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Nuclear Abolition: Q&A with Dr. David Krieger
TRANSCEND MEMBERS, 23 Sep 2019
David Krieger | Nuclear Age Peace Foundation – TRANSCEND Media Service
A special dialogue held at Nuclear Age Peace Foundation during our overseas fieldwork on 1 Feb 2019. This session was held between 13 Kansai Soka High School students and Dr. David Krieger, President of the Nuclear Age Peace Foundation.
Dr. Krieger: In the discussion, you said that the reason for nuclear deterrence is that it protects a country against assault and possible assault. However, if you really think about it, deterrence cannot protect, not in the sense of physical protection, and that is the confusion about deterrence in most people's minds. They think that nuclear deterrence actually protects, but deterrence is only a psychological concept, not a physical barrier. I think of deterrence as something like the Maginot Line in World War II. France built a strong wall and thought that it would protect them from Germans invading again. However, the Germans just went around the wall, attacked and occupied France. I think deterrence is misunderstood, and I don't really think you can have a compromise between the people who support nuclear deterrence and those who do not.
Emi Kuroda: Why do you think nuclear deterrence supporters cannot compromise with people who don't support deterrence?
Dr. Krieger: I think deterrence is a false premise. I don't think deterrence can provide any protection. You mentioned in your slideshow that deterrence cannot provide 100% protection. I would say that deterrence cannot provide 50% protection or even 1% protection. Over time, deterrence will fail. If you do a statistical study and the level of chance where it can fail is 1%, you will have a failure over time. That is true. So I think you are right to come down on the side of abolition. I think you are right to look to ICAN, which we have supported from the beginning, as a partner organization. I think you are right to support the new treaty, which is a departure from deterrence, as it implicitly recognizes that deterrence cannot work over time. I think people who support deterrence actually have another agenda, and the other agenda is to give themselves an advantage over other countries and threaten them with the offensive use of nuclear weapons. So I would say that your presentation is very good, but I would be careful about thinking of nuclear deterrence as a way to add to the disarmament of nuclear weapons. Many countries believe in deterrence, but I believe it's a magical fallacy.
Rei Hagihara: I would like to ask a question. We think that we should find a common ground between the two sides (nuclear deterrence supporters & nuclear abolition supporters). Do you think we should find a common ground? If you do, what do you think is the common ground?
Dr. Krieger: I'm very skeptical that you can find a common ground, because I think deterrence is based on a false assumption, which is that nuclear weapons can protect you. But the reality is they can't protect you. I think people who have accepted the premise that deterrence can protect you believe in that. I don't see them moving away from that to a common ground. I don't know what the common ground would be. I think having a common ground is a nice idea, but I don't see it working in the case of people who support nuclear deterrence.
The second president of Soka Gakkai, Josei Toda, said nuclear weapons are an absolute evil. So how do you compromise with an absolute evil? Well, actually I have one idea of compromise. Sixty-six million years ago, a meteor hit the earth and caused mass extinction of most complex life at the time. It wiped out the dinosaurs, for example. It actually made it possible for our human ancestors to survive because they were so small. But possibly, if we eliminate the nuclear weapons down to one, two or three, and they are kept in international storage just in case the earth is threatened by a meteor, that is a kind of compromise. Although not really a compromise for deterrence, it is a compromise for those saying you might go to a very low number—on the way to zero—and decide that a meteor is a sufficient threat to maintain a couple of nuclear weapons under international control. But tell me how you think compromise is possible.
Emi Kuroda: We think that a possible common ground is human rights because nuclear abolition supporters think that human rights of all human beings should be protected, but nuclear deterrence supporters think that human rights of their own country is a priority. But we don't think we can make nuclear deterrence supporters compromise by using human rights.
Dr. Krieger: Well, human rights include the right to life. That's in the Universal Declaration of Human Rights. I think nuclear weapons pose a threat not only to individual lives but also a threat of mass extinction to humans and other complex life. So I agree with you that human rights is an important element—because of the right to life. I think the people who advocate for nuclear deterrence ironically think that protecting their country is more important than human lives and human rights.
Let me say one more thing. There is such a widespread belief in nuclear deterrence that a lot needs to be done to challenge the logic of nuclear deterrence. That is a very important element. We had a symposium here on nuclear deterrence and created the Santa Barbara Declaration, which you might want to take a look at when thinking about nuclear deterrence. We also have a 4-minute video called "The Myth of Nuclear Deterrence."
Emi Kuroda: We gathered the opinions of nuclear deterrence supporters, and we originally thought that those opinions would help us understand the reality. But we struggled with how to deal with those opinions. What do you think the role of the opinions of nuclear deterrence supporters is? How do we use those opinions to promote nuclear abolition?
Dr. Krieger: I think you need to educate people, starting with young people—and put a lot of emphasis on educating young people—because nuclear deterrence is a very common myth that nuclear weapons can protect a country. I just don't think that is reality. I think you have to counter those opinions, and that's why in the presentation we gave, we talked about malice, madness, mistake, miscalculation, and manipulation (hacking). So I think a dangerous aspect of nuclear weapons, going forward, is that skilled computer hackers will break into nuclear weapon systems. What if the systems are not that sophisticated? You only need to break into the weakest country's system. What if a hacker could, for example, break into North Korea's nuclear weapons? Probably North Korea doesn't have the warheads connected to missiles right now, but it will eventually. What about Pakistan? What if a skilled hacker could break in and trigger the use of nuclear weapons by Pakistan against India? And India, instead of trying to figure it out, attacks Pakistan, and they will go back and forth. Experts in climatology predict that if 100 nuclear weapons are used, with 50 on each side between Pakistan and India, it could result in a cut in food supplies, leading to 2 billion deaths globally. So, how good is deterrence against a hacker? It's not at all. How good is deterrence against madness? What if you have a leader who is crazy, mad? We may have one now, in the US. What if there is a mistake? There have been many mistakes in interpreting nuclear launches. Russians, thinking nuclear weapons were launched against them, found out that actually it was just geese reflected against the cloud cover. Nuclear deterrence has no value against mistakes, miscalculation, madness or hacking. Maybe deterrence could dissuade a country from using nuclear weapons out of malice, but that is only a possibility. There is no assurance that it would work.
Emi Kuroda: Yesterday, during our presentation in Los Angeles, we said that deterrence doesn't work because terrorists can use nuclear weapons. But yesterday we heard that it is really difficult for terrorists to have nuclear weapons. Is it true that it is almost impossible for terrorists to get nuclear weapons?
Dr. Krieger: A Christian nun and two anti-nuclear activists went to a nuclear weapons site in Oakridge, Tennessee. I think it was called the Y-12 National Security Complex. They cut through the outer fence, they hiked a quarter mile to the place where nuclear weapons were kept. They painted on the bunkers where the nuclear weapons were stored. The nun was 82 years old. So can terrorists get nuclear weapons? I don't know, but I wouldn't rule it out. And that's in the United States, which supposedly has a good system of protection. What if there is a coup d'état in Turkey, where the US keeps 50 nuclear weapons? What if there's a coup d'état in Pakistan?
Over time, I think the chances are more likely that terrorists can get nuclear weapons; the probability is not zero. We don't know what the probability is, but over time, terrorists are a worry. That's why it's so important to be all in for abolition. That's why it's important to understand that abolition is the answer. It has got to be a negotiated abolition, a phased abolition and a verified abolition. It will take time, but the starting point is negotiations. Maybe that is a common ground—starting negotiations. People who don't believe in deterrence could invite people who do believe in deterrence, to try to educate them on the importance of moving from deterrence to abolition. Terrorism could take the form of hacking.
Hiromi Hashide: I'd like to ask how you developed your sense of poetry. I have read the dialogue between yourself and Dr. Ikeda, and I was able to understand the importance of a sense of poetry. I think those who understand the importance of poetry can also understand the dignity of life, and I'd like more people to have a sense of poetry, including myself.
Dr. Krieger: Thank you. That's a really good question. The more I work in the area of nuclear weapons abolition and peace and war, the more I think that the most important things in life are truth, beauty, love, family, and nature; those are all subjects of poetry. Maybe poets pay more attention to those concepts than ordinary people. I think when you study nuclear weapons and work for their abolition, it can be a very dark place, thinking about the devastation that is possible. So, for myself, I tend to rely on reason and logic, and I realized that reason and logic may not be enough to change people's minds, so I began writing poetry as a way of reaching out more directly to a person's heart. We have the faculties of our mind and faculties of our heart. I think that a mind, no matter how reasonable and logical one is, cannot really tackle fully issues like the danger of nuclear weapons, the danger of climate change, or the danger of destroying the environment. So, for me, poetry is a means of sharing my heart, which I hope has more effectiveness than my logic. Does that answer your question? Do you have another question?
Hiromi Hashide: Yes. How did you develop your poetry skills?
Dr. Krieger: By writing poetry. And also by reading poetry.
Kaz: Do you have a favorite poet?
Dr. Krieger: I have some favorite poets, whom I mentioned at the time when I was writing a book with Dr. Ikeda. I like Pablo Neruda. He was an Ambassador of Chile, and Chile has a nice tradition of inviting poets to be ambassadors. I like Denise Levertov, and I like Lawrence Ferlinghetti, who turned 100 this year. Actually, there are a number of poets I like, but I especially like poets who pay attention to peace, and I try, in my poetry, to pay attention to peace. My advice to you, if you want to be a poet, is to sit down and write poems, and read a wide variety of poets and find your style because there are so many different styles of poetry; so experiment with styles that you are interested in.
Kaz Iguchi: Any other questions?
Ayumi Otsuji: Thank you for this wonderful opportunity. When I imagine a "peaceful world," I imagine that everyone is smiling. If you imagine a peaceful world that you want to achieve, what would you imagine?
Dr. Krieger: I would not imagine everybody smiling. I would imagine that, in a peaceful world, you would still have conflicts, but the conflicts would be resolved peacefully, non-violently. Everyone would accept the idea that life is sacred, and nobody would try to injure or destroy. But it wouldn't be a world where people didn't have disagreements. Having disagreements, I think, is a valuable part of life. I mean, you learn from disagreements, you grow from disagreements, but you don't try to settle disagreements with your fists or with guns. You start with respect for other human beings and you then have a sense of belonging. I think, in a peaceful world, your sense of belonging to the world and to humanity has to be greater than your sense of belonging to one nation or one group. You can still belong to different groups; you can be Japanese, I can be American, but we should not fight and destroy each other because our common humanity is greater than our individual sense of identity. That's what I think.
Ayumi Otsuji: Thank you so much.
Dr. Krieger: But smiles are good. Everybody should smile more. You can experiment, walking down the street, just smile. And I think other people who see you will smile too.
Yuichi Matsuna: Thank you very much. I read Choose Hope, and I was impressed with the idea that "recovery of imagination" is important for nuclear abolition. Why should people have an imagination for the abolition of nuclear weapons?
Dr. Krieger: Why should people use their imaginations for the abolition of nuclear weapons? Well, there is a lot of ignorance and apathy around nuclear weapons. In your school, perhaps, if you say to someone that we should abolish nuclear weapons, maybe they will say "well, that's a good idea, but I haven't thought about it," or "I'm too busy," or something like that—expressing different kinds of reasons not to be involved. I think imagination is limitless, knowledge has boundaries. We don't know certain very important things: we don't know where we come from, or why we were born; we don't know where we go when we die; we don't know what is in the rest of the universe, or even in our own galaxy. But imagination can take you anywhere, and it's an opportunity to try to figure out some puzzles. Einstein was a big advocate of imagination, and I think he was correct in thinking that "imagination is a great gift." So how do you apply imagination to nuclear weapons' abolition? Think outside the bomb, come up with new ideas. Peace Literacy is a new movement. I encourage you to look into the Peace Literacy idea. As Sarah said, Paul Chappell, who went to the US military academy, and was trained as an officer in a military, is now trying to apply the same principles of waging war to waging peace. I think that's a great application of imagination, to take the principles of waging war and turn them to waging peace. Do you have anything to add, Sarah?
Sarah: Thank you for asking. On Paul, I think something that is very significant about what he argues is that we have spent so much time and effort thinking about how to wage war; so as Dr. Krieger was saying, Why haven't we spent as much time and effort—or have as many people—thinking about how to build peace instead? And so I think that's a part of where Paul's mind-set came from. Instead of spending all the time and effort to figure out how to better wage war, let's figure out how to better wage peace. That's using imagination.
Ryoma Masutani: Thank you very much. I'd like to ask about nuclear abolition. I think, even if all nuclear weapons are abolished, the knowledge or technique of creating nuclear weapons will still remain. So what is true nuclear abolition? And how can we achieve this?
