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Implications of the New Transfer Pricing Guidelines in China and Practical Measures for Multinationals to Adopt in 2009
There have been seismic developments in the transfer pricing field in China in the past year with the promulgation by the State Administration of Taxation (SAT) of the following important legislation and guidance:
• "The Corporate Income Tax Law of the People's Republic of China" (hereinafter referred to as the "Corporate Income Tax Law") issued on 16 March 2007 and effective from 1 January 2008;
• "The Implementation Regulations of the Corporate Income Tax Law of the People's Republic of China" (hereinafter referred to as the "Implementation Regulations of the Corporate Income Tax Law") published on 11 December 2007;
• "Annual Reporting of Related Party Transactions" otherwise known as Guo Shui Fa [2008] No. 11 4, issued on 17 December 2008, detailing the related party disclosure forms that will be required to be completed and submitted by taxpayers along with their 2008 tax return on or before 31 May 2009; and
• "The Implementation Regulations of Special Tax Adjustments" released in Guo Shui Fa (2009) No 2 on 9 January 2009, (hereinafter referred to as the "STA Guidelines").
The end result of these key documents is a modern and comprehensive transfer pricing system for China, although certain areas require further clarification, and uncertainty remains over the consistency of enforcement of the rules from one province to another. Taxpayers can expect further guidance to be released in the coming months and years to continue the development of China's transfer pricing regime.
Other articles in the recent past have described in detail the content of the new rules in China. The purpose of this article is to reflect on these current developments and offer some insights on what they should mean for multinationals currently operating in China or considering investment there.
The amount of information that will be required to be presented on an annual basis by taxpayers to the tax authorities is huge. The release of Guo Shui Fa [2008] No. 11 4 requires every taxpayer to submit nine very detailed forms along with their tax return if they have entered into any related party transactions during the tax year under review. It is important to note that the thresholds applicable to transfer pricing documentation do not apply in respect of these disclosure forms – every taxpayer with any related party transactions will need to submit them, and the deadline remains 31 May 2009 in respect of the 2008 year.
The forms that will be required are as follows:
• Annual Reporting of Related Party Transactions – Associated Parties
• Annual Reporting of Related Party Transactions – Transaction Summary
• Annual Reporting of Related Party Transactions – Sales and Purchases
• Annual Reporting of Related Party Transactions – Services
• Annual Reporting of Related Party Transactions – Transfer of Intangible Assets
• Annual Reporting of Related Party Transactions – Transfer of Fixed Assets
• Annual Reporting of Related Party Transactions – Financing
• Annual Reporting of Related Party Transactions – Outbound Investments
• Annual Reporting of Related Party Transactions – Outbound Payments
Many multinationals will need to make changes and enhancements to their IT and accounting systems to enable this type of detailed information to be produced on a reliable and timely basis. To assist multinationals in this process, the Transfer Pricing Associates (TPA) group has developed an MS Excel version of the disclosure forms in English and Chinese that will be suitable for multinationals of all sizes to capture, communicate and record the information quickly and efficiently. Taxpayers should be aware that failure to submit the forms along with the tax return will constitute grounds for initiation of a transfer pricing audit, as well as giving rise to a fine.
Based on experiences in countries other than China that have advised the Chinese authorities over the past 5-10 years in the development of their transfer pricing system, taxpayers in China can look forward to the SAT using this detailed information to risk assess taxpayers – in other words, to classify taxpayers as either high, medium or low risk of transfer pricing investigation. The factors that the SAT will apply have already been spelt out in Chapter 5 of the STA Guidelines as follows:
• Significant amounts or many different types of related party transactions
• Long-term losses, marginal profits or fluctuating profits
• Profit levels lower than the industry norm
• Profit levels lower than fellow group companies
• Profit levels not in accordance with functions performed or risks borne
• Transactions with related parties in tax havens
• Failure to declare related party transactions or prepare relevant tranfer pricing documentation
• Enterprises that "obviously" disobey the arm's length principle
In addition, contract manufacturers (so-called "solefunction manufacturers") that are operating at a loss face a particularly high risk of transfer pricing audit and adjustment since the release of Guo Shui Han No. 236 [2007] – a circular issued by the SAT to local tax bureau officers instructing them to investigate such companies.
Therefore, multinationals should ensure that their scarce resources in terms of time and money are devoted to those areas of highest risk. This can be achieved through an objective assessment of transfer pricing risk, by considering the following types of risk factor:
• Prior audit history
• Any advance pricing arrangements in place
• Size of transactions
• Types of transactions
• Location of transacting entities (tax havens)
• Profitability of transacting entities (vs industry norms/ other entities in the company's group)
• Whether existing documentation is available
• Whether benchmarking was carried out
• Tax differentials between jurisdictions of transacting entities
• Whether tax treaty protection is available
Through a more or less scientific methodology, it is possible to decide which areas require the greatest amount of work – higher risk transactions (e.g. royalties, sale of goods to a loss-making distributor) or higher risk entities (e.g. loss-making manufacturers) should receive a higher priority in terms of allocation of time and budget for preparing documentation and other supporting analysis. This will involve the identification of internal resources to handle the project, or selection of external service providers to provide assistance within the budget allocated.
