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Transfer pricing

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 arm’s-length principle). The OECD and World Bank recommend intragroup pricing rules based on the arm’s-length principle, and 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 generally 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, services, 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 generally 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 (transfer mispricing),    the term refers to a set of substantive and administrative regulatory requirements imposed by governments on certain taxpayers. However, aggressive intragroup pricing – especially for debt and intangibles – has played a major role in corporate tax avoidance, and it was one of the issues identified when the OECD released its base erosion and profit shifting (BEPS) 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, which is a technique for concealing illicit transfers by reporting falsified prices on invoices submitted to customs officials. “Because they often both involve mispricing, many aggressive tax avoidance schemes by multinational corporations can easily 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.

In general
Over sixty governments have adopted transfer pricing rules, which in almost all cases (with the notable exceptions of Brazil and Kazakhstan) 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 (for purposes of computing tax liability) where the prices charged are outside an arm's length range. Most, if not all, governments permit adjustments by the tax authority even where there is no intent to avoid or evade tax. The rules generally require that market level, functions, risks, 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 generally 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 generally 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 generally is allowed (at least by the adjusting government) 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 commonly used methods are comparable uncontrolled prices, cost-plus, resale price or markup, and 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 (including intangible 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, Canada, 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 generally considered to be improved by use of multiple year data.

Most rules require that the tax authorities consider actual transactions between parties, and permit adjustment only to actual transactions. Multiple transactions may be aggregated or tested separately, and testing may use multiple year data. In addition, transactions whose economic substance differs materially from their form may be recharacterized under the laws of many systems to follow the economic substance.

Transfer pricing adjustments have been a feature of many tax systems since the 1930s. The United States led the development of detailed, comprehensive transfer pricing guidelines with a White Paper in 1988 and proposals in 1990–1992, which ultimately became regulations in 1994. In 1995, the OECD issued its transfer pricing guidelines which it expanded in 1996 and 2010. The two sets of guidelines are broadly similar and contain certain principles followed by many countries. The OECD guidelines have been formally adopted by many European Union countries with little or no modification.

Comparability
Most rules provide standards for when unrelated party prices, transactions, profitability or other items are considered sufficiently comparable in testing related party items. Such standards typically require that data used in comparisons be reliable and that the means used to compare produce a reliable result. The U.S. and OECD rules require that reliable adjustments must be made for all differences (if any) between related party items and purported comparables that could materially affect the condition being examined. Where such reliable adjustments cannot be made, the reliability of the comparison is in doubt. Comparability of tested prices with uncontrolled prices is generally considered enhanced by use of multiple data. Transactions not undertaken in the ordinary course of business generally are not considered to be comparable to those taken in the ordinary course of business. Among the factors that must be considered in determining comparability are:
 * the contractual terms of the transaction, either formalized in written contract or not;
 * the functions performed by each of the parties to the transaction taking into account assets used and risks assumed (so-called Functions, Assets, and Risks Analysis or FAR Analysis);
 * the characteristics of property transferred or services provided, as difference in quality or the extent of service may affect price;
 * the economic circumstances of the parties and of the market in which the parties operate, e.g. the geographic location, the extent of competition, and consumer purchasing power may result in different pricing even for the same goods and services; and
 * the business strategies pursued by the parties, e.g. start-ups and mature businesses may have different pricing strategy, whether to focus on customer acquisition or profitability.

Nature of property or services
Comparability is best achieved where identical items are compared. However, in some cases it is possible to make reliable adjustments for differences in the particular items, such as differences in features or quality. For example, gold prices might be adjusted based on the weight of the actual gold (one ounce of 10 carat gold would be half the price of one ounce of 20 carat gold).

Functions and risks
Buyers and sellers may perform different functions related to the exchange and undertake different risks. For example, a seller of a machine may or may not provide a warranty. The price a buyer would pay will be affected by this difference. Among the functions and risks that may impact prices are:
 * Product development
 * Manufacturing and assembly
 * Marketing and advertising
 * Transportation and warehousing
 * Credit risk
 * Product obsolescence risk
 * Market and entrepreneurial risks
 * Collection risk
 * Financial and currency risks
 * Company- or industry-specific items

Terms of sale
Manner and terms of sale may have a material impact on price. For example, buyers will pay more if they can defer payment and buy in smaller quantities. Terms that may impact price include payment timing, warranty, volume discounts, duration of rights to use of the product, form of consideration, etc.

Market level, economic conditions and geography
Goods, services, or property may be provided to different levels of buyers or users: producer to wholesaler, wholesaler to wholesaler, wholesaler to retailer, or for ultimate consumption. Market conditions, and thus prices, vary greatly at these levels. In addition, prices may vary greatly between different economies or geographies. For example, a head of cauliflower at a retail market will command a vastly different price in unelectrified rural India than in Tokyo. Buyers or sellers may have different market shares that allow them to achieve volume discounts or exert sufficient pressure on the other party to lower prices. Where prices are to be compared, the putative comparables must be at the same market level, within the same or similar economic and geographic environments, and under the same or similar conditions.

Testing of prices
Tax authorities generally examine prices actually charged between related parties to determine whether adjustments are appropriate. Such examination is by comparison (testing) of such prices to comparable prices charged among unrelated parties. Such testing may occur only on examination of tax returns by the tax authority, or taxpayers may be required to conduct such testing themselves in advance of filing tax returns. Such testing requires a determination of how the testing must be conducted, referred to as a transfer pricing method.

Best method rule
Some systems give preference to a specific method of testing prices. OECD and U.S. systems, however, provide that the method used to test the appropriateness of related party prices should be that method that produces the most reliable measure of arm's length results. This is often known as a "best method" rule. Factors to be considered include comparability of tested and independent items, reliability of available data and assumptions under the method, and validation of the results of the method by other methods.

Comparable uncontrolled price (CUP) method
The comparable uncontrolled price (CUP) method is a transactional method that determines the arm's-length price using the prices charged in comparable transactions between unrelated parties. In principle, the OECD and most countries that follow the OECD guidelines consider the CUP method to be the most direct method, provided that any differences between the controlled and uncontrolled transactions have no material effect on price or their effects can be estimated and corresponding price adjustments can be made. Adjustments may be appropriate where the controlled and uncontrolled transactions differ only in volume or terms; for example, an interest adjustment could be applied where the only difference is time for payment (e.g., 30 days vs. 60 days). For undifferentiated products such as commodities, price data for arm's-length transactions ("external comparables") between two or more other unrelated parties may be available. For other transactions, it may be possible to use comparable transactions ("internal comparables") between the controlled party and unrelated parties.

The criteria for reliably applying the CUP method are often impossible to satisfy for licenses and other transactions involving unique intangible property, requiring use of valuation methods based on profit projections.

Other transactional methods
Among other methods relying on actual transactions (generally between one tested party and third parties) and not indices, aggregates, or market surveys are:
 * Cost-plus (C+) method: goods or services provided to unrelated parties are consistently priced at actual cost plus a fixed markup.  Testing is by comparison of the markup percentages.
 * Resale price method (RPM): goods are regularly offered by a seller or purchased by a retailer to/from unrelated parties at a standard "list" price less a fixed discount.  Testing is by comparison of the discount percentages.
 * Gross margin method: similar to resale price method, recognised in a few systems.

Profit-based methods
Some methods of testing prices do not rely on actual transactions. Use of these methods may be necessary due to the lack of reliable data for transactional methods. In some cases, non-transactional methods may be more reliable than transactional methods because market and economic adjustments to transactions may not be reliable. These methods may include:
 * Comparable profits method (CPM): profit levels of similarly situated companies in similar industries may be compared to an appropriate tested party.  See U.S. rules below.
 * Transactional net margin method (TNMM): while called a transactional method, the testing is based on profitability of similar businesses.  See OECD guidelines below.
 * Profit split method: total enterprise profits are split in a formulary manner based on econometric analyses.

CPM and TNMM have a practical advantage in ease of implementation. Both methods rely on microeconomic analysis of data rather than specific transactions. These methods are discussed further with respect to the U.S. and OECD systems.

Two methods are often provided for splitting profits: comparable profit split and residual profit split. The former requires that profit split be derived from the combined operating profit of uncontrolled taxpayers whose transactions and activities are comparable to the transactions and activities being tested. The residual profit split method requires a two step process: first profits are allocated to routine operations, then the residual profit is allocated based on nonroutine contributions of the parties. The residual allocation may be based on external market benchmarks or estimation based on capitalised costs.

Tested party and profit level indicator
Where testing of prices occurs on other than a purely transactional basis, such as CPM or TNMM, it may be necessary to determine which of the two related parties should be tested. Testing is to be done of that party testing of which will produce the most reliable results. Generally, this means that the tested party is that party with the most easily compared functions and risks. Comparing the tested party's results to those of comparable parties may require adjustments to results of the tested party or the comparables for such items as levels of inventory or receivables.

Testing requires determination of what indication of profitability should be used. This may be net profit on the transaction, return on assets employed, or some other measure. Reliability is generally improved for TNMM and CPM by using a range of results and multiple year data. this is based on circumstances of the relevant countries.

