Verrechnungspreismissbrauch

Transfer pricing tax evasion.

Under international finance rules that allowed corporations to assign profits earned by subsidiaries in countries with taxes to subsidiaries in countries without taxes, an online documentary explained, commodities companies could avoid taxes in source countries by having their extracting subsidiary sell the commodity to subsidiaries abroad at prices that did not reflect market prices, moving around on-paper profits and on-paper losses. The tactic is called transfer pricing. Rules supposed to prevent it required among other things that divisions of the same organization deal with each other “at arm’s length,” as if they were not part of the same organization.

Profits from this and other paper shuffles can apparently show up decades later and inflict serious fiscal damage on countries, even countries with the resources to give government auditors enough training to stand up to international corporations’ negotiators. In 2013 Rupert Murdoch’s giant News Corp. appears to have received the “largest cash payout from the Australian Tax Office ever,” a rebate of US$800 million for some on-paper loans to itself made in 1989. The money showed up in News Corp’s U.S. subsidiary’s Q4 2013 accounts as a US$800 million payment from “a foreign tax authority.” The original deduction was estimated by the Australian Financial Review at AU$600 million, but it was decided that News Corp was owed additional interest on it of almost AU$300 million.

The huge payment is being described as a substantial inconvenience or “blowout” to the current Australian federal budget. Last summer then-Australian prime minister Kevin Rudd accused News Corp companies in Australia of running a “ferocious” media campaign against his government, including accusing the Labour government of overspending. Kevin Rudd lost the Australian election to Tony Abbott on 07 Sep 2013.

This is how the tax deduction happened, according to an online 17 Feb 2014 article from the Australian Financial Review:

“In a 1989 meeting, four News Corp Australia executives exchanged cheques and share transfers between local and overseas subsidiaries that moved through several currencies.

“They were paper transactions; no funds actually moved. In 2000 and 2001 the loans were unwound. With the Australian dollar riding high, News Corp’s Australian subsidiaries recorded a $2 billion loss, while other subsidiaries in tax havens recorded a $2 billion gain.

“By last July that paper “loss”, booked against News Corp’s Australian newspaper operations, had become an [A]$882 million cash payout.

“Under a legal arrangement when the company was spun off last June, News was forced to pass all of the tax payout to Mr Murdoch’s 21st Century Fox.

“News Corp said it had retained $A81 million because it faced income tax charges on the interest payments by the Tax Office. However it seems unlikely to actually pay these funds: News Corp Australia carried another $1.5 billion in tax deductions from a separate paper shuffle that it made when News reincorporated in the US.”

(Fair ECHH noongs price mis BROW chh.)

Seltene Sprachen und Dialekte, die über Crowdsourcing aufgenommen und gedolmetscht wurden

Researchers at the University of Melbourne have created a free app that lets speakers of endangered languages, whether encountered by academics doing field work or self-selected in networks of colingual neighbors and friends, use relatively cheap Android phones to record their speech. After the sound file is uploaded, people anywhere can listen, stop the playback at any point and record voice translations of the sentences into another language. The translation sound files are linked to the source sound files in the database, creating a vast verbal Rosetta stone that doesn’t require literacy to accomplish preservation and sharing. This archive of vocabulary, grammar and content—tales and histories—will be available for future linguists to explore, centuries from now.

In an interview about the project on Australian ABC Radio National, Dr. Bird said once the person demonstrating the software has explained how it works, it is older people especially in the village who are delighted and start recording story after story in these rare languages.

(ZELL ten ah   SHPRRROCHHH en   oont   dee ah LECKED ah,   dee   über   KRAUT sourcingk   ow! f geh nome en   oont   geh DOLE metched   voor den.)

Auge in Auge in Auge in Auge in Auge

“Eye to eye to eye to eye to eye,” the Five Eyes alliance of data-sharing intelligence agencies from the countries of UK, USA, Canada, Australia and New Zealand.

(OW! geh   in   OW! geh   in   OW! geh   in   OW! geh   in   OW! geh)

Bourguiba Spracheninstitut

Language institute in Tunisia where Salafists recently tried to halt filming of a “Harlem Shake” video, actually fighting with students and waving but not wielding a Molotov cocktail. After Education Minister Abdellatif Abid (Ettakatol party, a secular center-left ally of Ennahda, Tunisia’s ruling Islamist party) threatened to expell students or fire staff involved in Harlem Shake videos this week, the Tunisian Ministry of Education’s website was hacked and a call went out via social media for a giant H.S. on Friday, March 1.

(Boor GWEE ba   SHPROCHH en in stee toot.)

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