The above information will enable the SAT and local auditors to devote tax investigation resources to those areas deemed to provide the highest chances of large transfer pricing adjustments and additional tax collections. This is likely to take place on an industry by industry basis – the SAT will likely advise local auditors to identify a particular industry which as a whole represents a high risk of tax leakage for the country, and systematically carry out investigations of the larger players in that industry first of all. Then, using the knowledge of the industry issues acquired from those initial audits, the SAT is likely to advise local auditors to carry out investigations of the other key players in the same industry. The particular industries that could be targeted initially could be those involving significant intellectual property, potentially including local marketing intangibles.
Transfer pricing adjustments in the past years have concentrated on manufacturers, with the adjustment made to the mark-up applied to costs. Hence, the amount of the adjustments made has been relatively modest by international standards. However, the SAT and local auditors are becoming more confident in pursuing larger adjustments by focussing on higher value issues, such as the potential presence of local marketing intangibles, to justify a significantly higher return in China. The development of local intangible assets by China manufacturers led multinationals to apply the contribution profit split method.
This tougher and more targeted approach to tax investigations and transfer pricing enforcement will be boosted by the establishment of the large enterprise tax administration department in the SAT, and by the fact that the former head of transfer pricing for China has been transferred into that new department. Larger enterprises can expect to be investigated from an anti-avoidance and transfer pricing perspective sooner rather than later.
Under the STA Guidelines, comprehensive transfer pricing documentation should be prepared by all taxpayers for each year from 2008 unless one of the following exemptions applies:
• Entities whose total number of annual domestic and cross-border related party transactions lie below certain thresholds – tangible goods transactions (such as purchase and sale of raw materials, components and finished goods) worth less than RMB 200 million and intangible goods transactions (such as royalties, service fees and loan interest) of less than RMB 40 million
• Entities whose related party transactions are all covered by an Advance Pricing Agreement (APA)– although there will be limited documentation obligations under the terms of the APA
• Entities that are not majority foreign-owned and do not have any cross-border related party transactions. Hence, wholly or majority foreign-owned enterprises are subject to the documentation requirements even though they only have domestic related party transactions, unless one of the other exemptions applies
The transfer pricing documentation should be in place by the time for submitting of the tax return for the year in question, which is normally 31 May in the following year. However, as a concession, the deadline for taxpayers to comply with the documentation requirement for the 2008 year will be extended to 31 December 2009.
Taxpayers that fail to prepare the transfer pricing documentation when required to do so will clearly face an increased risk of transfer pricing review and audit, and if transfer pricing adjustments are made, they will be subject to an additional 5% interest penalty. Such interest and penalties can become very substantial when transfer pricing adjustments relate to a number of years, and taxpayers should be aware that no correlative relief is available under double tax treaties for such interest and penalties.
It is important to emphasize that, even if taxpayers are not required by the STA Guidelines to prepare transfer pricing documentation, they are still highly recommended to do so in a number of circumstances, such as:
• The taxpayer company has characteristics that subject it to a high risk of transfer pricing audit and investigation, such as being a loss-making manufacturer or a distributor achieving net margins lower than the industry norm
• The taxpayer operates in a high-risk industry or is part of a large multinational group that faces a high risk of a transfer pricing audit
• The taxpayer discloses unusual or suspicious related party transactions or transfer pricing methods when completing the obligatory related party disclosure forms
• The taxpayer is exempt for the 2008 year due to the thresholds on related party transactions, but expects an increase in the amount of related party transactions in future years. In this case, it is highly recommended to carry out a documentation exercise for the 2008 year in order to capture the industry and functional analysis information for future use, because such information can be lost over time as employees change employers and memories fade
Taxpayers should bear in mind that transfer pricing adjustments can be made, and additional tax and penalties levied, by the SAT to include years when documentation may not have been strictly required – the limitation period is up to 10 years, and the interest and penalties will not be capable of correlative relief under any double tax treaties.
The article reviews transfer pricing regulatory and enforcement developments in China in 2014. It is evident that the Chinese tax authorities have become more and more sophisticated and experienced on transfer pricing administration, audit and investigation. The impact of global developments, in particular the targeting of BEPS at the OECD level, has further strengthened the resolve of the Chinese tax authorities to deal with the risk to China revenue that transfer pricing creates.