Intangible property issues
Valuable intangible property tends to be unique. Often there are no comparable items. The value added by use of intangibles may be represented in prices of goods or services, or by payment of fees (royalties) for use of the intangible property. Licensing of intangibles thus presents difficulties in identifying comparable items for testing. However, where the same property is licensed to independent parties, such license may provide comparable transactional prices. The profit split method specifically attempts to take value of intangibles into account.

Services
Enterprises may engage related or unrelated parties to provide services they need. Where the required services are available within a multinational group, there may be significant advantages to the enterprise as a whole for components of the group to perform those services. Two issues exist with respect to charges between related parties for services: whether services were actually performed which warrant payment, and the price charged for such services. Tax authorities in most major countries have, either formally or in practice, incorporated these queries into their examination of related party services transactions.

There may be tax advantages obtained for the group if one member charges another member for services, even where the member bearing the charge derives no benefit. To combat this, the rules of most systems allow the tax authorities to challenge whether the services allegedly performed actually benefit the member charged. The inquiry may focus on whether services were indeed performed as well as who benefited from the services. For this purpose, some rules differentiate stewardship services from other services. Stewardship services are generally those that an investor would incur for its own benefit in managing its investments. Charges to the investee for such services are generally inappropriate. Where services were not performed or where the related party bearing the charge derived no direct benefit, tax authorities may disallow the charge altogether.

Where the services were performed and provided benefit for the related party bearing a charge for such services, tax rules also permit adjustment to the price charged. Rules for testing prices of services may differ somewhat from rules for testing prices charged for goods due to the inherent differences between provision of services and sale of goods. The OECD Guidelines provide that the provisions relating to goods should be applied with minor modifications and additional considerations. In the U.S., a different set of price testing methods is provided for services. In both cases, standards of comparability and other matters apply to both goods and services.

It is common for enterprises to perform services for themselves (or for their components) that support their primary business. Examples include accounting, legal, and computer services for those enterprises not engaged in the business of providing such services. Transfer pricing rules recognize that it may be inappropriate for a component of an enterprise performing such services for another component to earn a profit on such services. Testing of prices charged in such case may be referred to a cost of services or services cost method. Application of this method may be limited under the rules of certain countries, and is required in some countries e.g. Canada.

Where services performed are of a nature performed by the enterprise (or the performing or receiving component) as a key aspect of its business, OECD and U.S. rules provide that some level of profit is appropriate to the service performing component. Canada's rules do not permit such profit. Testing of prices in such cases generally follows one of the methods described above for goods. The cost-plus method, in particular, may be favored by tax authorities and taxpayers due to ease of administration.

Cost sharing
Multi-component enterprises may find significant business advantage to sharing the costs of developing or acquiring certain assets, particularly intangible assets. Detailed U.S. rules provide that members of a group may enter into a cost sharing agreement (CSA) with respect to costs and benefits from the development of intangible assets. OECD Guidelines provide more generalized suggestions to tax authorities for enforcement related to cost contribution agreements (CCAs) with respect to acquisition of various types of assets. Both sets of rules generally provide that costs should be allocated among members based on respective anticipated benefits. Inter-member charges should then be made so that each member bears only its share of such allocated costs. Since the allocations must inherently be made based on expectations of future events, the mechanism for allocation must provide for prospective adjustments where prior projections of events have proved incorrect. However, both sets of rules generally prohibit applying hindsight in making allocations.

A key requirement to limit adjustments related to costs of developing intangible assets is that there must be a written agreement in place among the members. Tax rules may impose additional contractual, documentation, accounting, and reporting requirements on participants of a CSA or CCA, which vary by country.

Generally, under a CSA or CCA, each participating member must be entitled to use of some portion rights developed pursuant to the agreement without further payments. Thus, a CCA participant should be entitled to use a process developed under the CCA without payment of royalties. Ownership of the rights need not be transferred to the participants. The division of rights is generally to be based on some observable measure, such as by geography.

Participants in CSAs and CCAs may contribute pre-existing assets or rights for use in the development of assets. Such contribution may be referred to as a platform contribution. Such contribution is generally considered a deemed payment by the contributing member, and is itself subject to transfer pricing rules or special CSA rules.

A key consideration in a CSA or CCA is what costs development or acquisition costs should be subject to the agreement. This may be specified under the agreement, but is also subject to adjustment by tax authorities.

In determining reasonably anticipated benefits, participants are forced to make projections of future events. Such projections are inherently uncertain. Further, there may exist uncertainty as to how such benefits should be measured. One manner of determining such anticipated benefits is to project respective sales or gross margins of participants, measured in a common currency, or sales in units.

Both sets of rules recognize that participants may enter or leave a CSA or CCA. Upon such events, the rules require that members make buy-in or buy-out payments. Such payments may be required to represent the market value of the existing state of development, or may be computed under cost recovery or market capitalization models.

Penalties and documentation
Some jurisdictions impose significant penalties relating to transfer pricing adjustments by tax authorities. These penalties may have thresholds for the basic imposition of penalty, and the penalty may be increased at other thresholds. For example, U.S. rules impose a 20% penalty where the adjustment exceeds US$5 million, increased to 40% of the additional tax where the adjustment exceeds US$20 million.

The rules of many countries require taxpayers to document that prices charged are within the prices permitted under the transfer pricing rules. Where such documentation is not timely prepared, penalties may be imposed, as above. Documentation may be required to be in place prior to filing a tax return in order to avoid these penalties. Documentation by a taxpayer need not be relied upon by the tax authority in any jurisdiction permitting adjustment of prices. Some systems allow the tax authority to disregard information not timely provided by taxpayers, including such advance documentation. India requires that documentation not only be in place prior to filing a return, but also that the documentation be certified by the chartered accountant preparing a company return.

U.S. specific tax rules
U.S. transfer pricing rules are lengthy. They incorporate all of the principles above, using CPM (see below) instead of TNMM. U.S. rules specifically provide that a taxpayer's intent to avoid or evade tax is not a prerequisite to adjustment by the Internal Revenue Service, nor are nonrecognition provisions. The U.S. rules give no priority to any particular method of testing prices, requiring instead explicit analysis to determine the best method. U.S. comparability standards limit use of adjustments for business strategies in testing prices to clearly defined market share strategies, but permit limited consideration of location savings.

Comparable profits method
The Comparable Profits method (CPM) was introduced in the 1992 proposed regulations and has been a prominent feature of IRS transfer pricing practice since. Under CPM, the tested party's overall results, rather than its transactions, are compared with the overall results of similarly situated enterprises for whom reliable data is available. Comparisons are made for the profit level indicator that most reliably represents profitability for the type of business. For example, a sales company's profitability may be most reliably measured as a return on sales (pre-tax profit as a percent of sales).

CPM inherently requires lower levels of comparability in the nature of the goods or services. Further, data used for CPM generally can be readily obtained in the U.S. and many countries through public filings of comparable enterprises.

Results of the tested party or comparable enterprises may require adjustment to achieve comparability. Such adjustments may include effective interest adjustments for customer financing or debt levels, inventory adjustments, etc.

Cost plus and resale price issues
U.S. rules apply resale price method and cost-plus with respect to goods strictly on a transactional basis. Thus, comparable transactions must be found for all tested transactions in order to apply these methods. Industry averages or statistical measures are not permitted. Where a manufacturing entity provides contract manufacturing for both related and unrelated parties, it may readily have reliable data on comparable transactions. However, absent such in-house comparables, it is often difficult to obtain reliable data for applying cost-plus.

The rules on services expand cost-plus, providing an additional option to mitigate these data problems. Charges to related parties for services not in the primary business of either the tested party or the related party group are rebuttably presumed to be arm's length if priced at cost plus zero (the services cost method). Such services may include back-room operations (e.g., accounting and data processing services for groups not engaged in providing such services to clients), product testing, or a variety of such non-integral services. This method is not permitted for manufacturing, reselling, and certain other services that typically are integral to a business.

U.S. rules also specifically permit shared services agreements. Under such agreements, various group members may perform services which benefit more than one member. Prices charged are considered arm's length where the costs are allocated in a consistent manner among the members based on reasonably anticipated benefits. For instance, shared services costs may be allocated among members based on a formula involving expected or actual sales or a combination of factors.

Terms between parties
Under U.S. rules, actual conduct of the parties is more important than contractual terms. Where the conduct of the parties differs from terms of the contract, the IRS has authority to deem the actual terms to be those needed to permit the actual conduct.

Adjustments
U.S. rules require that the IRS may not adjust prices found to be within the arm's length range. Where prices charged are outside that range, prices may be adjusted by the IRS unilaterally to the midpoint of the range. The burden of proof that a transfer pricing adjustment by the IRS is incorrect is on the taxpayer unless the IRS adjustment is shown to be arbitrary and capricious. However, the courts have generally required both taxpayers and the IRS to demonstrate their facts where agreement is not reached.

Documentation and penalties
If the IRS adjusts prices by more than $5 million or 10 percent of the taxpayer’s gross receipts, penalties apply. The penalty is 20% of the amount of the tax adjustment, increased to 40% at a higher threshold.