Dr. Krieger: I think you are right. We can't get rid of the knowledge of how to make nuclear weapons, and probably the materials too. But I think abolition is when we have no nuclear weapons. I think we have to understand that even with no nuclear weapons, they could come back because people understand now the physics of making nuclear weapons. And I think the way to deal with that is through verification. So, first of all, abolition will be negotiated; secondly, it would be done in phases, increments, and with each increment, you will build support, and build confidence that the system is working. Verifications could be spot inspections. So if the United States says that it was down to 500 nuclear weapons, and Russia says "we want to verify that," the United States, as part of the agreement, will have to let Russian inspectors go wherever they want to, and whenever they want, to check whether the United States is doing what it claims, and vice versa. I think negotiations, verification, inspections, phased reductions to build confidence—all those things will help in going to zero nuclear weapons, trusting that it will lead to zero nuclear weapons. You have to trust. Ronald Reagan, one of our most conservative US presidents, said "trust, but verify." Verification is extremely important. Okay?
Ryoma Masutani: Yes.
Dr. Krieger: Do you have another question?
Takuma Furukawa: Thank you. Many countries have nuclear weapons, and one of them is North Korea. The United Nations decided to give North Korea an economic penalty, but I think the situation in North Korea will become worse. The people in North Korea will suffer more because of it. Could you please share your opinions about how developed countries should deal with North Korea?
Dr. Krieger: There have been times when there have been agreements with North Korea to end sanctions. I think about 20 or 25 years ago, we were close to an agreement with North Korea to give them nuclear power plants, and give them something in exchange for them doing away with developing nuclear weapons. But the US never followed through, and it has tried to deal with North Korea with sanctions; and now maybe it is too late to change North Korea's nuclear power with sanctions. Really, I'm not sure if there are any more reasons for North Korea to disarm its nuclear arsenal. I mean, if any country that has nuclear weapons can argue that deterrence works, I would say the country would be North Korea. But I don't believe in deterrence, as I said, so I'm not supporting that. But I do think we should use our imaginations and try to get all countries to abolish nuclear weapons, not just North Korea, which is in a very precarious situation from which to go for abolition. I don't know what the practical argument is for North Korea to abolish its nuclear weapons, while the United States, Russia and other countries that have them shouldn't also do so. If they want North Korea to abolish its nuclear weapons, the rest of the world has to be ready to abolish their nuclear weapons. That's my belief. Does it make sense to you?
Takuma Furukawa: Yes, thank you.
Takuto Yoshii: Thank you for giving us this opportunity to talk to you. My name is Takuto Yoshii. My question is, as you said, each country will try to protect itself. As I have read in Choose Hope, each country has to be altruistic to realize a sustainable and peaceful world, and I learned that people need to change their hearts, and have thoughtfulness towards others. I think it is very difficult for people to think that way. So how do you think people can learn how to think altruistically? What kind of education do you think is necessary?
Dr. Krieger: That is a great question. Altruism is very important. I think we have to learn it. This may sound silly, but I think we have to learn to love each other. I think the way we practice that is by smiling, by acts of kindness, by empathy, where you feel for other people's difficult situations. I think that question requires a lot of imagination. How do you put altruism, kindness, and empathy into the learning that you do in school, for example? Most religions make a claim to teach those things, but I'm not sure if they really do. I'm not sure if schools are really prepared to teach altruism, kindness, and empathy. One way they could do so would be to teach about the lives of great peace leaders, such as the life of Gandhi, the life of Martin Luther King, Junior, the life of Nelson Mandela, and many more. There are so many lessons to be learned in those lives which are dedicated to peace and nonviolence. We give an award every year for distinguished peace leadership, and we have given an award for world citizenship from time to time. I am happy to say we gave the world citizenship award to Dr. Ikeda one year. He is one of our distinguished awardees. I think SGI does something similar, where it gives awards. So, that's another way you can learn about altruism and empathy—through people who have lived distinguished lives, in which they have given and sacrificed in the pursuit of peace and world citizenship. From there, I think you can use your imaginations to think of other ways to instill altruism.
One other way that I can think of right now, and it has already been done, but it can be done even more, is to videotape the thoughts of such people, including the Hibakusha. So many Hibakusha have impressed me by the suffering that they've gone through, and the kindness in the lives that they have led. One of the poems that I wrote is called "The Deep Bow of a Hibakusha," and it is about a particular Hibakusha whose name is Miyoko Matsubara. She came here to Santa Barbara to study English so that she could share her experience with young people in the United States. I think that's very altruistic. Most of the Hibakusha that I have met don't have any feelings of hostility, or revenge; they are all kind. And what they want to say is, "don't let what happened to me happen to anybody else." So that's another thought: meeting with and interviewing Hibakusha. But you can interview many other people, and you might choose to interview somebody who you think is very altruistic, like a parent, an uncle or aunt, or a grandparent, someone not widely known to the world. Those are my thoughts on altruism. It is a fertile area to continue to develop and think about and practice. Small acts of kindness take you so far. There's a movie called "Pay it Forward," about doing something kind for somebody, and not expecting to get paid back, but rather expecting the recipient of the kindness to do something kind for another person. It's a good movie. I recommend it.
Atsushi Saitou: I think everyone understands the danger of nuclear weapons, but maybe that is not enough to make people really understand that we don't need nuclear weapons. So rather than just saying nuclear weapons are bad, because everybody understands that, is there another more powerful way to reach out to people to stop nuclear weapons?
Dr. Krieger: I don't agree with the assumption that people know that nuclear weapons are bad. It's not enough to spread the knowledge of the dangers. I think it is only when enough people understand and take seriously the dangers of nuclear weapons, will it make a difference. Nuclear weapons have got to go. Right now, we are educating people about these dangers, but they have to be taken seriously enough to become a political project. Here in the United States, virtually no one who is running for the presidency talks about doing something about nuclear weapons. Most are believers in nuclear deterrence. Nuclear weapons are a danger, and understanding that they are a danger is a starting point, but it's not enough. We have to keep using our imaginations and building the number of people who think that nuclear weapons are a serious danger. We have to do that to the point that it makes a difference politically. Right now, people's priority here and in most other places—probably in Japan as well—puts greater emphasis on the economy, the environment, social issues, and education. Those are all important, and I don't disagree that they are important. But nuclear weapons could end civilization in an afternoon, and I think that's something that should make an impact in people's minds. In a certain way, working for nuclear abolition is an act of faith, because we don't see the results immediately, so we have to believe that enough people will catch on before nuclear weapons are used—not after—to make a difference. A lot of movies are about post-apocalyptic societies, and I think it would be a great failure of imagination if we end up in a post-apocalyptic world because we can't use our imaginations to see that such a world is a real possibility if we don't act. So it is as an act of faith and an act of hope that we do this work, and we do this work on behalf of not only schools and organizations, but on behalf of all humanity. Humanity has been at risk from nuclear weapons for almost 75 years. That is not a very long time. We haven't had a nuclear war for almost 74 years, which is good, but it shouldn't give us confidence that a nuclear war, nuclear accident, or nuclear terrorism couldn't begin anytime.
Emi Kuroda: How can we encourage people around us to have confidence that they have the power to achieve nuclear abolition?
Dr. Krieger: I think we have to recognize the power that each of us has. Any person on this planet has power. I would like to talk about the power of one. One person can make quite a difference in the world, and we've seen that in the lives of many people, including Dr. Daisaku Ikeda. I think, though, with nuclear weapons, it's not going to be the power of one, it's going to be the power of many, or many ones. When we build a movement that's strong enough, that movement can take many shapes: it can take the form of petitioning, it can take the form of educating, or it can take the form of protesting. It can take a lot of different shapes. But I don't think we can convince people that they have that power. We can only say that unless you join us, and add your power, it is unlikely that we will ever build a movement large enough and strong enough to abolish nuclear weapons. By not participating, by not joining such a movement, you are actually creating a self-fulfilling prophecy, because we need a big movement, and we need people to care. Abolishing nuclear weapons may sound negative because it's getting rid of something, but it's really very positive because we are getting rid of something that is evil, something that could destroy us. So I would tell people that nuclear weapons are the ultimate human rights issue. Nuclear weapons are the ultimate environmental issue. Nuclear weapons are the ultimate altruism issue. And we need you. If each of you would join us and use your imagination, we will be one person closer to a nuclear weapons free world. That's what I think.
Sarah: Do you know about this old Japanese saying that goes, "if all of us cross the street in front of the red light, it isn't scary"? Are you familiar with this saying?
Dr. Krieger: I'm not familiar with that saying. I thought you were going to say the Japanese proverb, "if you fall down seven times get up eight." I think that is good advice. "Seven times down, eight times up." It's not going to be easy to abolish nuclear weapons. Nothing important is going to be done just like that. You are going to be challenged if you work for any great goal.
Sometimes I think of the medieval people who built cathedrals in Europe. When you build a cathedral, it is usually not done in one lifetime. It has to go through many generations. I don't know if we have that capacity to last through generations on nuclear weapons, but I do think that each generation should do its part, and I know the kind of education all of you have had makes you prime prospects for doing something really worthwhile in the world. And I hope that you will make working towards the abolition of nuclear weapons one of those goals that you seek to achieve, no matter how difficult. Join with others. Join with the Nuclear Age Peace Foundation. Join with ICAN. SGI is already doing a lot. So, I think you have great opportunities. Don't be disheartened. Choose hope, and get up that last time, even if you get knocked down. Get up and come up, struggling altruistically, non-violently.
Students: Thank you.
Dr. Krieger: All right, you had great questions. I'm very impressed.
Kaz Iguchi: Lastly, would you like to give a message to those students in Japan, as well as Dr. Ikeda, that we can bring back home?
Dr. Krieger: In my message for the students, I would say this: Your fellow students have represented Kansai Soka High School very well. I'm impressed by the students who came here. I hope that they will share with you the questions and answers, and what we talked about in Santa Barbara. I hope all of you will do something great in your lives. Please use your imaginations to set your goals high and then do what's in your power to create a better world and never give up, never give up.
And to Dr. Daisaku Ikeda, I would say: You are an amazing leader, and I'm so proud to know you and to be your friend. I know you have just celebrated your 91st birthday, and yet your ideals are as high and strong as ever. I know your message of peace focuses again on young people, and I share very much your desire to see young people pick up the baton from all of us older people and finish the job that we have worked so hard on. I admire you greatly for your courage, your compassion, and your commitment to creating a world free of nuclear weapons and at peace.
David Krieger, Ph.D. is founder and president of the Nuclear Age Peace Foundation, and a member of the TRANSCEND Network for Peace Development Environment. Amongst several of his wide-spanning leadership endeavors in global peacebuilding, he is a founder and a member of the Global Council of Abolition 2000, councilor on the World Future Council, and is the chair of the Executive Committee of the International Network of Engineers and Scientists for Global Responsibility. He has a BA in Psychology and holds MA and Ph.D. degrees in Political Science from the University of Hawaii as well as a J.D. from the Santa Barbara College of Law; he served for 20 years as a judge pro tem for the Santa Barbara Municipal and Superior Courts. Dr. Krieger is the author of many books and studies of peace in the Nuclear Age. He has written or edited more than 20 books and hundreds of articles and book chapters. He is a recipient of several awards and honors, including the OMNI Center for Peace, Justice and Ecology Peace Writing Award for Poetry (2010). He has a new collection of poems entitled Wake Up. For more visit the Nuclear Age Peace Foundation website: www.wagingpeace.org.
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There is much to consider and think about before beginning a truck-driving career. The following is a general list to help you sort through the variables of the trucking lifestyle.
- You'll have to pay for your own food, laundry, shower, snacks, entertainment, etc.
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The winter's first snow started arriving in Southern Norway during the weekend, and a lot more was expected through Tuesday. Meteorologists warned motorists of slippery roads that already were sending some vehicles spinning out of control.
A bus with 30 passengers ran off the road and into a ditch on Myravegen in Arendal on Monday. Other cars faced difficult driving conditions throughout the day, with snow falling heavily in Kristiansand and Vennesla as well.
As the snowstorm moved north, residents in and around Oslo were told to brace for as many as 20 centimeters of snow during the night and heading into Tuesday. Winter tires aren't required until November 1, so the snow caught many by surprise.
Local workshops around the country were deluged with requests to change tires on Monday, with most facing long waiting time. Tuesday's snow was expected to turn into rain later in the day, which could make driving even more difficult.