To avoid potential tax audit risks, it is advisable that taxpayers take positive and proactive steps to address the practical issues relating to the actual operation of the transfer pricing legislation, and to manage their transfer pricing documentation obligations and audit risks in the Chinese business environment. This is important now but will become essential in 2015 when the BEPS rollout continues and concepts such as CbC reporting are introduced.
Taxpayers should therefore approach the new transfer pricing regime in China with utmost caution. While this will involve a certain level of investment in terms of management time and resources, appointment of external advisers to assist in the process and so on, it is important in these difficult economic times to maximise the value derived from the economic analysis carried out and the documentation created, while reducing costs as far as possible.
Master file approach to documentation
A master file approach to documentation in China makes a great deal of sense for many reasons; it reduces the time taken to meet the compliance burden, eliminates inconsistencies, avoids duplication of effort and cost, and ultimately reduces the risk of transfer pricing audits, adjustments and double taxation.
In brief, the master file approach in the China context is to prepare core elements of transfer pricing documentation centrally, such as:
• Analysis of the overall business context and industry
• Functional analysis in respect of each type of entity, such as manufacturer, distributor, service provider and so on, provided that the multinational operates a centralised business model where the activities of each type of entity are broadly similar
• Classification of each type of entity for transfer pricing purposes in accordance with the responsibility centre concept the Organization for Economic Cooperation and Development (OECD) Guidelines and the China regulations
• Identification of the inter-company transactions involving the entities in China
• Selection of the most appropriate transfer pricing methodologies for each type of inter-company transaction, in accordance with the OECD Guidelines and China's regulations
• Benchmar k ing analyses us ing the databases recommended by the SAT in respect of each type of transaction and/or type of entity Once the China master file has been prepared in this way, preparing documentation for each specific entity becomes relatively simple. This would involve:
• Limited additional functional analysis work to confirm the nature of the specific entity's activities and the accuracy of the functional analysis information included in the master file
• Selection of the relevant sections of the master file report to be included in the entity-specific report, such as classification of the entity, identification of the inter-company transactions, selection of the transfer pricing methodology and benchmarking
• Financial analysis of the specific entity's performance to enable conclusions to be drawn as to the specific entity's compliance with the arm's length principle. It is important to appreciate that the master file is in itself not designed to satisfy the documentation requirements of any specific entity. Rather, it is a stepping stone to allowing the maximum amount of leverage in the preparation of multiple specific entity reports on a highly efficient, consistent and cost effective basis.
Many multinationals manage their global and regionaltransfer pricing compliance burden in this fashion, and a
similar approach to the China market is recommended – either as an extension of a global or regional master file, or as a separate standalone exercise. However, it is important to mention that reliance on a global master file will not suffice to satisfy the documentation requirements in China, as a certain amount of China – specific content is required.
Development of templates
It should be possible to develop documentation templates in the first year that documentation is prepared, and to leverage from those in future years in order to minimize additional costs. The Transfer Pricing Associates group has developed such templates including master file documentation, China standalone reports together with relevant Appendices and, as mentioned above, the related party transaction disclosure forms in electronic format.
Global multinationals are likely to continue the trend of insourcing their extensive transfer pricing documentation and tax compliance requirements, and the need to prepare China transfer pricing documentation will provide this trend with added impetus.
In a global survey of leading multinationals carried out by the Transfer Pricing Associates group in 2008, it was found that the majority of respondents would consider increasing their in-house transfer pricing activities to include routine documentation, which in turn would reduce external support costs. However, constraints in terms of in-house experience and resources remain. To the extent that insourcing is possible in light of the availability of resources, this will minimise the costs of satisfying the China transfer pricing documentation requirements.
Early identification of risks
The preparation of transfer pricing documentation for China should be accompanied by a detailed review of all potential transfer pricing risk areas, so that the multinational can take appropriate action to minimize those risks before they become reality. This should form an integral part of all transfer pricing documentation exercises, and can result in significant value being derived by the multinational concerned.
Identifying opportunities to minimise overall effective rate of tax
Similarly, the transfer pricing documentation exercise can help identify opportunities for achieving a different profit allocation between different entities in a company group while complying with the arm's length principle and in compliance with the provisions of the Corporate Income Tax Law. This may be achieved by simply correcting a non-arm's length transfer pricing system, or by altering the functions, assets and/or risks sufficiently to justify the of a different transfer pricing method or a different classification of one or more entities in the group. Such restructuring must be supported by the economic reality and business substance, in order to avoid challenges by the tax authorities under the STA Guidelines and the general anti-avoidance rules.
The recent developments in China's transfer pricing regime should put multinationals of all sizes and industries on notice of a rapid increase in transfer pricing enforcement activities by the SAT and local tax auditors. The documentation process should not be viewed as a purely compliance process, as it can deliver significant benefits in the long run in terms of reduced risks and identification of opportunities to lower the overall effective tax burden.
No reproduction is allowed without permission.
