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 unibelle

link 23.06.2020 20:42 
Subject: rigor
Здравствуйте, прошу помочь с переводом слова "rigor" в следующем контексте (привожу пункты до и после для контекста):

Transfer pricing guidelines

Section on safe harbours

4.117 It is important to observe that the problems of non-arm’s length results and potential double taxation and double non-taxation arising under safe harbours could be largely eliminated if safe harbours were adopted on a bilateral or multilateral basis by means of competent authority agreements between countries. Under such a procedure, two or more countries could, by agreement, define a category of taxpayers and/or transactions to which a safe harbour provision would apply and by agreement establish pricing parameters that would be accepted by each of the contracting countries if consistently applied in each of the countries. Such agreements could be published in advance and taxpayers could consistently report results in each of the affected countries in accordance with the agreement. 

4.118 The rigor of having two or more countries with potentially divergent interests agree to such a safe harbour should serve to limit some of the arbitrariness that otherwise might characterise a unilateral safe harbour and would largely eliminate safe harbour-created double taxation and double non-taxation 8 concerns. Particularly for some smaller taxpayers and/or less complex transactions, creation of bilateral or multilateral safe harbours by competent authority agreement may provide a worthwhile approach to transfer pricing simplification that would avoid some of the potential pitfalls of unilateral safe harbour regimes. 

4.119 The Annex I to Chapter IV of these Guidelines contains sample memoranda of understanding that country competent authorities might use to establish bilateral or multilateral safe harbours in appropriate situations for common classes of transfer pricing cases. The use of these sample memoranda of understanding should not be considered as either mandatory or prescriptive in establishing bilateral or multilateral safe harbours. Rather, they are intended to provide a possible framework for adaptation to the particular needs of the tax authorities of the countries concerned.

Спасибо

 Pokki

link 24.06.2020 1:42 
Вы думаете, это какой-то термин? Переводите, как хотите - жёсткость, строгость, суровость...

 johnstephenson

link 24.06.2020 11:46 
'rigor' here means 'applying strict controls' (to the process) -- by ensuring that at least two countries have to agree to it, rather than just one country.

 unibelle

link 24.06.2020 12:49 
Всем спасибо

 johnstephenson

link 25.06.2020 16:01 
unibelle: This may not be important, but I suspect that your text has been either:

a) written by more than one native English-speaker -- one (or more) from the US and one (or more) from the UK; or else

b) translated into (very good) English by a non-native speaker using US English and UK English dictionaries,

rather than being written by a single, native English-speaker.

Reason: rigor is US English -- but harbour is UK English. Both of these words appear in your text. Americans don't usually use the UK spelling, and Britons don't usually use the US spelling.

* rigor (US Eng) = rigour (UK Eng)

* harbor (US Eng) = harbour (UK Eng)

 unibelle

link 26.06.2020 13:13 
johnstephenson, I suppose you are right, though who knows what happens within OECD :)

 johnstephenson

link 26.06.2020 13:27 
What has OECD to do with it?

 

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