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Marvel leak may reveal how 1 Mutant solves a huge MCU/X-Men plothole
Will Marvel's first X-Men movie star Moira... or Moira X?
Jake Kleinman
How will the X-Men change the MCU? The Marvel Cinematic Universe has faced existential threats before, but the introduction of Mutants could rewrite the genetic structure of the world's favorite movie franchise. Recent leaks suggest the first Mutants could show up in the MCU before the end of 2021, and a closer look at one of these rumors may reveal a radical way Marvel can transform its cinematic universe while also answering our biggest question about the mutant superhero team.
Warning! Possible spoilers for the MCU and X-Men ahead.
According to a leak from Twitter user @mainmiddleman (who previously spoiled a major plot point from WandaVision), Marvel's first X-Men movie (allegedly titled Mutants) will focus on Professor Charles Xavier and Doctor Moira MacTaggert. This makes sense since Professor X created the X-Men and Moira has also been heavily involved in that story. The two characters are also often romantically involved, which could be a major plot point of this rumored MCU film.
However, recent developments in the X-Men comic books could reveal that Moira's involvement in Mutants is even more important than we think...
Moira X and the X-Men
Moira's many lives with the X-Men. Marvel Comics
In 2019, the X-Men comic events House of X and Powers of X told an overlapping story that dramatically changed the character of Moira MacTaggert. It turns out that Moira is actually a mutant (Moira X) with a very unique ability: the power of reincarnation. Every time she dies, she's reborn in the same body at the same time of her original birth — but with all her previous memories intact.
Moira X is experiencing her 10th (and potentially final) life. In each lifetime, she tries to change the future, but it always turns out poorly for mutant-kind. And throughout each attempt, she's become more radicalized, gradually shifting from trying to work with Xavier to training herself as an assassin to siding with Magneto instead.
It's a fascinating take on a familiar X-Men character, told primarily in House of X #2: "The Uncanny Life of Moira X," but could it actually translate onto the big screen in a Marvel movie? And if so, how would that help explain the existence of Mutants in the MCU?
How Moira X fixes the MCU's biggest problem
Moira X meets Professor X. Marvel Comics
The trickiest part of introducing the X-Men to the Marvel Cinematic Universe is that you have to answer one simple question: Where have Mutants been this whole time? Unless Marvel plans to have the first X-genes activate now (or reveal that a small handful of famous characters have been in hiding), it doesn't exactly make sense if all of a sudden the MCU is full of Mutants.
But what if one particular Mutant has been using her extraordinary powers to keep the entire thing a secret? In House of X, we learn that Moira X used her abilities to repeatedly nudge Magneto towards building a safe haven for Mutants. She even gave Professor X the idea to start the X-Men by showing him a memory from one of her past lives of him creating the X-Men (pretty trippy, right?).
So maybe (just maybe) Moira has also been using those same abilities to help cover up the X-Men in the MCU. She could have already lived out multiple lifetimes while subtly manipulating the Avengers and the rest of the world into keeping Mutants a secret.
It's a wild idea, but with the MCU already messing around with far-out concepts like time travel and the multiverse, it doesn't seem that out of place. Plus, considering that X-Men fans have already seen Moira onscreen before, it would be pretty cool if Marvel decided to step things up by introducing us to Moira X instead.
Corey Stoll could have the chops to make a live-action M.O.D.O.K. work
By Mónica Marie Zorrilla
The MCU could bring back a hero from its most underrated TV show
By Dais Johnston
Ant-Man 3 interview proves Marvel is taking the wrong lesson from Jodorowsky's Dune