Dr Jian Li(Kunda Tax Consulting (Shanghai) Limited)
Jian is a Senior Partner at Kunda Tax Consulting (Shanghai) Limited with more than 15 years' experience in transfer pricing consulting. He provides transfer pricing services in the Greater China region, in both English and Chinese.


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J.B. Hunt announced today that it has received the SmartWay Excellence Award from the EPA for the ninth consecutive year.
The company and 39 other recipients were presented with their awards at the American Trucking Associations Management Conference & Exhibition on October 29. They were selected among the 3,700 organizations participating in the SmartWay program, which helps companies advance supply chain sustainability by measuring, benchmarking, and improving freight transportation efficiency.
"We are grateful to once again receive this recognition for operating with environmental excellence," said Craig Harper, executive vice president and chief operations officer at J.B. Hunt. "As a leader and innovator in this industry, J.B. Hunt will continue to invest in the technology and resources that help us further reduce our carbon footprint and improve efficiency and sustainability."
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Skepticism makes no headway here so it must in fact be a sort of naturalist religious cult.
Tag: Oumuamua
University of Maryland: Oumuamua was not an alien spacecraft
"Stick with analogs we know, you advise"? Yes, good idea. It used to be the usual approach among scientists. So why was it suddenly suspended? We are still wondering. Or maybe we know but no one wants to discuss it. See Tales of an invented god .
Why are we still talking about the Oumuamua space alien sighting panic?
Look, these people needed a miracle from outer space and it was great while it lasted. But why is the embarrassing story being kept alive? Won't another, similar one come along soon?
What? Oumuamua was just a comet? After all the ET hype?
Yeah. Sure. But let's not lose sight of the fact that it was orthodox science media (Scientific American, we are looking at you… ) who were marketing the space alien thing, not some crackpot in a tinfoil hat. And yet the same people have the nerve to sponsor reams of stuff on why "people" believe in pseudoscience.
Astronomer: We're too dumb to think space object Oumuamua was extraterrestrial lightsail
Hmmm. In the real world, when you are an only child so far as you know, it is hard to compare yourself to your siblings. Few readily accept criticism for failure to measure up to the standards of imaginary beings.
Conventional non-ET explanations for Oumuamua
ut hey, like we always say, They Will Always Be Out There if you need them to be. Also, be kind to ET. He is somebody's deity.
Why some scientists saw asteroid Oumuamua as ET
It is now in Saturn's orbit and public attention is fading but an astrophysicist reflects on colleagues seeing ET.
Did interstellar object Oumuamua normalize space aliens as science in 2018?
At least media feel freer to treat the topic that way: The turning point came in November, when Avi Loeb, the head of the astronomy department at Harvard University, co-wrote a paper saying that Oumuamua is so unusual that scientists should consider the possibility that it's not a far-out comet or asteroid, as his colleagues assumed, Read More…
Astronomers: Solar system object in transit, Oumuamua, might be a "light sail of extra-terrestrial origin"
A light sail is "a small spacecraft, propelled solely by sunlight." Interstellar object Oumuamua, was discovered 2017 while passing through our solar system. It's peculiar acceleration is explained, seriously, by a Harvard prof as an extraterrestrial spacecraft: Interestingly enough, there has also been some speculation that based on its shape, 'Oumuamua might actually be an Read More…


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- One of my favorite parts of renovations and #operationShedRehab #operationDeckRehab #operationKitchenRehab Renting the dumpster to get rid of the ruins
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Van Wolfswinkel diagnosed with brain aneurysm after suffering concussion
Ricky van Wolfswinkel will be out of action 'for a long time' as he undergoes treatment on a brain aneurysm discovered after a severe concussion in Champions League qualifying.
The Basel striker took a heavy blow to the head late in the first leg of his side's 5-2 aggregate defeat to LASK.
Van Wolfswinkel, who has won two Netherlands caps and featured regularly at youth level, was diagnosed with a concussion but sent to hospital for further testing.
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Doctors uncovered an aneurysm that otherwise would have gone undetected and the forward will now take time out from football to have treatment.
"Because of the brain aneurysm, I will need treatment. Having treatment will mean that I won't be able to play football for a long time," Van Wolfswinkel explained on Twitter.
"At this moment, we are not able to determine a date of returning. It's just clear that it won't be for at least another six months.
"The return date will of course depend on the results and the reaction of the brain aneurysm after the operation. The months after will decide when I could be back."
🏥 | Last week @RvWolfswinkel9 suffered a severe concussion. During the follow-up examination, an aneurysm in his head was discovered, which will require treatment. More info in the video #FCBasel1893 #zämmestark pic.twitter.com/KB7ocZ0WIp
— FC Basel 1893 🇬🇧 (@FC_Basel_en) August 15, 2019
While now set for an extended stint on the sidelines, the 30-year-old is simply happy his condition was disovered before it was too late.
