The Harmonisation of Transfer Pricing: the Obstacles, the Arm's Length Principle and the OECD Guidelines

&lt;p&gt;This essay argues that the complete harmonisation of transfer pricing rules with the arm’s length principle is unattainable for three reasons. First, states are not under a legal obligation to apply the principle outside of treaty or domestic law. Second, the theoretical shortcomings of the principle are creating a divergence from the OECD guidelines on how the principle should be applied. Third, the perception held by states that multinational enterprises are not paying a fair share of tax is also creating a divergence from the OECD guidelines on the principle. The resultant divergence is a significant obstacle to transfer pricing harmonisation.&lt;/p&gt;</jats:p

The Harmonisation of Transfer Pricing: the Obstacles, the Arm's Length Principle and the OECD Guidelines

&lt;p&gt;This essay argues that the complete harmonisation of transfer pricing rules with the arm’s length principle is unattainable for three reasons. First, states are not under a legal obligation to apply the principle outside of treaty or domestic law. Second, the theoretical shortcomings of the principle are creating a divergence from the OECD guidelines on how the principle should be applied. Third, the perception held by states that multinational enterprises are not paying a fair share of tax is also creating a divergence from the OECD guidelines on the principle. The resultant divergence is a significant obstacle to transfer pricing harmonisation.&lt;/p&gt;</jats:p

Method Validation for Detection and Quantification of Cocoa Butter Equivalents in Cocoa Butter and Plain Chocolate

Abstract A European interlaboratory study was conducted to validate an analytical procedure for the detection and quantification of cocoa butter equivalents in cocoa butter and plain chocolate. In principle, the fat obtained from plain chocolate according to the Soxhlet principle is separated by high-resolution capillary gas chromatography into triacylglycerol fractions according to their acyl-C-numbers, and within a given number, also according to unsaturation. The presence of cocoa butter equivalents is detected by linear regression analysis applied to the relative proportions of the 3 main triacylglycerol fractions of the fat analyzed. The amount of the cocoa butter equivalent admixture is estimated by partial least-squares regression analysis applied to the relative proportions of the 5 main triacylglycerols. Cocoa butter equivalent admixtures were detected down to a level of 2% related to the fat phase, corresponding to 0.6% in chocolate (assumed fat content of chocolate, 30%), without false-positive or -negative results. By using a quantification model based on partial least-squares regression analysis, the predicted cocoa butter equivalent amounts were in close agreement with the actual values. The applied model performed well at the level of the statutory limit of 5% cocoa butter equivalent addition to chocolate with a prediction error of 0.6%, assuming a chocolate fat content of 30%.</jats:p

Complete microbial genomes for public health in Australia and the Southwest Pacific

Complete genomes of microbial pathogens are essential for the phylogenomic analyses that increasingly underpin core public health laboratory activities. Here, we announce a BioProject (PRJNA556438) dedicated to sharing complete genomes chosen to represent a range of pathogenic bacteria with regional importance to Australia and the Southwest Pacific; enriching the catalogue of globally available complete genomes for public health while providing valuable strains to regional public health microbiology laboratories. In this first step, we present 26 complete high-quality bacterial genomes. Additionally, we describe here a framework for reconstructing complete microbial genomes and highlight some of the challenges and considerations for accurate and reproducible genome reconstruction.</jats:p