This penalty may be avoided only if the taxpayer maintains contemporaneous documentation meeting requirements in the regulations, and provides such documentation to the IRS within 30 days of IRS request. If documentation is not provided at all, the IRS may make adjustments based on any information it has available. Contemporaneous means the documentation existed with 30 days of filing the taxpayer's tax return. Documentation requirements are quite specific, and generally require a best method analysis and detailed support for the pricing and methodology used for testing such pricing. To qualify, the documentation must reasonably support the prices used in computing tax.

Commensurate with income standard
U.S. tax law requires that the foreign transferee/user of intangible property (patents, processes, trademarks, know-how, etc.) will be deemed to pay to a controlling transferor/developer a royalty commensurate with the income derived from using the intangible property. This applies whether such royalty is actually paid or not. This requirement may result in withholding tax on deemed payments for use of intangible property in the U.S.

OECD specific tax rules
OECD guidelines are voluntary for member nations. Some nations have adopted the guidelines almost unchanged. Terminology may vary between adopting nations, and may vary from that used above.

OECD guidelines give priority to transactional methods, described as the "most direct way" to establish comparability. The Transactional Net Margin Method and Profit Split methods are used either as methods of last resort or where traditional transactional methods cannot be reliably applied. CUP is not given priority among transactional methods in OECD guidelines. The Guidelines state, "It may be difficult to find a transaction between independent enterprises that is similar enough to a controlled transaction such that no differences have a material effect on price." Thus, adjustments are often required to either tested prices or uncontrolled process.

Comparability standards
OECD rules permit consideration of business strategies in determining if results or transactions are comparable. Such strategies include market penetration, expansion of market share, cost or location savings, etc.

Transactional net margin method
The transactional net margin method (TNMM) compares the net profitability of a transaction, or group or aggregation of transactions, to that of another transaction, group or aggregation. Under TNMM, use of actual, verifiable transactions is given strong preference. However, in practice TNMM allows making computations for company-level aggregates of transactions. Thus, TNMM may in some circumstances function like U.S. CPM.

Terms
Contractual terms and transactions between parties are to be respected under OECD rules unless both the substance of the transactions differs materially from those terms and following such terms would impede tax administration.

Adjustments
OECD rules generally do not permit tax authorities to make adjustments if prices charged between related parties are within the arm's length range. Where prices are outside such range, the prices may be adjusted to the most appropriate point. The burden of proof of the appropriateness of an adjustment is generally on the tax authority.

Documentation
OECD Guidelines do not provide specific rules on the nature of taxpayer documentation. Such matters are left to individual member nations.

EU
In 2002, the European Union created the EU Joint Transfer Pricing Forum. The Communication on "Tax and Development – Cooperating with Developing Countries in Promoting Good Governance in Tax Matters‟, COM (2010) 163 final, highlighted the need to support developing countries' capacity in mobilizing domestic resources for development in line with the principles of good governance in taxation. In this context, PwC prepared the report Transfer pricing and developing countries.

Many EU countries are currently implementing the OECD Guidelines for Transfer Pricing. The latest adopter is Cyprus which issued a ruling in 2017 for financial arrangements.

China specific tax rules
Prior to 2009, China generally followed OECD Guidelines. New guidelines were announced by the State Administration of Taxation (SAT) in March 2008 and issued in January 2009. These guidelines differed materially in approach from those in other countries in two principal ways: 1) they were guidelines issued instructing field offices how to conduct transfer pricing examinations and adjustments, and 2) factors to be examined differed by transfer pricing method. The guidelines covered: On September 17, 2015, the SAT released a revised draft version of the "Implementation Measures for Special Tax Adjustment (Circular 2)," which replaced the previous 2009 guidelines. Three new sections were introduced under the revised draft: monitoring and management, intangible transactions/intra-group services and a new approach to transfer pricing documentation.
 * Administrative matters
 * Required taxpayer filings and documentation
 * General transfer pricing principles, including comparability
 * Guidelines on how to conduct examinations
 * Advance pricing and cost sharing agreement administration
 * Controlled foreign corporation examinations
 * Thin capitalization
 * General anti-avoidance

Documentation
Under the 2009 Circular, taxpayers must disclose related party transactions when filing tax returns. In addition, the circular provides for a three-tier set of documentation and reporting standards, based on the aggregate amount of intercompany transactions. Taxpayers affected by the rules who engaged in intercompany transactions under RMB 20 million for the year were generally exempted from reporting, documentation, and penalties. Those with transactions exceeding RMB 200 million generally were required to complete transfer pricing studies in advance of filing tax returns. For taxpayers in the top tier, documentation must include a comparability analysis and justification for the transfer pricing method chosen.

The 2015 draft introduced an overhauled three-tiered standardized approach to transfer pricing documentation. The tiers vary in documentation content and include the master file, the local file, and the country-by-country report. The draft also requires companies involved with related-party service transactions, cost sharing agreements or thin capitalization to submit a so-called "Special File."

General principles
Chinese transfer pricing rules apply to transactions between a Chinese business and domestic and foreign related parties. A related party includes enterprises meeting one of eight different tests, including 25% equity ownership in common, overlapping boards or management, significant debt holdings, and other tests. Transactions subject to the guidelines include most sorts of dealings businesses may have with one another.

The Circular instructs field examiners to review taxpayer's comparability and method analyses. The method of analyzing comparability and what factors are to be considered varies slightly by type of transfer pricing analysis method. The guidelines for CUP include specific functions and risks to be analyzed for each type of transaction (goods, rentals, licensing, financing, and services). The guidelines for resale price, cost-plus, transactional net margin method, and profit split are short and very general.

Cost sharing
The China rules provide a general framework for cost sharing agreements. This includes a basic structure for agreements, provision for buy-in and exit payments based on reasonable amounts, minimum operating period of 20 years, and mandatory notification of the SAT within 30 days of concluding the agreement.

Agreements between taxpayers and governments and dispute resolution
Tax authorities of most major countries have entered into unilateral or multilateral agreements between taxpayers and other governments regarding the setting or testing of related party prices. These agreements are referred to as advance pricing agreements or advance pricing arrangements (APAs). Under an APA, the taxpayer and one or more governments agree on the methodology used to test prices. APAs are generally based on transfer pricing documentation prepared by the taxpayer and presented to the government(s). Multilateral agreements require negotiations between the governments, conducted through their designated competent authority groups. The agreements are generally for some period of years, and may have retroactive effect. Most such agreements are not subject to public disclosure rules. Rules controlling how and when a taxpayer or tax authority may commence APA proceedings vary by jurisdiction.

Economic theory
The discussion in this section explains an economic theory behind optimal transfer pricing with optimal defined as transfer pricing that maximizes overall firm profits in a non-realistic world with no taxes, no capital risk, no development risk, no externalities or any other frictions which exist in the real world. In practice a great many factors influence the transfer prices that are used by multinational corporations, including performance measurement, capabilities of accounting systems, import quotas, customs duties, VAT, taxes on profits, and (in many cases) simple lack of attention to the pricing.

From marginal price determination theory, the optimum level of output is that where marginal cost equals marginal revenue. That is to say, a firm should expand its output as long as the marginal revenue from additional sales is greater than their marginal costs. In the diagram that follows, this intersection is represented by point A, which will yield a price of P*, given the demand at point B.

When a firm is selling some of its product to itself, and only to itself (i.e. there is no external market for that particular transfer good), then the picture gets more complicated, but the outcome remains the same. The demand curve remains the same. The optimum price and quantity remain the same. But marginal cost of production can be separated from the firm's total marginal costs. Likewise, the marginal revenue associated with the production division can be separated from the marginal revenue for the total firm. This is referred to as the net marginal revenue in production (NMR) and is calculated as the marginal revenue from the firm minus the marginal costs of distribution. It can be shown algebraically that the intersection of the firm's marginal cost curve and marginal revenue curve (point A) must occur at the same quantity as the intersection of the production division's marginal cost curve with the net marginal revenue from production (point C).

If the production division is able to sell the transfer good in a competitive market (as well as internally), then again both must operate where their marginal costs equal their marginal revenue, for profit maximization. Because the external market is competitive, the firm is a price taker and must accept the transfer price determined by market forces (their marginal revenue from transfer and demand for transfer products becomes the transfer price). If the market price is relatively high (as in Ptr1 in the next diagram), then the firm will experience an internal surplus (excess internal supply) equal to the amount Qt1 minus Qf1. The actual marginal cost curve is defined by points A,C,D.

If the firm is able to sell its transfer goods in an imperfect market, then it need not be a price taker. There are two markets each with its own price (Pf and Pt in the next diagram). The aggregate market is constructed from the first two. That is, point C is a horizontal summation of points A and B (and likewise for all other points on the net marginal revenue curve (NMRa)). The total optimum quantity (Q) is the sum of Qf plus Qt.