"I'm just very grateful for the fact that the brain aneurysm got discovered now," he said.
"Normally, a brain aneurysm is not discovered on time, always too late when it has already ruptured or started damage.
"I want to say thank you to the FCB medical department and to the doctors of the university hospital in Basel.
"During the upcoming months, I will keep supporting FCB and my team-mates - like I always have. For now, I will focus on my health and my recovery to do what I love most as soon as possible - and that's to play football."
Van Wolfswinkel, who has previously represented Sporting, Norwich City, Saint-Etienne and Real Betis, as well as Vitesse and Utrecht in his homeland, scored 13 goals in the Swiss Super League last term.
Basel finished second, 21 points shy of eventual winners Young Boys, and won the Swiss Cup in May.


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Holloway Head will be one of Birmingham's largest schemes in the booming PRS sector.
The development will be sold to an institutional investor in a forward funding agreement – change to The development was sold to investment giants Invesco in Autumn 2019 n a forward funding agreement
The prestigious new development will see the regeneration of a derelict 1.3 acre brownfield site in the city centre to create 500 high quality apartments, helping to cater to the growing demand for rental property in the area.
The contemporary design features two connected 14 storey towers comprising 22 studios, 261 one-bedroom and 204 two-bedroom apartments, along with 3960 sq ft ground floor retail space, car parking and landscaped residents' courtyards.
The landmark site, just ten minutes walk from Birmingham New Street Station, has previously remained vacant for more than 25 years. Its redevelopment will continue the wider regeneration of Birmingham City Centre through the Big City Plan.
The £120 million venture will create 487 one, two and three bedroomed apartments over 17 storeys. Planning permission was granted in May 2018 and the development was sold to Invesco in September 2019 for £98.8 million.


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On Oprah Winfrey Network Television (OWN Network) tonight was the premier of the Michael Sam story.
I watched and experienced so many raw emotions through the entire documentary showing and the post documentary interview.
I also saw before my eyes confirmation of all of my LGBT societal perception thoughts.
Sexuality and societal perception can make or break a life.
The media can make or break a life.
The choices we make, the people we involve in those choices can make or break our lives.
It was such a very real, raw cycle of ups and downs watching his story play out.
I literally cried along with him.
As a pioneer within this sexual revolution by simply just being very outspoken bisexual married woman I totally identify with some of the struggles he faced in dealing with society's judgement and perceptions.
One of the biggest questions through the entire story was "Did coming out hurt his career?" We all know the answer is "Yes."
The answer is not yes because he came out alone but because of when he came out and who he came out to.
He came out to the entire world just at the pinnacle of realizing his career potential.
The world wasn't ready for his revelation.
No NFL team was ready to deal with the media attention of having the first openly gay football player on their team.
The world is not that open minded yet despite what may be 'politically correct' to say in public.
The world isn't ready to deal with married bisexual women or men.
'They' are still adjusting to gay and lesbian men and women.
The fact there are married and bisexual people is too much for some to deal with.
The fact Michael Sam is a gay man and a football player is too much for some to deal with.
Truth is 'They 'can't deal with anything that doesn't fit into the societal norms & traditional ideals laid out for us by 'them'.
Because 'they' can't identify with our lifestyles it is taboo for our lifestyles to be public or even visible.
Who is 'Them' & who is 'They'?
Why is it 'They' have so much power and control over our lives whether we allow them to or not, whether we go against the grain or not?
It seems 'They' Rule the world and we just live in it.
Why is there even an 'Us' and 'Them' thing?
Aren't we all humans?
Why does it matter what I do with my private parts?
So many questions on societal perceptions and influence were answered and arisen with this film.
It's pioneers like Michael Sam that inspire me.
It's women like Oprah with the courage to address these issues publicly that motivate me.
Keep on Michael Sam, the world will one day see you are an AWESOME football player.
Your sexuality shouldn't matter when it comes to the game.
-Jay Dee, Founder


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Above is My Video I did with BeautyCon and Absolutely Enjoyed Making it. and Then We have The Actual VLOG below.
Enjoy! My friends and I enjoyed LA so much. I hope you guys enjoy what we captured. As always, shoutout to BeautyCon I had fun. Any questions with outfit details on me or my friends, follow our instagrams or blogs (Links Down Below). @ventifashion, @thevisualaspectblog, and of course me @jonscottfashion. As always... I LOVE YOU GUYS!!
Chelsey of Venti Fashion
DeAnna of The Visual Aspect


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The as (plural asses), also assarius (rendered into Greek as ἀσσάριον, assarion)[1] was a bronze, and later copper, coin used during the Roman Republic and Roman Empire.