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text:
LAPD officer arrested for allegedly committing lewd acts on 2 girls
CASTAIC, Calif.
Sheriff's detectives say that on Saturday morning, Officer Miguel Schiappapietra, 28, allegedly lured two girls under 10 years old to his home on the 28000 block of Branch Road in Castaic. The officer is accused of committing lewd acts with the girls.
The six-year veteran of the force on Tuesday entered a not guilty plea on two counts of lewd acts on a child under the age of 14. His bail was set at $200,000.
"We asked the judge to reduce the bail and, understandably, base on the charges, the judge has to presume they are true. Our office, in fact, does not believe the validity in the allegations in this case, and we will be making a subsequent motion to reduce the bail so we can get our client home, out of custody, which is where he belongs," said defense attorney David Diamond.
Schiappapietra was assigned to the Foothill Division. Neighbors in his community spoke to Eyewitness News. One is a former Los Angeles police officer who wanted his identity shielded.
"I had a pride when I put on the badge, when I put on the uniform. I imagine this individual did too, to a point, and he just let his demons get the best of him," the former officer said. "I feel sorry for his wife just being shrouded in secrecy of this alleged behavior."
Some residents say the officer and his family moved into the community a few months ago. They say several law enforcement families live in the neighborhood, and they are all shocked.
"He's got kids of his own, and he is a police officer, you feel like you should be protected in a neighborhood with a police officer," said Jennifer Frank of Castaic.
Los Angeles County Sheriff's Special Victims Unit is investigating the case. Anyone with information about this incident is asked to contact the Los Angeles County Sheriff's Department's Special Victims Bureau at (877) 710-5273.