Alternative approaches to profit allocation
A frequently-proposed alternative to arm's-length principle-based transfer pricing rules is formulary apportionment, under which corporate profits are allocated according to objective metrics of activity such as sales, employees, or fixed assets. Some countries (including Canada and the United States) allocate taxing rights among their political subdivisions in this way, and it has recommended by the European Commission for use within the European Union. According to the amicus curiae brief, filed by the attorneys general of Alaska, Montana, New Hampshire, and Oregon in support of the state of California in the U.S. Supreme Court case of Barclays Bank PLC v. Franchise Tax Board, the formulary apportionment method, which is also known as the unitary apportionment method, has at least three major advantages over the separate accounting system when applied to multi-jurisdictional businesses. First, the unitary method captures the added wealth and value resulting from economic interdependencies of multistate and multinational corporations through their functional integration, centralization of management, and economies of scale. A unitary business also benefits from more intangible values shared among its constituent parts, such as reputation, good will, customers and other business relationships. See, e.g., Mobil, 445 U.S. at 438–40; Container, 463 U.S. at 164–65.

Separate accounting, with its emphasis on carving out of the overall business only income from sources within a single state, ignores the value attributable to the integrated nature of the business. Yet, to a large degree, the wealth, power, and profits of the world's large multinational enterprises are attributable to the very fact that they are integrated, unitary businesses. Hellerstein Treatise, P8.03 at 8-32.n9 As one commentator has explained: To believe that multinational corporations do not maintain an advantage over independent corporations operating within a similar business sphere is to ignore the economic and political strength of the multinational giants. By attempting to treat those businesses which are in fact unitary as independent entities, separate accounting "operates in a universe of pretense; as in Alice in Wonderland, it turns reality into fancy and then pretends it is the real world".

Because countries impose different corporate tax rates, a corporation that has a goal of minimizing the overall taxes to be paid will set transfer prices to allocate more of the worldwide profit to lower tax countries. Many countries attempt to impose penalties on corporations if the countries consider that they are being deprived of taxes on otherwise taxable profit. However, since the participating countries are sovereign entities, obtaining data and initiating meaningful actions to limit tax avoidance is hard. A publication of the Organisation for Economic Co-operation and Development (OECD) states, "Transfer prices are significant for both taxpayers and tax administrations because they determine in large part the income and expenses, and therefore taxable profits, of associated enterprises in different tax jurisdictions."

Reading and overall reference list
International:

 * Wittendorff, Jens: Transfer Pricing and the Arm's Length Principle in International Tax Law, 2010, Kluwer Law International, ISBN 90-411-3270-8.

Canada: China: Major international accounting and law firms have published summaries of the guidelines. See their web sites.
 * Section 247 of the Income Tax Act (Canada)
 * Information Circular 87-2R - International Transfer Pricing (1999)
 * Information Circular 94-4R - International Transfer Pricing: Advance Pricing Arrangements (APAs) (2001)
 * TPM 07 - Referrals to the Transfer Pricing Review Committee (2005)
 * TPM 09 - Reasonable efforts under section 247 of the Income Tax Act (2006)

India:
 * Income Tax Department's compilation of Transfer Pricing Rules
 * Domestic Transfer Pricing Overview

Nigeria:
 * Transfer Pricing Regulations 2012 - Federal Inland Revenue Service

OECD:
 * Transfer Pricing Country Profiles, a useful cross reference to guidance in each member country
 * Base Erosion and Profit Shifting (BEPS), OECD landing page
 * Base Erosion and Profit Shifting (BEPS), OECD landing page

Russian Federation:
 * Tax Code of Russian Federation

United Kingdom:
 * Transfer pricing statute: ICTA88/Sch 28AA
 * HMRC International Manual Transfer Pricing INTM430000

United Nations

United States:
 * Law: 26 USC 482
 * Regulations: 26 CFR 1.482-0 through 9
 * IRS view on OECD rules: https://www.irs.gov/pub/irs-apa/apa_training_oecd_guidelines.pdf
 * APA Procedure: Rev. Proc. 2008-31
 * Feinschreiber, Robert: Transfer Pricing Methods, 2004, ISBN 978-0-471-57360-9
 * Parker, Kenneth and Levey, Marc: Tax Director's Guide to International Transfer Pricing, 2008, ISBN 978-1-60231-001-8
 * Services by Thompson RIA and Wolters Kluwer: search "transfer pricing" on their websites

title: Transfer pricing


text:
Shtick

A shtick is a comic theme or gimmick. The word entered the English language from the Yiddish shtik (שטיק), related to German Stück, Polish sztuka, Cyrillic штука (all ultimately from Proto-Germanic *stukkiją), all meaning "piece", "thing" or "theatre play"; Theaterstück is the German word for play (and is a synonym of Schauspiel, literally "viewing play" in contrast to Singspiel).

The English word piece is sometimes used in a similar context (for example, a musical piece). In stand-up comedy context a near equivalent term is a "bit". Another variant is "bits of business" or just "bits". Shtick may refer to an adopted persona, usually for comedy performances, that is maintained consistently (though not necessarily exclusively) across the performer's career. In this usage, the recurring personalities adopted by Laurel and Hardy through all of their many comedy films (although they often played characters with different names and occupations) would qualify as their shtick. A comedian might maintain several different shticks of this sort, particularly if appearing in a variety show encouraging development of multiple characters, such as Saturday Night Live.

In common usage, the word shtick has also come to mean any talent, style, habit, or other eccentricity for which a person is particularly well known, even if not intended for comedic purposes. For example, a person who is known locally for an ability to eat dozens of hot dogs quickly might say that it was his shtick. Among Orthodox Jews, "shtick" can also refer to wedding shtick, in which wedding guests entertain the bride and groom through dancing, costumes, juggling, and silliness.

Many fictional characters have more thematic shticks. This is particularly true of comic book villains, who are almost always seen wearing a particular costume and behaving in ways that are consistent with a bizarre and psychotic obsession. The supervillains of Batman (collectively known as the Rogues Gallery) are especially notorious for this (see below). There are also many professional wrestlers who deliver memorable catchphrases, and/or enter arenas performing signature gestures to the tune of thematically appropriate songs, causing crowds to laugh and cheer (see below).

What may be considered non-comedic and/or religious shticks are the metaphysical domains of the numerous gods and goddesses of the world’s mythologies, who each embody a particular set of supernatural powers and (usually) a complex of spiritual values. Perhaps the most famous example is the “thunder-god,” personified by Zeus, Jupiter, Thor, Indra, and other pagan deities. It is not unusual for comic book characters and professional wrestlers alike to draw upon these mythologies in their megalomania to craft either heroic or villainous personae; indeed, there exist both a DC Comics villain and a former pro wrestler who adopted “Zeus” as their name. Some of these characters genuinely are mythological figures, such as Thor and Loki of the Marvel Comics Universe. And in lighter entertainments such as Disney’s animated film Hercules and the ‘90s TV series Hercules: The Legendary Journeys, Greek deities tend to be rendered as comedic stereotypes, causing them to have literal shticks. On the series, for example, Athena, the goddess of wisdom, wears eyeglasses, while her sister, literal sex-goddess Aphrodite, is an archetypal “dumb blonde.” And in the Disney film, death-god Hades behaves like an evil stand-up comedian, cracking grim jokes.

Because of its roots in show business, shtick has taken on the connotation of a contrived and often-used act. For this reason, journalists and commentators often apply the word disparagingly to stock replies from politicians.