The Romans replaced the usage of Greek coins, first by blocks and then by disks made of bronze Aes rude.[2] The system thus named as was introduced in ca. 280 BC as a large cast bronze coin during the Roman Republic. The following fractions of the as were also produced: the bes (2/3), semis (1/2), quincunx (5/12), triens (1/3), quadrans (1/4), sextans (1/6), uncia (1/12, also a common weight unit), and semuncia (1/24), as well as multiples of the as, the dupondius (2), sestertius (2.5), tressis (3), quadrussis (4), quinarius (5), denarius (10) and aureus (250).
After the as had been issued as a cast coin for about seventy years, and its weight had been reduced in several stages, a sextantal as was introduced (meaning that it weighed one-sixth of a pound). At about the same time a silver coin, the denarius, was also introduced. Earlier Roman silver coins had been struck on the Greek weight standards that facilitated their use in southern Italy and across the Adriatic, but all Roman coins were now on a Roman weight standard. The denarius, or 'tenner', was at first tariffed at ten asses, but about 140 B.C. it was retariffed at sixteen asses. This is said to have been a result of financing the Punic Wars.
During the Republic, the as featured the bust of Janus on the obverse, and the prow of a galley on the reverse. The as was originally produced on the libral and then the reduced libral weight standard. The bronze coinage of the Republic switched from being cast to being struck as the weight decreased. During certain periods, no asses were produced at all.
Following the coinage reform of Augustus in 23 BC, the as was struck in reddish pure copper (instead of bronze), and the sestertius or 'two-and-a-halfer' (originally 2.5 asses, but now four asses) and the dupondius (2 asses) were produced in a golden-colored alloy of bronze known by numismatists as orichalcum. The as continued to be produced until the 3rd century AD. It was the lowest valued coin regularly issued during the Roman Empire, with semis and quadrans being produced infrequently, and then not at all by the time of Marcus Aurelius. The last as seems to have been produced by Aurelian between 270 and 275 and at the beginning of the reign of Diocletian.[3]
The as, under its Greek name assarion, was re-established by the Emperor Andronikos II Palaiologos (r. 1282–1328) and minted in great quantities in the first half of the 14th century. It was a low-quality flat copper coin, weighing ca. 3–4 grams and forming the lowest denomination of contemporary Byzantine coinage, being exchanged at 1:768 to the gold hyperpyron. It appears that the designs on the assarion changed annually, hence they display great variations. The assarion was replaced in 1367 by two other copper denominations, the tournesion and the follaro.[1][4]
Here are some example salaries and product costs as of the times of Diocletian in the third century AD:
United Kingdom, Italy, Germany, Rome, France
Julius Caesar, Roman Kingdom, Roman Empire, Ancient Rome, Augustus
Numismatics, Nummus, Byzantine coinage, Republic of Macedonia, Solidus (coin)
Byzantine Empire, Follis, Numismatics, Ancient Rome, Solidus (coin)
Gold, Silver, Aluminium, Nickel, Zinc
Rome, Brass, Nero, Silver, Ancient Rome
Rome, Nero, Copper, Obverse and reverse, Brass
Ancient Rome, Latin, Numismatics, As (Roman coin), Coin
Bible, Hercules, Apulia, Numismatics, Coin
1284年, 剑桥大学彼得学院


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With temperatures and positive COVID-19 cases going down, what's safe to do outside?
President Trump Taps Former Arizona PIO Stephanie Grisham As New Press Secretary
Published: Wednesday, June 26, 2019 - 1:57pm
President Donald Trump has named Stephanie Grisham as his new press secretary, replacing Sarah Huckabee Sanders.
Grisham most recently has been a top aide to First Lady Melania Trump, but her name is also familiar to many Arizona journalists. She has worked for former Attorney General Tom Horne and former Arizona House Speaker David Gowan.
Howie Fischer of Capitol Media Services joined The Show to talk more about Grisham and her move to one of the higher-profile positions in the Trump Administration.


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Generate a Solar Permit Package for a design using JA Solar JAM6-60-240/SI (240W)Sign up Learn More
With SolarDesignTool, you can create a design from scratch and generate a full PV permit package in as little as 15 minutes.
This page contains information about the JA Solar JAM6-60-240/SI (240W) solar panel. To compare this to other PV modules, click here.
DC Electrical Characteristics
- STC Power Rating 240W
- PTC Power Rating 212.9W 1
- STC Power per unit of area 13.6W/ft2 (146.8W/m2)
- Peak Efficiency 14.68%
- Power Tolerances 0%/+5%
- Number of Cells 60
- Nominal Voltage not applicable
- Imp 7.85A
- Vmp 30.56V
- Isc 8.54A
- Voc 37.49V
- Temp. Coefficient of Power -0.43%/K
- Temp. Coefficient of Voltage -0.127V/K
- Series Fuse Rating 15A
- Maximum System Voltage 1000V
Mechanical Characteristics
- Type Monocrystalline Silicon
- Output Terminal Type Multicontact Connector Type 4
- Frame Color Clear
- Backsheet Color data not available
- Length 65in (1,650mm)
- Width 39in (991mm)
- Depth 1.6in (40mm)
- Weight 43lb (19.5kg)
- Installation Method Rack-Mounted
Warranty and Certifications
- 80% Power Output Warranty Period 25yrs
- 90% Power Output Warranty Period 10yrs
- Workmanship Warranty Period 10yrs
- UL 1703 Fire Classification data not available
- Compliances UL 1703
- CSI Listed Yes
This web page is not the manufacturer's official data sheet and is not endorsed by the manufacturer in any way. For an official data sheet, please go to JA Solar's website.