Share of major product categories (left) and regions (right) in the global man-made phosphorus load to fresh water from 2002 to 2010.
Water pollution level per river basin related to human-induced phosphorus loads from the agricultural, industrial and domestic sectors from 2002-2010. Basins with a WPL above one received more phosphorus than they could assimilate.


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In the Design and Developer Guides, you will find information on kuryr kubernetes integration plans and design decisions. There are sections that contain specific integration components description and detailed designs. Finally, the developer guide includes information about kuryr kubernetes testing infrastructure.


text:
The Transfer Pricing Law Review - Edition 3
Catherine O'Meara
I OVERVIEW
Formal transfer pricing legislation was introduced in Ireland for the first time through the Finance Act 2010 for accounting periods commencing on or after 1 January 2011 in respect of transactions, the terms of which were agreed on or after 1 July 2010. Ireland's transfer pricing legislation is set out in Part 35A of the Taxes Consolidation Act 1997 (TCA).2 The Irish transfer pricing legislation is currently under review as part of a modernisation project and it is expected that new legislation will be introduced in late 2019, to take effect from 1 January 2020.
Before the introduction of transfer pricing legislation in 2010, there were limited circumstances in which an 'arm's-length' or 'market-value' rule applied in Irish tax legislation. However, there was certainly some familiarity with the concept. For example, capital gains tax rules always required the imposition of market value on certain transactions undertaken otherwise by means of a bargain and arm's length;3 interest in excess of a 'reasonable commercial return' may be reclassified as a distribution;4 and, historically, income or losses qualifying for the (no longer applicable) 10 per cent corporation tax rate for manufacturing operations were calculated as they would for 'independent parties dealing at arm's length'.5
The transfer pricing legislation introduced in 2010 certainly broadened the scope of application of transfer pricing in Irish tax legislation. As might be expected, where the transfer pricing rules apply, an arm's-length amount should be substituted for the actual consideration in computing taxable profits. The arm's-length amount is the consideration that independent parties would have agreed in relation to the arrangement in question.6 The transfer pricing legislation applies equally to domestic and international arrangements but does not apply to small and medium-sized enterprises.7
Irish tax legislation requires that the profits or gains of a trade carried on by a company must be computed in accordance with generally accepted accounting practice subject to any adjustment required or authorised by law.8 Therefore, Irish transfer pricing legislation may result in an adjustment to the accounting profits for tax purposes. Where a transaction is undertaken at undervalue this may be a deemed distribution by the company for Company Law purposes, and if the company does not have distributable reserves this may be an unlawful distribution by the company.
However, there are a number of unusual aspects to the Irish transfer pricing rules that are worth noting and that are currently being considered as part of a Department of Finance public consultation process on the modernisation of Ireland's transfer pricing rules, launched on 18 February 2019.
First, the transfer pricing legislation applies to any 'arrangement' involving the supply and acquisition of goods, services, money or intangible assets. For these purposes, arrangement is very broadly defined and it captures any kind of agreement or arrangement whether it is, or is intended to be, legally enforceable. However, the transfer pricing legislation does not apply to any arrangement that was agreed before 1 July 2010.9 This grandfathering of existing arrangements is not limited by time and as long as the terms do not change then an arrangement in place before 1 July 2010 may be excluded from the Irish transfer pricing legislation, potentially indefinitely. Practically, the expectation of the Irish Revenue Commissioners (Irish Revenue) is that this grandfathering of transactions predating 1 July 2010 will be lost through the passage of time, where actual trading relationships change, even though contractual terms may not. As part of the transfer pricing legislative reform, it is expected that arrangements predating 1 July 2010 would cease to be grandfathered.
Second, the transfer pricing legislation applies where the supplier and acquirer in question are 'associated'. Two persons are associated if one person participates in the management, control or capital of the other, or the same person participates in the management, control or capital of each of the two persons. However, the first person is participating in the management, control or capital of the other person only if that other person is a company controlled by the first person. The transfer pricing rules will, therefore, necessarily involve at least one corporate entity.10 However, the transfer pricing rules do not apply in a single corporate entity. Therefore the transfer pricing rules do not apply in determining the pricing between the head office of a company and a branch of that company. Transfer pricing legislative reform is likely to see the application of the authorised Organisation for Economic Co-operation and Development (OECD) approach to branch profit attribution.
Third, the transfer pricing legislation will only apply to profits or losses arising from the relevant activities that are taxed as the profits of a trade or profession.11 This is an unusual aspect of the Irish transfer pricing rules that is worth considering in the context of the Irish corporation tax rates. In Ireland, corporate trading profits are taxable at 12.5 per cent while other non-trading or passive income (e.g., interest income) is typically taxed at 25 per cent. Rather unhelpfully, trading is defined in Irish legislation as including 'every trade, manufacture, adventure or concern in the nature of a trade'. While there is extensive case law on the meaning of trading, the case law is typically very old and originates from a time when trading profits were taxable and non-trading profits were not taxable (in the absence of a capital gains tax). Typically, a trade in Ireland involves regular activity conducted in Ireland by persons engaged in the revenue generating part of that business. Very often, it is clear whether a particular activity constitutes a trade; however, it is not always clear in the context of intra-group loans or an intra-group licence arrangement, which can have trading and non-trading characteristics depending on the facts. This means it is possible for an Irish company to make an interest-free loan or grant a royalty-free licence where the level of activity does not rise to the level of a trade. The Irish transfer pricing rules will not apply to the non-trading arrangement and the Irish company is not obliged to charge interest on the loan or charge a royalty on the licence. However, where the company is making a number of loans or granting a number of licences, this may increase the likelihood that the company is actually trading and that the transfer pricing rules will apply requiring the imposition of an interest charge or royalty. Other noteworthy consequences of the rule, whereby transfer pricing legislation only applies to trading transactions, include the fact that capital transactions are not covered by the transfer pricing legislation (though the market value rule mentioned above may apply) and non-trading shareholder transactions are not captured either. The transfer pricing rules are likely to apply in some way to non-trading transactions as from 1 January 2020. There is some concern over a potential mismatch in the application of transfer pricing rules to wholly domestic Irish transactions. For example, non-trading interest income could be taxable at 25 per cent in one group company while deductible at 12.5 per cent in the other group trading company.
Fourth, the Irish transfer pricing legislation can only operate to increase the Irish taxable profit.12 Therefore the rules can only increase understated income or reduce overstated expenses.
Fifth, the Irish transfer pricing legislation should be construed to ensure, as far as practicable, consistency with the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. However, the relevant OECD Transfer Pricing Guidelines referenced in the Irish transfer pricing legislation are the guidelines approved by the Council of the OECD on 13 July 1995, as modified by the updates of 16 July 2009 and the revision of 22 July 2010 (namely the 2010 Transfer Pricing Guidelines).13 The 2017 OECD Transfer Pricing Guidelines have not yet been incorporated into Irish law but are likely to apply as from 1 January 2020. This is more relevant in respect of dealings between Irish companies and persons resident in non-double-tax treaty partner jurisdictions. The 2017 OECD Transfer Pricing Guidelines are considered to already apply to the interpretation of the arm's-length principle for the purposes of Ireland's double-tax treaties.
These unusual aspects of the Irish transfer pricing rules have raised questions as to whether the rules are still fit for purpose. As a result, the transfer pricing rules are under review and changes to the transfer pricing rules can be expected over the coming years. Possible future changes to the transfer pricing rules are considered in Section X.
ii FILING REQUIREMENTS
There is very little legislation detailing the documentation requirements for transfer pricing purposes. Quite simply, the legislation requires the taxpayer to have available, on a timely basis, such records as may reasonably be required for the purposes of determining whether the trading income has been computed in accordance with the requirements of the transfer pricing legislation.14 The transfer pricing legislative reform process is considering enhanced documentation requirements as outlined in Annexes I and II of Chapter V of the 2017 OECD Transfer Pricing Guidelines to ensure implementation of the best practice recommendation in BEPS Action 13.
Irish Revenue has issued guidance on the expectations regarding transfer pricing documentation.15 The guidance issued by Irish Revenue notes that there is no requirement for documentation to be kept in a standard form. The legislation does not require that the taxpayer itself must prepare the documentation or that the documentation must be in Ireland. Furthermore, if appropriate documentation has been prepared by an associated company for tax purposes in another country, it should be sufficient that the documentation can be made available if required. Although not binding, Irish Revenue accepts the EU Council code of conduct entitled 'EU Transfer Pricing Documentation' and Chapter V of the OECD Transfer Pricing Guidelines as representing good practice.
The actual documentation required will depend on the facts and circumstances and the documentation maintained should be commensurate with the risk involved whereby complex and high value transactions would generally require more detailed documentation than simple high volume transactions.
The guidelines issued on documentation (without being prescriptive) suggest that the relevant documentation maintained should clearly identify:
the associated persons for the purposes of the legislation;
the nature and terms of transactions within the scope of the legislation;
the method, functional analysis and comparables used;
how this has resulted in arm's-length pricing;
relevant budgets or forecasts relied upon; and
the terms of the relevant transactions.
It is best practice that the documentation is prepared or available at the time the terms of the transaction are agreed. There is no obligatory time frame for review and updating of transfer pricing documentation; however, it should be reviewed at regular intervals to determine whether the pricing remains at arm's length.
Ireland has introduced legislation to implement country-by-country reporting requirements.16 The Irish country-by-country reporting closely mirrors the OECD model legislation and relies on it for certain definitions. It should be noted that there are some differences between the OECD model legislation and the Irish country-by-country reporting legislation. Primarily in relation to options to appoint a surrogate parent entity or EU designated entity to provide the country-by-country report on behalf of the multinational group. Where there is a conflict, the Irish legislation takes precedence. Currently, there is no Irish legislation in respect of public country-by-country reporting, though this is an area of interest to the European Commission and ultimately may be introduced as an EU directive.
iii PRESENTING THE CASE
i Pricing methods
As mentioned above, the Irish transfer pricing legislation states that in computing the taxable profits and losses of a taxpayer, the legislation shall be interpreted to 'ensure, as far as practicable, consistency' with the OECD Transfer Pricing Guidelines. The Irish transfer pricing rules do not prescribe any preferred transfer pricing methodology or methodologies. Provided the methodology is appropriate in the circumstances and adheres to general OECD principles, it should be acceptable. Therefore the identification of the most appropriate transfer pricing method, either traditional transaction methods (CUP, resale price and cost-plus) or a transactional profit method (transactional net margin and transactional profit split), and the application of that method should be in accordance with the OECD Transfer Pricing Guidelines.
Irish Revenue has published guidance on a simplified approach in respect of low-value intra-group services.17 In summary, where a cost-based method is determined to be the most appropriate transfer pricing method for determining an arm's-length price for low value intra-group services, Irish Revenue is prepared to accept a markup of 5 per cent of the relevant cost base without the a requirement for a benchmarking study. The guidance also sets out the documentation requirements for the taxpayer to avail of this simplified approach for low value intra-group services.
Low value intra-group services are services performed by entities within a multinational group for other entities within the same group and are typically administrative, routine and supportive services that are ancillary to the main business and do not involve valuable intangibles or risk for the service provider. Irish Revenue is prepared to accept a markup of 5 per cent of the cost base without a requirement for a benchmarking study to be carried out by the taxpayer to support this rate.
However, supporting documentation is required and must include the following information:
a description of the services provided or received;
the identity of the recipient or provider of the service;
an explanation of why the services are considered to be low-value services;
the rationale for the provision or receipt of the services;
a description of the benefits of each category of services;
an explanation and justification of the allocation key chosen;
