungi offspring of wheat and barley species are more successful from asexual reproduction compared to sexual reproduction counterparts. Woolly aphids and other sucking insects are vectors of transmission for powdery mildew, other infectious diseases. Woolly aphids in sub temperate climates precede and are an indicator of various infections, including Powdery mildew. Aphids penetrate plant surfaces where they reside and provide a host of potential inoculants through physical, digestive or fecal secretions.
Aphids are an indicator of other potential plant problems. In an agricultural setting, the pathogen can be controlled using chemical methods, genetic resistance, careful farming methods. Chemical fungicides are an effective way to manage powdery mildew disease on plants. Spray programs of chemical fungicides are advised to begin when powdery mildew symptoms and signs are first noticed. Chemical fungicides should be applied on a regular basis for best results against the disease. Chemical control is possible with fungicides such as propiconazole. Effective chemical control is possible with fungicides hexaconazole and penconazole in reducing the mildew. Another chemical treatment involves treating with a silicon calcium silicate slag. Silicon helps the plant cells defend against fungal attack by degrading haustoria and by producing callose and papilla. With silicon treatment, epidermal cells are less susceptible to powdery mildew of wheat. Organic fungicides are an effective way to manage powdery mildew disease on plants by offering alternative modes of action.
Bio organic fungicides are made up of specialized fungi and metals such as copper and sulfur. The most effective non-chemical methods of control against powdery mildew are milk, heavy metals, oils. Metal-based organic fungicides should be applied on a regular basis up until harvest of the host. Sulfur must be applied before the disease has emerged since it prevents fungi spores from germinating. Copper sulfate can cause harm to the host plant. Addition of lime results in a safer fungicide. Neem oil manages powdery mildew on many plants by interfering with the fungus' metabolism and terminating spore production. Sulfur and Fish Oil + Sesame Oil are effective bio fungicides. Milk has long been popular with home gardeners and small-scale organic growers as a treatment for powdery mildew. Milk is diluted with water and sprayed on susceptible plants at the first sign of infection, or as a preventative measure, with repeated weekly application controlling or eliminating the disease. Studies have shown milk's effectiveness as comparable to some conventional fungicides, better than benomyl and fenarimol at higher concentrations.
Milk has proven effective in treating powdery mildew of summer squash, pumpkins and roses. The exact mechanism of action is unknown, but one known effect is that ferroglobulin, a protein in whey, produces oxygen radicals when exposed to sunlight, contact with these radicals is damaging to the fungus. Dilute sprays containing sodium bicarbonate and vegetable or mineral oils in water are recommended for controlling powdery mildew, but such mixtures have limited and inconsistent efficacy. While sodium bicarbonate has been shown to reduce to growth of mildews in lab tests, sprays containing only baking soda and water are not effective in controlling fungal diseases on infected plants, high concentrations of sodium are harmful to plants. Potassium bicarbonate is an effective fungicide against powdery mildew and apple scab, allowed for use in organic farming. Pm3 allel is an effective genetic resistance strategy that protects host species against powdery mildew fungus. Blumeria
Party of Communists of the Republic of Moldova
The Party of Communists of the Republic of Moldova is a communist party in Moldova led by Vladimir Voronin. It is the only communist party to have held a majority in government in the post-Soviet states; the PCRM is part of the Party of the European Left. The PCRM was registered as a political party in 1994; the PCRM was part of the Popular Patriotic Forces Front at the time of the 1996 presidential election, in which Voronin stood as the coalition's candidate and won 10.3% of the vote, placing third. The party supported Petru Lucinschi in the second round of the election, following Lucinschi's victory the PCRM was given two positions in the government. In the March 1998 parliamentary election, the PCRM won 30.1% of the vote and 40 seats, becoming the largest party in parliament. Despite its strong showing, the PCRM was left in opposition due to the formation of a center-right coalition government, Alliance for Democracy and Reforms. Although Lucinschi nominated Voronin as Prime Minister of Moldova in late 1999, the nomination was unsuccessful because Voronin did not have enough support in parliament.
The PCRM received 49.9% of the vote in the February 2001 parliamentary election, winning 71 out of the 101 seats in parliament. With a PCRM parliamentary majority, Voronin was elected as President by parliament in April 2001; the Constitutional Court ruled that the President could lead a political party, Voronin was re-elected as party leader. As the ruling political party in Moldova, it won the Moldovan parliamentary election, 2005, provided the President, Vladimir Voronin, the Prime Minister, Zinaida Greceanîi, the Speaker of the Moldovan Parliament, Marian Lupu. Under Voronin, it governed in a multi-party fashion, it favors European integration and eventual EU membership. After April 2009 election and the civil unrest, the climate in Moldova became polarized; the parliament failed to elect a new president. For this reason, the parliament was dissolved and snap elections were held. At the July 29 polls the Communist Party received 44.7% of the vote. That gave the former ruling party 48 MPs, the remaining 53 seats in the 101-member chamber went to four opposition parties, Alliance For European Integration.
For the first time since 2001, communists went into opposition. After the Parliament failed to elect a new President of the Republic, snap elections were called. In the election, PCRM obtained 39.34% of votes, winning 42 seats, going again into opposition to the Alliance of European Integration. In 2011 Igor Dodon and Zinaida Greceanîi left the party and joined the Party of Socialists of the Republic of Moldova. Parliamentary election of 2014 saw a great defeat for PCRM, which received only 17.48% of votes, losing more than half of its electors to PSRM and electing 21 seats. Following the elections, the party agreed to give supply to the new Gaburici Cabinet; the Agreement collapsed in June 2015 and PCRM went back into opposition. In 2016, the party suffered a large split as 14 MPS left PCRM faction and established the Social Democratic Platform for Moldova, joining the majority of Filip Cabinet. On 10 March 2017, all 14 MPs joined the Democratic Party of Moldova. Since the party declined in polls, losing most of its votes to PSRM and PDM.
In the 2019 parliamentary election PCRM collapsed, receiving only 3,75% of votes and losing all representation in the Parliament. According to its Statute adopted in 2008, article 1, the Party of Communists of the Republic of Moldova is a "lawful successor and heir of the Communist Party of Moldavia both in terms of ideas and traditions". While espousing a Leninist communist doctrine, there is debate over their policies; the Economist considers it a centre-right party, communist only in name, whereas Romanian political scientist Vladimir Tismăneanu argues that the party is communist in the classical sense, as it has not changed much since the fall of the Soviet Union. Ion Marandici, a Moldovan political scientist considers that the success story of the Moldovan Communists is due to the Communists' capacity to attract the votes of the ethnic minorities and the Romanian-speakers identifying as Moldovans, by proposing a Moldovenist nation and state-project; the decline of the Communists followed after Marian Lupu, a key figure in Moldovan politics, left the Communists Party and joined the Democratic Party, thus bringing with him the Moldovan supporters of the Communists.
The party is opposed to any unification of Romania and Moldova. For the current period of governance, the PCRM has outlined the following goals for the country: A new quality of life. Official website