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This has literally been one of those "go go go!" days where you can barely catch a breath! I woke up around 5:30, got ready and dressed for work and made myself a bowl of:
1 cup of bran flakes
1/2 cup of almond milk
1/2 of a banana
I headed out of the door for my 7-12 shift, which is short compared to my typical 6 or 8 hour shifts, and came home to prepare myself a delicious salad:
romaine/spinach mix
kidney beans
I've been thinking lately of taking a day to incorporate juices into my diet, since I did get a brand new juicer for the holidays. Hopefully I'll stumble across some delicious ones to experiment with. Any suggestions? I think it would be nice to do a juicing cleanse, especially after watching the movie "Hunger for Change" which I entirely recommend to all of the health conscious people out there. After work I went over to the post office to mail my mom her birthday surprise *she may be reading this, so I can't tell you just yet what she's getting!).
My energy was draining in my afternoon class, but luckily the gym was a nice pick me up. Cardio, arms, and leg day today. 3:30 is the worst time to go I guess because it was mobbed! And that's the worst feeling, especially for someone like me who wants to use all of the machines and a person is on every single one of them. I'm biting into my apple as I write this, procrastinating my AHN exam tomorrow 😦 although I feel rather confident, I could still use another cram session. Guess I should stop procrastinating!


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We give you an ecletic mix of 7 different looks for 7 days each week of one off vintage and specially curated pieces.
We launch these 7 looks every Friday to prepare you for the week ahead!
Buy products individually or buy the whole look its really up to you but one thing is for sure...GET IN QUICK!
Be sure to tag us #trash7looksfor7days


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Loss of Property and Stocks Due to Fire (Calculation and Illustration)!
The insured, in the event of fire accident, informs the insurer (Insurance Company) of the loss of property and stocks. The insurance contract is usually for a year and the insurer indemnifies the insured for the loss suffered.
In response to the request of the insured, a technical expert is entrusted by the Insurance Company; and the technical expert, after investigation, sends his report by stating the amount payable by the Insurance Company to the insured. His report, after a careful investigation, must reveal the causes due to which the fire broke out and whether the claim is covered by the policy or not.
Claim for Loss of Stock:
The values of assets other than stock can be ascertained at any time. The stocks with which he deals are not maintained daily. Moreover, stock-taking every day is not possible and is a very difficult job. In such a situation, one has to estimate the loss of value of stock on account of fire by preparing a statement or a Memorandum Trading Account.
The items that are needed or available are:
Step 1: First, try to know the value of opening stock of the year, in which the fire broke out.
Step 2: To the above (Step 1), add the net purchases made up to the date of fire.
Step 3: From the result of Step 2, deduct the cost of goods sold.
Step 4: From the result of Step 3, deduct the salvaged stock; and the figure finally available is the loss of stock due to fire.
The above, put in a statement, appears like this:
Calculation of Cost of Goods Sold:
The cost of goods can be found out in the following ways. Rather, the method of finding out the cost of goods sold depends upon the nature of questions.
(1) When sales figure has been given in the question along with the rate of Gross Profit, then deduct the Gross Profit from the sales in order to get the cost of goods sold.
That is:
Sales – Gross Profit = Cost of goods sold
(2) When the rate of Gross Profit on sales is given, then the
Gross Profit = Sales x Rate/100
(3) When the rate of Gross Profit on cost is given, Gross Profit is found out on the basis of sales. For instance, Gross Profit is 25% on cost, and then the sales rate is 125%. Therefore, the
Gross Profit = Sales x 25/125
(4) In certain cases, the rate of Gross Profit is not given in the problem. In such a situation, the percentage of Gross Profit on sales earned last year is applied to the current year. Therefore, by preparing a Trading Account of the previous year, the rate of Gross Profit is to be found out. This percentage of Gross Profit is applied to know the estimated Gross Profit in the current year, when the fire occurred.
It is important to note that when calculating the rate of Gross Profit, the abnormal circumstances of sales may be ignored. For instance, products, which were damaged, might have been sold at a low price or products were sold at higher price during over-demanded period. These situations may be ignored when calculating the Gross Profit.