confirmation of the markup applied;
written contracts, and any amendments to the same, for the provision of services;
calculations of the final fee charged showing the calculation of the cost base, the application of the allocation key to that cost base and the application of the markup to the apportioned cost base;
confirmation that shareholder costs and duplicate costs have been excluded from the cost base; and
confirmation that no markup has been applied to pass-through costs.
Irish Revenue accepts that the EU guidelines on low-value added intra-group services represent good practice.
ii Authority scrutiny and evidence gathering
On transfer pricing matters, Irish Revenue does not typically engage in dawn raids. The taxpayer will be provided with reasonable notice of an upcoming visit or intention to initiate an audit. This is typically followed by a series of written request for further information or explanations. This may be supplemented by requests for meetings with representatives of the taxpayer and interviews with relevant persons employed by the taxpayer.
While Irish Revenue will seek to understand the taxpayer's business and obtain an overview of its global business, in the normal course of events the primary focus is typically on the direct intra-group relationships to which the Irish resident taxpayer is a party. Irish Revenue does not typically consider arrangements to which the Irish taxpayer is not a party or seek to allocate profit share per jurisdiction throughout a multinational group.
Irish Revenue may also serve notice on a financial institution and other third parties to make books, records or other documents available for inspection, if they contain information relating to a tax liability of a taxpayer, even if the taxpayer is not known to the officer but is identifiable by other means. The officer authorised must have reasonable grounds to believe that the financial institution or other third party is likely to have information relating to this liability.
Irish Revenue is a strong advocate for international cooperation on tax matters. Ireland has entered into a more than 70 double-taxation treaties and numerous tax information exchange agreements under which Irish Revenue cooperates with foreign authorities in the exchange of tax information. Irish Revenue has information exchange obligations arising from Ireland's membership of the European Union and the OECD, both of which involve automatic exchange of information relating to cross-border tax rulings and advance pricing agreements.
iv INTANGIBLE ASSETS
There are no particular rules in Ireland addressing transfer pricing in respect of intangible assets, although the amortisation available on the acquisition of intangible assets is limited to the amount 'which would have been paid or payable for the asset in a transaction between independent persons acting at arm's length'.18 There is no further guidance on the meaning of arm's length in this context. However, Ireland has strongly endorsed the outcomes of the BEPS project, including the report on Actions 8–10.
The 2017 OECD Transfer Pricing Guidelines have not yet been incorporated into Irish law. Therefore in non-double-tax treaty transfer pricing cases the development, enhancement, maintenance, protection and exploitation of intangibles (DEMPE) principles, to the extent they are not reflected in the 2010 OECD Transfer Pricing Guidelines, should not have direct application. This is particularly relevant from an Irish perspective in the context of royalty payments from Irish resident companies to IP holding companies resident in a non-double-tax treaty jurisdiction. However, the DEMPE principles are relevant in double-tax treaty cases.
v SETTLEMENTS
There is no publicly available information on transfer pricing settlements concluded with Irish Revenue. However, in practice it is clear that Irish Revenue places great importance on reaching settlements that can be supported by appropriate evidence and are based on OECD principles. Under Irish Revenue's internal quality assurance programme, a selection of audits and ultimately settlements are monitored to ensure quality.
A taxpayer may make a voluntary disclosure of an underpayment of tax before an audit has commenced to benefit from reduced penalties. Once an audit has commenced, and through the appeals process, the opportunity to settle remains open, though the level of penalty mitigation may be reduced.
Once a settlement is agreed, the outstanding tax plus interest and penalties is paid and the audit is closed. In certain circumstances, where significant penalties are imposed as part of the settlement, Irish Revenue is obliged to publish the name and address of the taxpayer along with the default amount and applicable tax head.19
As Irish Revenue will endeavour to conclude a transfer pricing settlement based on OECD principles, they will generally accept a similar methodology going forward as long as the facts and circumstances have not changed. While a settlement discussion may be broadened and extended into a bilateral advance pricing agreement Irish Revenue will no longer agree to a unilateral advance pricing agreement in any circumstances.
vi INVESTIGATIONS
Irish Revenue maintains scrutiny on the transfer pricing matters within the framework of the existing tax compliance infrastructure with support from a team of economists. Separately Irish Revenue's competent authority team manage international transfer pricing disputes and bilateral or multilateral advance pricing agreements. Irish Revenue has published guidance on its approach to transfer pricing investigations.20
Upon the introduction of the transfer pricing legislation in 2010, it was recognised that there was not a significant level of experience or understanding of the transfer pricing policies of multinationals operating in Ireland. Therefore within the context of monitoring transfer pricing compliance, in November 2012 Irish Revenue initiated a system of transfer pricing compliance reviews.21 This comprised a non-audit intervention whereby the tax inspector would make a request for information on the transfer pricing policy within a multinational group. The information requested would include:
the group structure;
details of transactions by type and associated companies involved;
pricing and transfer pricing methodology for each type of transaction;
the functions, assets and risks of parties;
a list of documentation available or reviewed; and
the basis for establishing how the arm's-length standard is satisfied.
This initial non-audit intervention could lead to a more traditional audit. Over time, as experience has grown, transfer pricing audits are more common and are handled in a similar manner to audits under other tax heads. Irish Revenue has noted that the deployment of its resources will take into account risk factors and, therefore, it is unlikely that transactions between persons that involve no overall loss of revenue will be targeted.
An authorised officer can require a taxpayer to deliver, or to make available for inspection, books, records and other documents (including transfer pricing documents) or to furnish information relevant to the taxpayer's tax liability under the legislation. An authorised officer can also apply to the High Court for an order directing the person concerned to comply with the officer's requirements in respect of books, records and other information.22
The statute of limitations for raising an assessment is four years from the end of the accounting period in which the relevant tax return is delivered.23 This typically means the accounting period remains open for audit for five years from the end of the accounting period in question.
Once an assessment is raised the taxpayer has 30 days to lodge an appeal to the assessment in writing. The case then moves forward to the Tax Appeals Commissioners for determination. Further appeal on points of law may be made to the High Court, Court of Appeal and ultimately the Supreme Court through the regular court system. It is worth noting that settlement negotiations can continue during the period following the issuing of an assessment and lodging an appeal.
vii LITIGATION
i Procedure
To make an appeal to an assessment the taxpayer must submit a formal notice of appeal to the Tax Appeals Commission, along with a copy of the notice of assessment or the letter of notification containing the decision to be appealed. The notice of assessment or the letter or notification will state the time limit for making an appeal but it is generally 30 days from the date on the notice of assessment or the letter or notification.
For the Tax Appeal Commissioner to accept the appeal, the taxpayer must have submitted a tax return and paid the amount of tax declared on the return. It is not necessary to pay the tax assessed by Irish Revenue in the notice of assessment. If this condition is not satisfied, Irish Revenue may object to the leave to appeal and will notify the taxpayer of the objection. While Irish Revenue can object to the acceptance of the appeal, it is a matter for the Tax Appeals Commission to accept or refuse to accept the appeal.
Most appeals end up being settled by an agreement between taxpayers and Irish Revenue rather than being decided by the Tax Appeals Commission. The appeal to the Tax Appeals Commission will remain open for the duration of any discussions with Irish Revenue. However, the Tax Appeals Commission may decide to proceed with the appeal if it thinks that it is unlikely to be settled by agreement or it is unlikely to be settled within a reasonable period.
Most appeals that end up with the Tax Appeals Commission are decided following an oral hearing before an Appeal Commissioner. A hearing involves the Appeal Commissioner listening to arguments and evidence presented by the taxpayer and an Irish Revenue official. Both parties may be represented by a tax adviser or lawyer. Before an oral hearing takes place, the Tax Appeals Commission may ask the taxpayer or Irish Revenue to provide additional information about the matter being appealed. The Tax Appeals Commission can decide not to have an oral hearing but, instead, to make a decision based on written material provided by the taxpayer and Irish Revenue. This is more likely to happen where the matter being appealed is straightforward.
Whether your appeal is decided with or without an oral hearing, the taxpayer is given a detailed written decision that explains why the Appeal Commissioner made the decision. All decisions are published on the Commission's website24 but do not identify the particular taxpayer involved. To date, there have been no transfer pricing decisions published.
Either party may appeal a decision of the Appeal Commissioners to the High Court on a point of law but this is not a complete re-hearing of the appeal. Therefore, the ability to appeal will depend on the decision made by the Appeal Commissioner and the reasons given for making that decision.
ii Recent cases
There has been no case law or Tax Appeals Commissioners decision on Ireland's transfer pricing legislation, although there are cases awaiting hearing. In a case that pre-dated the transfer pricing legislation, Belville Holdings v. Cronin,25 the High Court considered whether a parent company was obliged to charge for services provided to subsidiaries in circumstances where it was otherwise incurring losses as a result of expenses incurred. The High Court held that the parent company should be obliged to charge expenses incurred managing its subsidiaries but only to bring the transaction within the realm of being a bona fide transaction in the ordinary course of business.
viii SECONDARY ADJUSTMENT AND PENALTIES
Irish Revenue is not entitled to impose secondary adjustments under transfer pricing legislation where those adjustments do not relate to an understatement of trading profits.
The transfer pricing legislation does not contain any specific penalties. Therefore, normal taxation and penalty provisions will apply. Therefore both fixed and tax-geared penalties may apply. The applicable tax-geared penalty can be as much as 100 per cent of the underpaid tax. Irish Revenue is prepared to mitigate penalties to an amount as low as 3 per cent of the underpaid tax. The applicable percentage will depend on whether there has been a qualifying disclosure, it is a first offence, it is careless behaviour or deliberate behaviour and whether consequences are significant.26
Where the taxpayer does not agree on the liability to a penalty then it is a matter for the court to determine whether that person is liable to a penalty.
ix BROADER TAXATION ISSUES
i Diverted profits tax and other supplementary measures
Ireland has not introduced a diverted profits tax or other measures to supplement transfer pricing rules.
ii Double taxation
To avoid double taxation on transfer pricing matters, taxpayers may request mutual agreement procedure assistance under the terms of the relevant double-tax treaty or the EU Arbitration Convention.
The legal basis for a mutual agreement procedure request falls under the equivalent of Article 25 of the OECD's Model Tax Convention on Income and on Capital in the relevant double-tax treaty. In international transfer pricing matters it is typically advisable for each affected taxpayer to make a separate request for mutual agreement procedure assistance to the competent authority of the country in which it is resident. Under the multilateral instrument agreed as part of the BEPS process Ireland has opted to allow a taxpayer approach the competent authority of either jurisdiction. The mutual agreement procedure request must be submitted in writing within the time limit applicable in the relevant double-tax treaty (which is typically three years, but may vary by treaty) or the EU Arbitration Convention (which is three years from the first notification of the action that results or is likely to result in double taxation). The time period typically begins from the date of the first tax assessment notice or equivalent.
The minimum information to be provided as part of a mutual agreement procedure request under a double-tax treaty includes details of the relevant tax periods, the nature of the action and the names and addresses of the relevant parties. For a valid request under the EU Arbitration Convention, the request should also include details of the relevant facts, copies of assessments, details of litigation commenced and an explanation of why the principles of the EU Arbitration Convention have not been observed.27
Double taxation can also be avoided by means of settling an advance pricing agreement. Importantly Irish Revenue is prepared to conclude a multilateral or bilateral advance pricing agreement with double-tax treaty partner jurisdictions. Irish Revenue will not conclude unilateral pricing agreements. Irish Revenue has issued detailed guidelines on the processes for advance pricing agreements.
A request for a mutual agreement procedure can be distinguished from a request for a correlative adjustment where a foreign associated taxpayer has settled a case unilaterally with its foreign tax administration with regard to a transaction with its Irish associated taxpayer, and the associated Irish taxpayer subsequently makes a claim to Irish Revenue for a correlative adjustment. Irish Revenue will consider the appropriateness of such claims and will only allow a correlative adjustment to the profits of the Irish taxpayer to the extent that it considers the adjustment to be at arm's length.