Notable examples

 * Charlie Chaplin created one of the earliest of modern comedy shticks: bowler hat, toothbrush mustache, bamboo cane, baggy pants, floppy shoes, and a waddling walk.
 * Buster Keaton sported a robotic, never-changing facial expression.
 * Harold Lloyd wore thick glasses and a boater hat.
 * Marcel Marceau, the archetypal mime artist, was famous for "Bip": a white-faced clown in a top hat and sailor suit. His act included pretending to walk against a stiff wind and behaving as if he were enclosed by walls. Countless other mimes have copied these acts.
 * Lucille Ball's shtick included imitating a baby's cry and wrinkling up her face. More elaborate routines included getting drunk while advertising a vitamin syrup and gobbling chocolates while working on the assembly line at a candy factory.
 * Jack Benny's character on his radio program was notoriously both stingy and a bad violin player, as well as being perpetually 39 years old. In real life, Benny was known as a competent violinist and lavish tipper, and kept celebrating his 39th birthday each year publicly because "there's nothing funny about 40".
 * Bill Cosby became famous for delivering satirical monologues (often about his humble upbringing) and complaining about the younger generation in an exasperated drawl.
 * Three of the Marx Brothers, Groucho, Chico and Harpo, had well-honed shticks by the time they started making movies.
 * Groucho, with his stooped walk, greasepaint moustache, lascivious eyebrow raising, and his cigar;
 * Chico, with his fake Italian accent, his "shooting the keys" style of piano playing, and borderline moronic behavior; and
 * Harpo, with his pantomime routines, the seemingly bottomless pockets of his trench coat, and his ability to play the harp.
 * The fourth performing brother, Zeppo, never developed a shtick and was a straight man in their movies — though some have argued that blandness and "normality" was indeed his shtick.
 * W.C. Fields nurtured a character that was not far from himself in real life, being misanthropic, misogynistic, and a hard drinker, as well as the unique bellow of his voice and his famous bulbous nose.
 * Many of the performers over the course of Saturday Night Live's long broadcast history have developed shticks that were popular enough to be developed into feature films. The earliest of these was The Blues Brothers, the dark-suited alter egos of Dan Aykroyd and John Belushi, which spawned two movies and several actual blues albums. Of the movies that followed in later years, some met with similar success (such as Mike Myers' Wayne's World), while others are regarded as critical and commercial disasters (Julia Sweeney's It's Pat!).
 * Henny Youngman's standard line "Take my wife — please!" was part of his shtick. It consisted of several one-liners delivered in rapid-fire sequence.
 * Johnny Carson's many shticks include his role as "Carnac the Magnificent", an Indian fortune teller who could divine answers to questions sealed in envelopes and "kept in a hermetically sealed mayonnaise jar on the front porch of Funk & Wagnalls since noon today". His signature imaginary golf swing at the end of his monologue would also qualify.
 * Chris Berman's shtick in his ESPN commentary was his tendency to give additional nicknames to players based on their last names (often intended as puns or pop culture references). Berman was also known to often say a football player "could — go — all — the — way" on long touchdown plays (parodying Howard Cosell's delivery).
 * Comedian George Carlin created a famously banned shtick, "Filthy Words", a/k/a "Seven dirty words."
 * Andrew Dice Clay's shtick in his comedy routines is his crude, misogynist themed humor, and sometimes vulgar reinterpretations of nursery rhymes.
 * Rodney Dangerfield's shtick was centered around his famous catchphrase, "I don't get no respect," accompanied by his characteristic facial gesture and yanking or straightening his scarlet necktie.
 * Stephen Colbert has referred to his character from his show The Colbert Report as a shtick.
 * Andy Kaufman was a particularly rigorous practitioner of shtick. Kaufman almost never appeared in public, other than as one of his shtick characters, such as "Foreign Man" or Tony Clifton. When he did appear as himself, he still acted out some shtick routine, with one notable example being a long-running professional wrestling feud with Jerry Lawler.
 * The Rubberbandits are Irish comedians who wear plastic bags over their faces as shtick.
 * Yakov Smirnoff's shtick, at the height of his career, involved comparisons between the United States and the Soviet Union, punctuated by the catchphrase "What a country!".
 * Lewis Black's shtick is the crescendo of rage upon which his routines are built; another is bewailing the rise in his blood pressure due to the presumed strain of these outbursts.
 * Sam Kinison's shtick was his increasingly emotional, high-stress vocal delivery, often leading to actual shouting or screaming, to the point where his voice became hoarse.
 * Bob Newhart's shtick is his long phone calls with imaginary or historical persons. Hearing only Newhart's deadpan comments, the audience is left to infer what the other person is saying.
 * All original members of The Wiggles were known for having shticks. Jeff Fatt's was falling asleep at odd times, leading the other Wiggles and the audience to call out the catchphrase "Wake Up Jeff!", Anthony Field's was eating too much food, Greg Page's was doing magic tricks, and Murray Cook's was an obsession with playing the guitar.
 * Penn and Teller's shtick focuses mainly on which part of the duo does the talking; Penn provides the only on-stage narration and is the only public voice of the act, whereas Teller never speaks on stage or on camera. In on-camera interviews, Teller remains in shadow, and in rare circumstances when Teller speaks on-stage, his face is obscured.
 * Gilbert Gottfried's stage persona, with his perpetually high-pitched squeaky voice and pinched face, is a shtick that has been maintained through almost all of his public appearances and television and film roles.
 * Larry the Cable Guy's stage persona, developed during his days as a member of a morning radio zoo crew, is considered a shtick. Despite his public appearances as a hillbilly with a deep Southern accent, propensity for wearing sleeveless flannel shirts and his signature "Git-R-Done!" catchphrase, the comedian, whose real name is Daniel Whitney, is a native of Nebraska.
 * Jerry Lewis played a nerd character with a nasal voice and overexcited mannerisms.
 * Flip Wilson had as his catchphrase "The devil made me do it!"
 * Pee-wee Herman is recognizable for his tight-fitting gray suit, red bow tie, short black hair, pale face, and rouged cheeks. He also delivers a high-pitched laugh, and is often seen riding a colorful bicycle. His trademark comeback is "I know you are, but what am I?"
 * Adam Sandler once performed the shtick of playing simple ditties on his guitar (most famously his "Hanukkah" song) while awkwardly singing lyrics in a whiny voice.
 * Chris Farley was a large, heavyset, clumsy man, with a loud and sometimes wheezy voice. His most famous sketch character, Matt Foley, would warn other characters to behave, lest they wind up "living in a van down by the river," before falling and crashing into something.
 * Julie Brown was known for her stereotypical "dumb blonde" character, and her lisp.
 * Jaleel White was known as Steve Urkel, a nerdy boy who wore glasses and suspenders, played the accordion, and delivered a snorting laugh. His most noteworthy shtick was accidentally destroying something and then asking guiltily, "Did I do that?"

Batman villain examples

 * The Joker (real name unknown): This psychopathic killer naturally resembles a clown, wears a purple suit, and commits crimes that often reference humorous entertainments, such as the circus, vaudeville, stand-up comedy, or cartoons. His partner Harley Quinn performs a similar, though often feminized, shtick.
 * Catwoman (real name Selina Kyle): A beautiful cat burglar who imitates an actual cat with her claws, pointed-eared mask, and skintight bodysuit.
 * The Penguin (real name Oswald Cobblepot): Has a fascination with birds, and penguins in particular. Also wears a tuxedo and top hat, and uses an umbrella for various purposes.
 * Two-Face (real name Harvey Dent): Half his face is hideously scarred, and he is obsessed with the duality of human nature. His morality is determined by the flip of a coin that has scratch marks carved into one side.
 * The Riddler (real name Edward Nigma; sometimes Nashton): Leaves clues to his criminal capers in the form of riddles.
 * The Mad Hatter (real name Jervis Tetch): Commits crimes thematically based either on hats or on the children's story Alice in Wonderland.
 * Mr. Freeze (real name Victor Fries): A metahuman who can survive only in a cybernetic suit that keeps his body at subzero temperatures. Uses an ice-spraying gun as his weapon.
 * Poison Ivy (real name Pamela Isley): A fanatical botanist, she considers plants to be more worthy of life than humans. Dresses in foliage and commits crimes with the help of mutated, often carnivorous plants. She can kill a victim with the toxins in her body via a kiss. Harley Quinn is her sidekick and lover, despite the differences between their shticks.
 * The Scarecrow (real name Jonathan Crane): Dresses as his namesake. Infects his victims with a hallucinogenic gas that causes them to see their worst fears come to life.
 * Bane (real name Eduardo Dorrance): He was a former prisoner subjected to a dangerous medical experiment that gave him superior physical strength and near-invulnerability. Usually seen wearing a frightening hooded mask, to which is attached an implant that pumps Venom, a powerful steroid, directly into his bloodstream.
 * Ra's Al-Ghul: He is a wealthy Middle Eastern lord whose facial hair gives him the appearance of a devil. He is centuries old due to regular immersions in the rejuvenating chemicals of the Lazarus Pit. A genocidal lunatic, his objective is to destroy everything in the world he considers evil.
 * The Ventriloquist (real name Arnold Wesker): He is skilled at throwing his voice, and expresses an alternate personality through Scarface, a wooden dummy dressed as a gangster.
 * Maxie Zeus (real name Max Zlotski): Believes himself to be the Greek god of thunder, and usually seen wearing a toga and sandals.
 * Clayface (real name Matt Hagen): A former actor whose body chemistry was mutated by a putty-like substance, he is able to reshape his body into the form of any human he wishes, as well as being able to mimic his or her voice.
 * Killer Croc (real name Waylon Jones): Suffers from a disease that has left him with scaly green skin, and believes himself to be an actual crocodile.
 * The Firefly (real name Garfield Lynns): An arsonist armed with a flamethrower, dressed in metal armor that makes him resemble a humanoid insect.
 * Abbatoir (real name Arnold Etchison): This cannibalistic serial killer slaughtered and ate members of his family, believing that their "souls" would keep him alive indefinitely. He was one of the few Batman villains who was killed and stayed dead.
 * Baby Doll (real name Mary Dahl): Born with a chronic condition that left her with the physical proportions of a toddler, she believes herself to be literally a toddler, albeit an evil one.
 * Roxy Rocket (real name Roxanne Sutton): Dresses as a World War I fighter pilot and rides a missile-shaped aircraft.
 * Hush (real name Thomas Elliot): This villain worked behind the scenes, secretly manipulating other villains. His face was always swathed in bandages. He was fond of quoting the philosopher Aristotle.
 * Deadshot (real name Floyd Lawton): Known as the world's greatest sharpshooter and assassin-for-hire.
 * Black Mask (real name Roman Sionis): This mob boss has a mania for masks, and conceals his burned face with one that is black and terrifying. His minions, collectively known as the False Face society, also wear masks.
 * Victor Zsasz: A knife-wielding murderer who usually appears stripped to the waist or almost naked, displaying the tally marks carved into his skin for every victim whose throat he has slit.
 * The Phantasm (real name Andrea Beaumont): An assassin who dresses in a futuristic suit that makes her resemble the Grim Reaper.
 * Cap'n Fear: Looks, talks, and acts like a colonial-era pirate captain.
 * The Ratcatcher (real name Otis Flannegan): A former exterminator, he instead came to see himself as the leader of all sewer rats. He summons the rats by blowing into a "silent" whistle.
 * Azrael (real name Jean-Paul Valley): More of an antihero than a villain, Azrael wore the disguise of a murderous knight with a fiery sword. The Azrael persona was passed down from father to son for several centuries.
 * Mr. Nice: This mild-mannered, bespectacled man stages violent robberies, but also attempts to be polite and even kind to his victims.
 * The General (real name Ulysses Armstrong): A child prodigy obsessed with military history.
 * The Troika: Three ex-Soviet spies (Dark Rider, Romana, Colonel Vega) turned terrorists, they continued to operate after Russia's communist government fell. They were assisted by the KGBeast, a hulking cyborg.
 * The Condiment King (real name Buddy Standler): One of the most humorous (and harmless) members of the Rogues Gallery. All he was capable of doing was squirting messy condiments at people. He was revealed to be a stand-up comedian whom the Joker, in a fit of jealousy, drove insane using a mind chip.