Double taxation may be unavoidable in a situation where a non-negotiable tax settlement has been agreed in one jurisdiction and Irish Revenue does not consider the settlement reached to reflect an arm's-length position.
iii Consequential impact for other taxes
Where a transfer pricing adjustment is simply booked as an adjustment to taxable profits and there is no adjustment to the actual price charged and invoiced as between the associated entities then there should be no VAT impact. Where the adjustment is charged and invoiced then VAT returns should be amended as appropriate. The VAT recovery consequences will then depend on the VAT profile of the entity in question.
For customs purposes the price paid or payable is taken as the transaction value for customs purposes. So a transfer pricing adjustment that results in a change in the price paid may be relevant to any market valuation used as part of customs reporting. In light of the recent decision of the European Court of Justice in Hamamatsu Photonics Deutschland,28 the impact of pricing adjustments on the customs valuation declared on the importation of the goods is unclear. Irish Revenue has not published guidance or otherwise commented on the decision to date.
x OUTLOOK AND CONCLUSIONS
The Irish transfer pricing rules were only introduced in 2010, but following the BEPS process, some aspects are already looking outdated. On 2 September 2016, the government decided to arrange for a review of Ireland's corporation tax code by an independent expert to be appointed by the Minister for Finance. In September 2017, following extensive consultation, the relevant report was published.29 In February 2019, the Irish Department of Finance commenced a public consultation to consider the recommendations in the independent expert report.
The public consultation is seeking comments on the following recommendations:
Ireland should provide for the application of the OECD 2017 Transfer Pricing Guidelines incorporating BEPS Actions 8, 9 and 10 in Irish legislation;
Irish domestic transfer pricing legislation should be applied to arrangements, the terms of which were agreed before 1 July 2010;
consideration should be given to extending transfer pricing rules to small and medium-sized enterprises, having due regard to the administrative burden and risks;
consideration should be given to extending domestic transfer pricing rules to non-trading income and capital transactions; and
there should be a specific obligation on Irish taxpayers who are subject to domestic transfer pricing legislation to have available the transfer pricing documentation outlined in Annex I and II of Chapter V of the OECD 2017 Transfer Pricing Guidelines to ensure implementation of BEPS Action 13.
While the independent expert report suggested that changes should take place no later than the end of 2020, it seems likely that changes will be introduced with effect from 1 January 2020.
Irish Revenue has recognised transfer pricing as an important tool for raising tax revenues and defending the existing Irish tax base. The number of domestic and international transfer pricing disputes is increasing. In the meantime, the Irish transfer pricing rules are ready for modernisation and we will see changes later this year. It remains to be seen whether the changes to the rules will help alleviate the potential for disputes in this area.
1 Joe Duffy and Catherine O'Meara are partners at Matheson.
2 Taxes Consolidation Act 1997 (as amended up to Finance Act 2017).
3 Section 547 TCA.
5 Section 453 TCA. Deleted by Finance Act 2012 Section 54.
6 Section 835C TCA.
7 Section 835E TCA.
8 Section 76A TCA.
9 Section 42 Finance Act 2010.
10 Section 835B TCA.
11 Section 835C TCA.
13 Section 835D TCA.
14 Section 835F TCA.
15 Transfer Pricing Documentation Obligations Part 35a-01-02, August 2017.
16 Section 891H TCA and Taxes (Country-by-Country Reporting) Regulations 2016.
17 Guidelines on Low Value Intra-Group Services, Part 35A-01-03, March 2018.
18 Section 291A TCA.
19 Section 1086 TCA.
20 Monitoring Compliance with Transfer Pricing Rules, Part 35A-01-01, June 2018.
21 See Revenue Operational Manual 35A-01-01.
22 Part 38 TCA.
23 Part 41A TCA.
24 www.taxappeals.ie.
25 III ITR 340.
26 See Code of Practice for Revenue Audit and other Compliance Interventions, February 2017.
27 See Tax and Duty Manual Part 35-02-08.
28 C-529/16.
29 Review of Ireland's Corporation Tax Code presented to the Minister for Finance and Public Expenditure and Reform by Seamus Coffey, September 2017.
The Transfer Pricing Law Review
Other chapters on Ireland
The Acquisition and Leveraged Finance Review
The Asset Management Review
The Banking Regulation Review
The Cartels and Leniency Review
The Class Actions Law Review
The Complex Commercial Litigation Law Review
The Corporate Governance Review
The Corporate Immigration Review
The Dispute Resolution Review
The Employment Law Review
The Foreign Investment Regulation Review
The Gambling Law Review
The Healthcare Law Review
The Initial Public Offerings Law Review
The Insolvency Review
The Insurance Disputes Law Review
The Insurance and Reinsurance Law Review
The International Investigations Review
The Inward Investment and International Taxation Review
The Life Sciences Law Review
The Patent Litigation Law Review
The Private Equity Review
The Professional Negligence Law Review
The Real Estate Investment Structure Taxation Review
The Real Estate M&A and Private Equity Review
The Restructuring Review
The Shipping Law Review
The Tax Disputes and Litigation Review
The Virtual Currency Regulation Review
All titles on Ireland
The Banking Regulation Review Edition 10
Editor Jan Putnis
Banking regulation continues to confound the idea that views about how banks should be regulated will eventually settle down to an orthodoxy broadly accepted throughout the world. This edition covers 37 countries and territories in addition to our usual chapters on international initiatives and the European Union. There must be a feeling among many of the authors that banking regulation is a subject that will never settle down; that it will never return to being the rather duller subject that it was before it became a political issue more than 10 years ago.
The Transport Finance Law Review Edition 5
Editor Harry Theochari
Norton Rose Fulbright
This book is intended to provide the legal industry with a guide to transport finance today, in each of the key jurisdictions globally in which aircraft, rolling stock and ships are financed. Each contribution reflects the significance of the transport sector today, and the need for readily available funding for industries that underpin the global economy by transporting people and commodities around the world every day.
The Consumer Finance Law Review Edition 3
Editors Richard Fischer, Obrea Poindexter and Jeremy Mandell
Consumer choice for financial products and services is proliferating across global markets. The ability to reach consumers at any time on their mobile phones, tablets or other devices has helped attract substantial capital investment in consumer financial services. This survey of consumer finance law describes the legal and regulatory approaches taken in the jurisdictions covered. Each chapter addresses the key characteristics of, and current climate within, a particular jurisdiction. Although payments, lending and deposits are the focus of this survey, other financial products and services are discussed where relevant.
The Asset Management Review Edition 8
Editor Paul Dickson
This continues to be a period of change and uncertainty for the asset management industry, as funds and managers act to comply with regulatory developments and investor requirements, and adapt to the changing geopolitical landscape. The world of asset management is increasingly complex, but it is hoped that this edition of The Asset Management Review will be a useful and practical companion as we face the challenges and opportunities of the coming year.
The International Capital Markets Review Edition 9
Editor Jeffrey Golden
3 Hare Court Chambers
This book serves two purposes – one obvious, but the other possibly less so. Quite obviously, and one reason for its continuing popularity, the book addresses the comparative law aspect of our readers' international capital markets (ICM) workload and equips them with a reference source. The second purpose this book aims to serve is to equip its readers to do a better job as practitioners at home. In other words, reading the summaries of foreign lawyers, who can describe relevant foreign laws and practices, is perfectly consistent with and helpful when interpreting and giving advice about one's own law and practice.
The Lending and Secured Finance Review Edition 5
Editor Azadeh Nassiri
This fifth edition contains contributions from leading practitioners in 25 different countries. We would like to thank each of the contributors for taking the time to share their expertise on the developments in the corporate lending and secured finance markets in their respective jurisdictions, and on the challenges and opportunities facing market participants.
The Acquisition and Leveraged Finance Review Edition 6
Editor Marc P Hanrahan
Milbank LLP
Leveraged finance, particularly with respect to acquisition financing, has been an expanding asset class for many years. This volume is intended to introduce the newcomer to the legal basics involved in leveraged finance, particularly acquisition finance, so that he or she is grounded in the underpinnings of the practice area. It is also intended to be a helpful update for the more seasoned practitioner with respect to what is new and what is being talked about in leveraged finance deals.
The Insolvency Review Edition 7
Editor Donald S Bernstein
Davis Polk & Wardwell LLP
This seventh edition of The Insolvency Review once again offers an in-depth review of market conditions and insolvency case developments in key countries. A debt of gratitude is owed to the outstanding professionals around the world who have dedicated their time and talents to this book. As always, their contributions reflect diverse viewpoints and approaches, which in turn reflect the diversity of their respective national commercial cultures and laws.
The Initial Public Offerings Law Review Edition 3
Editor David J Goldschmidt
Skadden Arps Slate Meagher & Flom
This publication introduces the reader to the main stock exchanges around the globe and their related initial public offering (IPO) regulatory environments, and provides insight into the legal and procedural IPO landscapes in 18 different jurisdictions. Each chapter gives a general overview of the IPO process in the region, addresses regulatory and exchange requirements, and presents key offering considerations.
The Project Finance Law Review Edition 1
Editor David F Asmus
Many of the classic project finance texts are becoming increasingly dated as the years go by, while project finance itself continues to evolve with the markets it serves. The purpose of this volume is to provide a living guide to project finance that will be updated on a regular basis, while still tackling the core project finance concepts that every practitioner needs to understand.
The Virtual Currency Regulation Review Edition 2
Editors Michael S Sackheim and Nathan A Howell
The second edition of the Review provides a practical analysis of recent legal and regulatory changes and developments, and of their effects, and looks forward to expected trends in the area of virtual currencies on a country-by-country basis. It is not intended to be an exhaustive guide to the regulation of virtual currencies globally or in any of the included jurisdictions. Instead, for each jurisdiction, the authors have endeavoured to provide a sufficient overview for the reader to understand the current legal and regulatory environment.
The Islamic Finance and Markets Review Edition 4
Editors John Dewar and Munib Hussain
We are honoured to present the fourth edition of The Islamic Finance and Markets Law Review. The chapters that follow describe the manner in which Islamic, or shariah-compliant, finance is practised in various jurisdictions throughout the world. Although each country will have variations, one of the most striking features of Islamic finance as a legal discipline is that it includes core concepts and structures that cross jurisdictional boundaries.
The Securitisation Law Review Edition 1
Editor Michael Urschel
The purpose of this inaugural edition of The Securitisation Law Review is to provide securitisation attorneys, borrowers, lenders and other market participants with insight into a sample of structural frameworks and regulatory issues surrounding the industry in a broad array of jurisdictions. This edition is not intended to be a comprehensive overview of securitisation regulation and structures in every jurisdiction, but rather to provide a frame of reference for, and a comparison of, the various structural features available and the regulatory considerations necessary in securitising assets globally.
The Financial Technology Law Review Edition 2
Editor Thomas A Frick
Niederer Kraft Frey
We are delighted to present the second edition of The Financial Technology Law Review. The authors of this publication are from the most widely respected law firms in their jurisdictions. They each have a proven record of experience in the field of fintech; they know both the law and how it is applied. We hope that you will find their experience invaluable and enlightening when dealing with any of the varied issues fintech raises in the legal and regulatory field.
The Banking Litigation Law Review Edition 3
Editor Deborah Finkler
This year's edition of The Banking Litigation Law Review demonstrates that the increase in litigation involving banks shows little sign of slowing. Although disputes arising from the 2008 financial crises are reaching their end, what might be termed 'normal' banking litigation has resumed, and is in no short supply.
The Restructuring Review Edition 12
Editor Christopher Mallon
We are very pleased to present this twelfth edition of The Restructuring Review. As with the previous editions, our intention is to help general counsel, private practice lawyers and the public sector understand the conditions prevailing in the global restructuring market in 2019, and to highlight some of the more significant legal and commercial developments and trends that have been evident in recent years, and that are expected to be significant in the future.
The Structured Products Law Review Edition 1
Editors Christopher S Schell, Yan Zhang and Derek Walters
Despite the significant growth of the global structured product market in recent years, very few books on legal and regulatory issues related to structured products are available. We hope that this publication will contribute to the knowledge base of legal practitioners and other structured product market participants. For our purposes, the term structured product refers to a pre-packaged investment that combines derivatives with other financial instruments to provide a return based on the performance of one or more underlying assets, including equity securities, indices, commodities, interest rates, currencies and, in some jurisdictions, credit risks.