Professional wrestling shticks
Tojo Yamamoto (real name Harold Watanabe, who was Japanese-American) played to American awareness of the Pacific Theater of World War II. Tojo was a Japanese general, and Yamamoto was the Japanese admiral who oversaw the attack on Pearl Harbor. Tojo Yamamoto wore a kimono to the ring, and often would use wooden shoes to strike opponents.
 * "Gorgeous George" Wagner developed one of the earliest wrestling gimmicks: that of an effeminate wrestler with curled blond hair, who had a phobia of germs and would be accompanied to the ring by a servant spraying antiseptic perfume.
 * "Nature Boy" Buddy Rogers was one of the first "arrogant heel" characters. He was known for saying, "To a nicer guy, it couldn't happen."
 * Hulk Hogan: Known for flexing his biceps while flashing a wild-eyed expression. Told children to "eat their vitamins and say their prayers."
 * Ric Flair sported an elaborate robe and long blond hair, and delivered numerous catchphrases, such as "Woo!" and "To be the man, you gotta beat the man." During his matches he would sometimes "strut," walking in an exaggeratedly slow manner while pointing his index fingers.
 * Sting: He enters rings dressed all in black and with his face painted white and black, often with a baseball bat. He also howls while cupping his hands around his mouth.
 * CM Punk: Performs a gesture very similar to Sting's, except that he shouts, "IT'S CLOBBERIN' TIME!"
 * Stone Cold Steve Austin: His main shtick is crashing two opened beer cans together before gulping down both of them at once. His most common catchphrase is "Gimme a 'Hell yeah!' "
 * Triple H: Upon reaching the ring, he would take a sip from a water bottle and then spew the water straight up into the air. At special events, he was known to enter arenas wearing a metal crown and often a matching skull mask, in tribute to his "King of Kings" nickname.
 * Shawn Michaels: Known for a variety of distinctive gestures: throwing his head back and spreading his arms out as pyrotechnics explode in the background; squatting sideways on his haunches while flexing his biceps; dramatically springing to his feet after being knocked down; tumbling ostentatiously over ring turnbuckles when he is thrown into them; and stomping his foot repeatedly before kicking an opponent in the face.
 * The Undertaker: Believing himself to be undead, he walked toward the ring through bluish mist at a foreboding tread, wearing a black hat and trench coat. Another signature gimmick of his was crossing his eyes and sticking out his tongue as he "killed" (pinned) an opponent.
 * Kane: Supposedly pyrokinetic, he would angrily lift his hands above his head before bringing them down with a violent motion, apparently causing the turnbuckles to burst into flame.
 * John Cena: Among the gestures he performed were the "Five-Knuckle Shuffle" (bouncing off the ropes before falling to the mat with a palm strike to the face of a downed opponent) and the "You Can't See Me" (waving his hand in front of his face). His greatest catchphrase was "The champ is here!" Earlier in his career, he taunted his opponents with insulting rap lyrics.
 * Batista would crouch on the entrance ramp and "fire" imaginary machine guns with his fists as smoke bombs went off behind him, then stand up and thrust his palm down in tandem with a final explosion. During matches he was known to experience a rush of adrenaline that inspired him to grab the ring ropes and shake them furiously while "roaring."
 * Randy Orton stands atop the turnbuckle while posing narcissistically, one hand raised higher than the other.
 * Kurt Angle, a real-life Olympic gold medalist, wore his medal around his neck constantly. The words he lived by were "intensity," "integrity," and "intelligence." His catchphrase was "Oh, it's true. It's damn true."
 * "Mr. Anderson," born Ken Anderson: A loudmouth known for performing his own ring introduction, loudly intoning his last name twice.
 * Bobby Roode: At certain times in his career, he has worn a fancy bathrobe and not only bragged about being selfish, but claiming to lead the "Selfish Generation." Also has nicknamed himself "Glorious."
 * James Storm: A Southern redneck. Catchphrase: "Sorry about your damn luck."
 * Maxwell Jacob Friedman (MJF) is a New York City socialite with some Mob characteristics, famous for sporting an oversized diamond ring and a plaid scarf worn around his shoulders. Uses his fortune to hire goons and to bribe others into giving him what he wants. Claims to be "better than you, and you know it."

license: Creative Commons - Attribution Share-Alike - https://creativecommons.org/licenses/by-sa/4.0/

title: Shtick


text:
Antonello da Messina

Antonello da Messina (c. 1425–1430 – February 1479), properly Antonello di Giovanni di Antonio, but also called Antonello degli Antoni and Anglicized as Anthony of Messina, was an Italian painter from Messina, active during the Italian Early Renaissance.

His work shows strong influences from Early Netherlandish painting, although there is no documentary evidence that he ever travelled beyond Italy. Giorgio Vasari credited him with the introduction of oil painting into Italy, although this is now regarded as wrong. Unusually for a southern Italian artist of the Renaissance, his work proved influential on painters in northern Italy, especially in Venice.

Early life and training
Antonello was born at Messina around 1429–1431, to Garita (Margherita) and Giovanni de Antonio Mazonus, a sculptor who trained him early on. He and his family resided in the Sicofanti district of the city.

Antonello is thought to have apprenticed in Rome before going to Naples, where Netherlandish painting was then fashionable. According to a letter written in 1524 by the Neapolitan humanist Pietro Summonte, in about 1450 Antonello was a pupil of the painter Niccolò Colantonio in Naples. This account of his training is accepted by most art historians.

Early career
Antonello returned to Messina from Naples during the 1450s. In around 1455, he painted the so-called Sibiu Crucifixion, inspired by Flemish treatments of the subject, which is now in the Muzeul de Artă in Bucharest. A Crucifixion in the Royal Museum of Antwerp dates from the same period. These early works shows a marked Flemish influence, which is now understood to be inspired by his master Colantonio and from paintings by Rogier van der Weyden and Jan van Eyck that belonged to Colantonio's patron, Alfonso V of Aragon.

In his biography of the artist, Giorgio Vasari remarked that Antonello saw an oil painting by Van Eyck (the Lomellini Tryptych) belonging to King Alfonso V of Aragon at Naples and consequently introduced oil painting to Italy. Recent evidence indicates that an "Antonello di Sicilia" (di Sicilia meaning 'from Sicily') was in contact with Van Eyck's most accomplished follower, Petrus Christus, in Milan in early 1456. It appears likely that this was in fact Antonello da Messina as this would explain why he was one of the first Italians to master Eyckian oil painting, and why Petrus Christus was the first Netherlandish painter to learn Italian linear perspective. Antonello's paintings after that date show an observation of almost microscopic detail and of minute gradations of light on reflecting or light absorbent objects that is very close to the style of the Netherlandish masters, suggesting that Antonello was personally instructed by Christus. Also, the calmer expressions on human faces and calmness in the overall composition of Antonello's works appear to be owing to a Netherlandish influence. He is believed to have shared Van Eyck's techniques with Gentile and Giovanni Bellini.

Between the years of 1456 and 1457, Antonello proved himself to be a master painter in Messina. He also shared his home with Paolo di Ciacio, a student from Calabria. The artist's earliest documented commission, in 1457, was for a banner for the Confraternità di San Michele dei Gerbini in Reggio Calabria, where he set up a workshop for the production of such banners and devotional images. At this date, he was already married, and his son Jacobello had been born.

In 1460, his father is mentioned leasing a brigantine to bring back Antonello and his family from Amantea in Calabria. In that year, Antonello painted the so-called Salting Madonna, in which standard iconography and Flemish style are combined with a greater attention in the volumetric proportions of the figures, probably indicating a knowledge of works by Piero della Francesca. Also from around 1460 are two small panels depicting Abraham Served by the Angels and St. Jerome Penitent now in the Museo Nazionale della Magna Grecia in Reggio Calabria. In 1461 Antonello's younger brother Giordano entered his workshop, signing a three-year contract. In that year Antonello painted a Madonna with Child, now lost, for the Messinese nobleman Giovanni Mirulla.

Historians believe that Antonello painted his first portraits in the late 1460s. They follow a Netherlandish model, the subject being shown bust-length, against a dark background, full face or in three-quarter view, while most previous Italian painters had adopted the medal-style profile pose for individual portraits. John Pope-Hennessy described Antonello as "the first Italian painter for whom the individual portrait was an art form in its own right".

Although Antonello is mentioned in many documents between 1460 and 1465, establishing his presence in Messina in those years, a gap in the sources between 1465 and 1471 suggests that he may have spent these years on the mainland. In 1474, he painted the Annunciation, now in Syracuse, and the St. Jerome in His Study also dates from around this time.

Venice
Antonello went to Venice in 1475 and remained there until the fall of 1476. His works of this period begin to show a greater attention to the human figure, regarding both anatomy and expressivity, indicating the influence of Piero della Francesca and Giovanni Bellini. His most famous pictures from this period include the Condottiero (Louvre), the San Cassiano Altarpiece and the St. Sebastian. The San Cassiano Altarpiece was especially influential on Venetian painters, as it was one of the first of the large compositions in the sacra conversazione format which was perfected by Giovanni Bellini (Antonello's surviving work in Vienna is only a fragment of a much larger original). It is also likely that Antonello passed on both the techniques of using oil paints and the principles of calmness on subjects' faces and in the composition of paintings to Giovanni Bellini and other Venetian painters during that visit. While in Venice he was offered, but did not accept, the opportunity to become the court portrait painter to the Duke of Milan.

Return to Messina and death
Antonello had returned to Sicily by September 1476. Works from near the end of his life include the famous Virgin Annunciate, now in the Palazzo Abatellis in Palermo, and the San Gregorio Polyptych.

He died at Messina in 1479. His testament dates from February of that year, and he is documented as no longer alive two months later. Some of his last works remained unfinished, but were completed by his son Jacobello.

Style and legacy
Antonello's style is remarkable for its union of Italian simplicity with Flemish concern for detail. He exercised an enormous influence on Italian painting, not only by the introduction of the Flemish invention, but also by the transmission of Flemish tendencies. However, no school of painting formed after his death, with the exception of the Sicilian Marco Costanzo.

Selected works

 * Sibiu Crucifixion (1455) - Brukenthal National Museum, Sibiu
 * Abraham Served by the Angels - Museo della Magna Grecia, Reggio Calabria
 * Portrait of a Man (1460s) - Oil on wood, Civic Museums, Pavia
 * Ecce Homo (c. 1470) - Tempera and oil on panel, 42.5 x 30.5 cm, Metropolitan Museum of Art, New York City
 * Ecce Homo (1470) - Tempera and oil on panel, 40 x 33 cm, Galleria Nazionale di Palazzo Spinola, Genoa
 * St. Jerome Penitent - Various techniques on wood, 40.2 x 30.2 cm, Museo della Magna Grecia, Reggio Calabria
 * San Gregorio Polyptych (1473) - Tempera on panel, 194 x 202 cm, Regional Museum, Messina
 * Ecce Homo (c. 1473) - Tempera on panel, 19.5 x 14.3 cm, Private collection, New York City
 * Portrait of a Man (1474) - Oil on wood, Staatliche Museen, Berlin
 * Madonna with Child (Salting Madonna) - Oil on wood, 43.2 x 34.3 cm, National Gallery, London
 * Portrait of a Man (1474) - Oil on wood, 32 x 26 cm, Staatliche Museen, Berlin
 * Annunciation (1474) - Oil on panel, 180 x 180 cm, Bellomo Palace Regional Gallery, Syracuse
 * St. Jerome in His Study (c. 1474) - Oil on wood, 46 x 36,5 cm, National Gallery, London
 * Ecce Homo (1475) - Oil on panel, 48.5 x 38 cm, Collegio Alberoni, Piacenza
 * Portrait of a Man (Il Condottiere) (1475) - Oil on wood, 35 x 38 cm, Musée du Louvre, Paris
 * Crucifixion (1455) - Oil on panel 52.5 x 42.5 cm, Koninklijk Museum voor Schone Kunsten, Antwerp
 * Crucifixion (1475) - Wood, 42 x 25,5 cm, National Gallery, London
 * Portrait of a Man (c. 1475) - Oil on wood, Galleria Borghese, Rome
 * Portrait of a Man (c. 1475) - Oil on panel, 36 x 25 cm, National Gallery, London
 * Portrait of a Man (1475–1476) - Oil on panel, 28 x 21 cm, Museo Thyssen-Bornemisza, Madrid
 * San Cassiano Altarpiece (1475–76) - Oil on panel, Kunsthistorisches Museum, Vienna
 * The Dead Christ Supported by an Angel (1475–78) - Panel, 74 x 51 cm, Museo del Prado, Madrid
 * Christ at the Column (c. 1475–1479) - Oil on wood, 25,8 x 21 cm, Musée du Louvre, Paris
 * Virgin of the Annunciation -Oil on panel, Alte Pinakothek, Munich
 * Portrait of a Man (1476) - Oil on panel, Museo Civico d'Arte Antica, Turin
 * Virgin of the Annunciation (c. 1476) - Oil on wood, 45 x 34,5 cm, Museo Nazionale, Palermo
 * St. Sebastian (1477–1479) - Oil on canvas transferred from panel, 171 × 85 cm, Gemäldegalerie Alte Meister, Dresden
 * Portrait of a Young Man (c. 1478) - Panel, 20.4 x 14.5 cm, Staatliche Museen, Berlin
 * Portrait of an unknown man - Oil on panel, Museo Mandralisca, Cefalù
 * Madonna and Child - Oil and tempera on panel transferred from panel, National Gallery of Art, Washington, D.C.

title: Antonello da Messina


text:
Ketuvim

The  (, Modern: Ktuvim, Tiberian: Kăṯūḇīm "writings") is the third and final section of the Tanakh (Hebrew Bible), after ("instruction") and  ("prophets"). In English translations of the Hebrew Bible, this section is usually titled "Writings" or "Hagiographa".

In the Ketuvim, 1–2 Chronicles form one book as do Ezra and Nehemiah which form a single unit entitled Ezra–Nehemiah. (In citations by chapter and verse, however, the Hebrew equivalents of "Nehemiah", "I Chronicles" and "II Chronicles" are used, as the system of chapter division was imported from Christian usage.) Collectively, eleven books are included in the Ketuvim.

Sifrei Emet
In Masoretic manuscripts (and some printed editions), Psalms, Proverbs and Job are presented in a special two-column form emphasizing the parallel stichs in the verses, which are a function of their poetry. Collectively, these three books are known as Sifrei Emet ( sip̄rēi ʾemeṯ "documents of truth" – an acronym of the titles of the three books in Hebrew, א יוב, מ שלי, ת הלים yields אמ״ת em e t , "truth").

These three books are also the only ones in the Hebrew Bible with a special system of cantillation that is designed to emphasize parallel stichs within verses. However, the beginning and end of the book of Job are in the normal prose system.

Five Megillot
The five relatively short books of Song of Songs, Book of Ruth, the Book of Lamentations, Ecclesiastes and Book of Esther are collectively known as the Five Megillot (Hamesh Megillot/ Five Scrolls). These are the latest books collected and designated as "authoritative" in the Jewish canon. These scrolls are traditionally read over the course of the year in many Jewish communities. The list below presents them in the order they are read in the synagogue on holidays, beginning with the Song of Songs on Passover.

Other books
The remaining books in the Ketuvim are the Book of Daniel, Ezra–Nehemiah and the Books of Chronicles. These books share a number of distinguishing characteristics:
 * The Talmudic tradition ascribes late authorship to all of them.
 * Daniel and Ezra are the only books in the Hebrew Bible with significant portions in Biblical Aramaic.
 * These two also describe relatively late events (i.e., the Babylonian captivity and the subsequent restoration of Zion).

Order of the books
The following list presents the books of the Ketuvim in the order they appear in most printed editions. It also divides them into three subgroups based on the distinctiveness of Sifrei Emet and Hamesh Megillot.

The Sifrei Emet: The Five Megillot Other books
 * Tehillim (Psalms) תְהִלִּים
 * Mishlei (Book of Proverbs) מִשְלֵי
 * Iyyôbh (Book of Job) אִיּוֹב
 * Shīr Hashīrīm (Song of Songs) שִׁיר הַשִׁירִים (Passover)
 * Rūth (Book of Ruth) רוּת (Feast of Weeks)
 * Eikhah (Lamentations) איכה (Ninth of Av or the Day of Atonement) [also called Kinnot in Hebrew]
 * Qōheleth (Ecclesiastes) קהלת (Feast of Tabernacles)
 * Estēr (Book of Esther) אֶסְתֵר (Feast of Lots)
 * Dānî’ēl (Book of Daniel) דָּנִיֵּאל
 * ‘Ezrā (Book of Ezra–Book of Nehemiah) עזרא
 * Divrei ha-Yamim (Chronicles) דברי הימים

The Jewish textual tradition never finalized the order of the books in the Ketuvim. The Babylonian Talmud (Bava Batra 14b–15a) gives their order as Ruth, Psalms, Job, Proverbs, Ecclesiastes, Song of Songs, Lamentations, Daniel, Esther, Ezra, and Chronicles.