Things start rough when Kevin loses his controller. Can he recover? Can he find his way to the City of Tears? Can he kill a couple bosses? Can he find that darned map guy? Can he find refreshing goodness from iced morning sickness tea?
The controller was on the ground.
Not for nearly an hour despite having quick travel powers to do so.
Also, sorry if the audio is a bit weird. I have my ceiling fan on since it's a little muggy in the Geek Asylum Studio studio today.
This time we find a few new talisman, Kevin gets a new toy, and our Hollow Knight find some respect with the mantis tribe! Also, we kill another dead ghost and harvest their energy. Best of all, I only die once! Woo-hoo!
We enter this round with the strong realization that we will have to fight the boss that caused so much misery in the previous episode…but things go a bit weird when our little knight doesn't see that boss for an hour and finds some really fun side events in the world between life and death. Also, now we can fight ghosts!
Maybe thinking the world was our oyster was a bad idea…it's time to see and learn about death. Like on a first name basis.
We pick up a new travel ability, a new map, and maybe find a new friend or two when we return to the Hollow Kingdom for more Hollow Knight.
Remember to join for the live streaming every Thursday around 4PM PDT.


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text:
Tasmanian health staff off to the UK on taxpayer-funded trip to recruit mental health nurses
By state political reporter Ellen Coulter
Posted Thu 10 Jan 2019 at 8:34pm Thursday 10 Jan 2019 at 8:34pm Thu 10 Jan 2019 at 8:34pm , updated Thu 10 Jan 2019 at 8:44pm Thursday 10 Jan 2019 at 8:44pm Thu 10 Jan 2019 at 8:44pm
Mental health services in Tasmania are understaffed, and public servants are on a recruiting drive. (ABC News)
abc.net.au/news/tasmanian-health-staff-off-to-uk-to-recruit-mental-health-nurses/10706708
A taxpayer-funded trip to the United Kingdom for five senior Tasmanian health service staff to recruit mental health workers has been criticised by unions, who say the issue could be solved if local nurses were simply paid more.
Tasmania has 30 vacant mental health service positions
In October 2017, two senior health staff took a taxpayer-funded trip to the UK to address employment expos
But unions say the THS should invest in existing staff
Tasmania's chief psychiatrist and four senior health service staff will spend nine days and at least $25,000 of taxpayer money next month in a bid to entice staff to the state — an exercise the union representing health workers has labelled "bizarre", as public sector employees continue to butt heads with the Government over a pay rise.
In October 2017, two senior Tasmanian Health Service (THS) staff took a $31,000 taxpayer-funded, three-week trip to the UK to speak at employment expos.
The THS said 20 international nurses had been recruited in 2018 as a result of that representation.
Chief psychiatrist Aaron Groves said the upcoming expedition would be different.
"We plan to be interviewing people for current vacant positions rather than going to expos," he said.
"This is people who will have applied for positions that we have in Tasmania that are vacant that we haven't been able to fill with Australians for the best part of 12 months."
Dr Groves said there were already 30 vacant mental health service positions in Tasmania, and the need for mental health nurses and psychiatrists would increase after a State Government commitment to expand mental health services.
Successful candidates would be offered relocation packages of up to about $10,000.
Nurses and other health workers have been locked in enterprise bargaining negotiations with the State Government for months.
Investment in local nurses the answer, unions say
Robbie Moore from the Health and Community Services Union (HACSU) said he was shocked by the trip, and said the State Government and THS should invest in existing staff and retainment incentives.
"They would be a lot better off paying their staff competitive wages," Mr Moore said.
"That's how you attract staff into the mental health sector.
"We think they should also be trying to invest with the university and make sure that people are attracted to mental health through competitive wages and conditions."
Dr Groves said there was an Australia-wide shortage of mental health nurses, and many of Tasmania's mental health nurses were approaching retirement age.
"It's not just a simple matter of what they're paid, it's a matter of how many they are and how many we're training and whether they're even available to be employed," he said.
A comparison of wages between the states. (Supplied: Australian Nursing and Midwifery Federation)
Emily Shepherd from the Australian Nursing and Midwifery Federation (ANMF) said there were significant difficulties in recruiting mental health-trained nurses in Tasmania.
"Obviously our preference would be supporting Tasmanian nurses and growing our own mental health-trained nurses here, but in the interim while those nurses are undertaking formal training, that [UK recruitment] would be welcome in terms of having additional support."
Ms Shepherd said the trip and relocation packages were a significant amount of money.
"We'd like to see similar amounts that are being offered for relocation for nurses to come and work in Tasmania be offered to Tasmanian nurses to specialise and undertake post-graduate qualifications in mental health," she said.
Ms Shepherd said recruiting nurses from the UK was a short-term strategy.
The ANMF says recruiting and retaining nurses is a problem in Tasmania. (ABC News)
"What we know from history is that often they do come to Tasmania and work here for a while, but traditionally we've seen that they then move on from Tasmania."
Dr Groves said the THS had worked with the Department of State Growth on state-nominated skills visas.
"The visa requirements for skilled migrants under this approach require applicants to live and work in Tasmania for at least two years."
The State Government spent $7.5 million on agency nurses last financial year, including flying them in from interstate to plug staffing gaps in the state's hospitals.
Mental health nursing is chronically understaffed in Tasmania. (ABC News: Louise Merrillees)
Posted 10 Jan 2019 10 Jan 2019 Thu 10 Jan 2019 at 8:34pm , updated 10 Jan 2019 10 Jan 2019 Thu 10 Jan 2019 at 8:44pm
Tasmanian nurse recruitment drive finds no takers
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Jason Kubler and Rinky Hijikata play in surprise men's doubles final
Liberals claim victory in Narracan, securing last seat to be decided in Victorian election
live: Jason Kubler and Rinky Hijikata play in surprise men's doubles final
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text:
package com.skubit.bitid;

public class ResultCode {

    public static final int NO_CONNECTION = -1;

    public static final int OK = 0;

    public static final int USER_CANCELED = 1;

    public static final int INVALID_BITID = 100;

    public static final int INVALID_NONCE = 101;

    public static final int NONCE_EXPIRED = 102;

    public static final int INVALID_SIGNATURE = 103;

    public static final int INVALID_ADDRESS = 104;

    public static final int CALLBACK_DOES_NOT_EXIST = 105;

    public static final int UNKNOWN_ERROR = 199;

}

redpajama_set_name: RedPajamaGithub