In Tiberian Masoretic codices, including the Aleppo Codex and the Leningrad Codex, and often in old Spanish manuscripts as well, the order is Chronicles, Psalms, Job, Proverbs, Ruth, Song of Songs, Ecclesiastes, Lamentations, Esther, Daniel, and Ezra.

Canonization
The Ketuvim is the last of the three portions of the Tanakh to have been accepted as Biblical canon. There is no scholarly consensus as to when the Hebrew Bible canon was fixed: some scholars argue that it was fixed by the Hasmonean dynasty, while others argue it was not fixed until the second century CE or even later.

While the Torah may have been considered canon by Israel as early as the 5th century BCE and the Former and Latter Prophets were canonized by the 2nd century BCE, Michael Coogan says that the Ketuvim was not a fixed canon until the 2nd century CE. According to T. Henshaw, as early as 132 BCE some references suggesting that the Ketuvim was starting to take shape, though it lacked a formal title. Jacob Neusner argues that the notion of a biblical canon was not prominent in 2nd-century Rabbinic Judaism or even later.

Against Apion, the writing of Josephus in 95 CE, treated the text of the Hebrew Bible as a closed canon to which "no one has ventured either to add, or to remove, or to alter a syllable"; Michael Barber, however, avers that Josephus' canon is "not identical to that of the modern Hebrew Bible". For a long time, following this date, the divine inspiration of Esther, the Song of Songs, and Kohelet (Ecclesiastes) was often under scrutiny.

In the 20th century, many scholars seemed to believe that the limits of the Ketuvim as canonized scripture were determined by the Council of Jamnia (c. 90 CE). But the theory of the Council of Jamnia is largely discredited today.

Liturgical use

There is no formal system of synagogal reading of Ketuvim equivalent to the Torah portion and haftarah. It is thought that there was once a cycle for reading the Psalms, parallel to the triennial cycle for Torah reading, as the number of psalms (150) is similar to the number of Torah portions in that cycle, and remnants of this tradition exist in Italy. All Jewish liturgies contain copious extracts from the Psalms, but these are normally sung to a regular recitative or rhythmic tune rather than read or chanted. Some communities also have a custom of reading Proverbs in the weeks following Pesach, and Job on the Ninth of Ab.

The five megillot are read on the festivals, as mentioned above, though Sephardim have no custom of public reading of Song of Songs on Passover or Ecclesiastes on Sukkot. There are traces of an early custom of reading a haftarah from Ketuvim on Shabbat afternoons, but this does not survive in any community. Some Reform communities that operate a triennial cycle choose haftarot on Shabbat morning from Ketuvim as well as Neviim.

Extraliturgical public reading
In some Near and Middle Eastern Jewish traditions, the whole of Ketuvim (as well as the rest of the Tanakh and the Mishnah) is read each year on a weekly rota, usually on Shabbat afternoons. These reading sessions are not considered to be synagogue services, and often took place in the synagogue courtyard.

Cantillation
Medieval sources speak of three cantillation melodies, for Torah, Nevi'im and Ketuvim respectively. Today the position is more complicated. Oriental Sephardic communities preserve cantillation systems for the three poetic books, namely Psalms, Proverbs and the main part of Job (usually a different melody for each of the three books). No such systems exist in the Ashkenazi or Spanish and Portuguese traditions. However, the Ashkenazic yeshiva known as Aderet Eliyahu, in the Old City of Jerusalem, uses an adaptation of the Syrian cantillation-melody for these books, and this is becoming more popular among other Ashkenazim as well.

In all communities there are special cantillation melodies for Lamentations and Esther, and in some communities for the Song of Songs. Otherwise, the melody for the book of Ruth is considered the "default" melody for books of the Ketuvim not otherwise provided for. The "prose" passages at the beginning and end of the book of Job, as read on Tisha B'Av, may be read either to the tune of Ruth or to one resembling that for the Song of Songs.

Targum to Ketuvim
Western targumim exist on Sifrei Emet, on the Five Megillot and on Chronicles, i.e. on all the books of Ketuvim besides Daniel and Ezra (which contain large portions in Aramaic anyway). There are several complementary targumim to Esther.

There is, however, no "official" eastern (Babylonian) targum to Ketuvim, equivalent to Targum Onkelos on the Torah and Targum Jonathan on Nevi'im. In fact, the Babylonian Talmud explicitly notes the lack of a Targum to Ketuvim, explaining that Jonathan ben Uzziel was divinely prevented from completing his translation of the Bible. A more prosaic explanation may consist in the lack of regular formal readings of Ketuvim in the synagogue (except the five Megillot), making it unnecessary to have an official system for line-by-line translation.

title: Ketuvim


text:
Talk:Left ventricle

do only humans have a left ventricle?

Ah, good point: All birds and mammals (I think) have all four chambers that I just created ... sigh. - DavidWBrooks 21:43 28 Jun 2003 (UTC)

Cheer up! The article looks great apart from that! I'll see if I have time to make a diagrma tomorrow, unless we already have one or you plan to make one yourself. -- Tarquin 22:19 28 Jun 2003 (UTC)

I have no diagram - so far, I'm purely a text guy. - DavidWBrooks 12:43 29 Jun 2003 (UTC)

error in pressure values of the left ventricle
there is an error in pressure values. The left ventricle receives blood from lungs during diastole at very low pressures, just few mmHg. Mentioned 80 mmHg are in aorta during diastole, not in the left ventricle.

how long has it been since we finnaly new about all the bicuspid and tricupid valves? when did humans discover this in the human anatomy? —Preceding unsigned comment added by 172.188.254.194 (talk) 17:08, 1 April 2008 (UTC) these are very important

title: Talk:Left ventricle


text:
Talk:Ketuvim

hello visitors. I have just finshed the first edition of this article and its not quite as comprehensive as it could be, so feel free to improve on it. If you want to make changes to spelling of transliterations etc. please discuss them first.

-- Avi

The following sentence from the 1st paragraph makes it seem that the Ruach HaKodesh ("Holy Spirit"), itself is less of an inspiration than some other unnamed influence:

The Ketuvim are believed to have been written under the Ruach HaKodesh, a level less than that of prophecy[1].

I suggest rephrasing such as: "The Ketuvim are believed to have been written under the Ruach HaKodesh, but with one level less authority than that of prophecy" -I'll go ahead and make that change now.

Canonization
I added a section regarding the canonization of the Ketuvim as a part of the Hebrew Bible and the Christian Old Testament. There is still a lot that could be done with this section.

I would like to get back to this page and add a section regarding the criteria to which a text was held in order to be counted among the Biblical canon of the Ketuvim.

Any other assistance in this arena would be excellent!

Nws106 (talk) 05:25, 28 September 2010 (UTC)

K'thubhim vs. Kəṯûḇîm
I've changed the article to give the latter instead of the former as the "actual Biblical Hebrew", in accordance with the spelling "כְּתוּבִים" and the transliteration scheme employed by Thomas O. Lambdin in "Introduction to Biblical Hebrew" and which seems to agree with where I have seen Biblical Hebrew transcribed elsewhere. However, I've put a note here, partly to defend my modification, and partly cause I'm not 100% confident in it... for a couple reasons:
 * 1) I have seen the apostrophe used in some places instead of the schwa, e.g. "l'chaim", so I'm not immediately ready to call its use here "incorrect". I think that might only be a convention of Modern Hebrew, but I'm not sure and haven't asked anyone, so maybe I'm wrong.
 * 2) I'm unaware of whether the spelling "K'thubhim" has any conventionalized usage anywhere. Additionally, "K'thubhim" (as well as "K'thuvim") both get way more Google hits than "Kəṯûḇîm". However, "Ketuvim" gets more than all three of them combined. I think the version as I have edited it makes it clear that "Ketuvim" is the commonly used, grandfathered-in, mostly-phonetic spelling while "Kəṯûḇîm" is the scholarly, historical transliteration of the original Hebrew. "K'thubhim" doesn't seem to fit either role that well.

Also, the spelling "K'thubhim" wasn't accompanied by any citation that supported it. Cevlakohn (talk) 05:50, 22 August 2011 (UTC)

 * "Ketuvim"
 * Këtu vim në gjuhën shqipe ka kuptim
 * Psh këtu vim ne e përdorim kur kemi lëvizur nga një vend dhe përdorim shprehjen këtu do vim,këtu erdhëm,këtu do vim etj... 188.172.108.48 (talk) 05:55, 18 July 2024 (UTC)

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title: Talk:Ketuvim


text:
Marcus Duronius

Marcus Duronius was a tribune of the plebs, most likely in 97 BC. He abrogated a sumptuary law, one of the Leges Liciniae. In retaliation, the Roman censors Lucius Valerius Flaccus and Marcus Antonius expelled him from the Senate. Duronius then brought an accusation of ambitus against Antonius.

title: Marcus Duronius