It is also possible that the rate of Gross Profit may show an increased or decreased trend during the previous years – year by year. In such cases, weighted average of these rates can be found out and Gross Profit is estimated on the basis of weighted average.
Loss of stock can also be ascertained instead of Statement (mentioned above), by preparing a Memorandum Trading Account, to the date of fire.
This account appears as follows:
Illustration 1:
Hence, an amount of Rs 23.000 to be claimed from the Insurance Company.
Illustration 2:
A fire occurred in a small Textile Store on 15th September 2005 and considerable part of the stock was destroyed. The stock was fully insured.
The books disclosed that on 1st January 2005 the stock valued as per their business convention at a 10% above cost was shown in the books at Rs 28,567. The purchases and sales to the date of fire amounted to Rs 57,628 and Rs 93,900 respectively. The stock salvaged was agreed to be worth Rs 3,200.
During the past three years, the average Gross Profit on sales was 36%. Prepare a statement showing the amount the Textile Stores should claim from the Insurance Company in respect of stock destroyed, assuming that the Textile Stores incurred an expense of Rs 200 to extinguish the fire.
If there is any balance in the Fire Claims Account, it may be transferred to Profit and Loss Account. That is the amount of loss incurred but not recoverable from Insurance Company.


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Sue Ryder comments on Select Committee for Work and Pensions report on bereavement benefits
Today, Tuesday 22 October, the Select Committee for Work and Pensions released their report and recommendations, 'Bereavement support benefit'.
Sue Ryder previously made a submission and gave evidence after consulting with its online bereavement community and family support service.
Heidi Travis, Chief Executive at Sue Ryder, said:
"We can and must do better at supporting those coping with bereavement. The inflexibility of access, eligibility and duration of financial assistance from the Bereavement Support Payment is still acting as a barrier to people receiving support at what can be the most difficult time of their lives.
"We gave evidence to the Work and Pensions Committee in May and they took on board our comments. The fact that the Government has still failed to reverse its decision to exclude unmarried partners from the Bereavement Support Payment is simply unacceptable and inhumane.
"Bereavement can affect people in different ways; feelings of shock, overwhelming sadness, guilt or anger are completely normal. When grieving, worrying about financial matters can be unbearable. It is time for the Government to step up and do all that it can to support these people."
More information
Read the statement from the Select Committee for Work and Pensions.


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Dear Conference, below for your information is an overview of the EPA financial data for the period through June 2017.
Posted on July 13, 2017
Category: Treasurer's Office Tags:
980 Madison Avenue
Norristown, PA 19403
Ph: 800-828-9093
Fax: 610-666-9093
P.O. Box 820
Valley Forge, PA
Copyright © 2020 Eastern Pennsylvania Annual Conference of The United Methodist Church.
All Rights Reserved. Site Map
The United Methodist Church


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Classic and stylish is this Gucci Jackie-O Hobo perfect for any occasion. The timeless design is made of pink pebbled leather with golden tone hardware. The single strap is adjustable and is adorned with a golden buckle on the side. A signature golden tone piston push clasp opens to reveal an interior lined in black leather with one zipped pocket. We can always count on Gucci for styles that we will love now and later.
Made in Italy
Serial Numbers: 137335 002058
Measurements: 13"L x 8" H x 1 ½"D
Adjustable Strap Drop: 8"-9"
Made in Italy
Serial Numbers: 137335 002058
Measurements: 13"L x 8" H x 1 ½"D
Adjustable Strap Drop: 8"-9"
Condition and Shipping Cost
|Excellent condition with minimal to no signs of use.
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Handle Drop is measured from high point of the strap to bag opening.
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Class reunions are a time where you will see people that you have not seen for years. These usually happen after the school year in the summer months. Now is the time to start prepping yourself to look your best by changing some unhealthy habits to healthy ones. This is going to be a process as doing a crash diet probably will not work and it will be extremely unhealthy for your body. The following are healthy habits to follow so you look your best for your upcoming class reunion.
Bright Smile
You need to have a reliable dentist like those at Southcentre Dental to go to for a cleaning before the reunion is a great tip. Maintaining this smile will take dedication and freshly whitened teeth look a bit fake. Finding the right dentist can be tough but once you do this dentist can put you on a hygiene regimen for your type of teeth. Some people have soft teeth while others have hard so this can impact what type of maintenance that you do on your oral health.
Toning Up
If your reunion is a few months away now is the perfect time to start working out. With a few months you can slowly work your way up to some pretty intense workouts and start to tone up those problem areas you might have. If you are unsure how to tone up certain areas do research online or enlist the help of a personal trainer. A good mix of exercise can keep you from hitting a plateau and most importantly keep things interesting while exercising.
Finally Sticking To Your Meal Plan
Now is the time that you should stick to your meal plan you have set and now you have the appropriate motivation. Take the time to physically write out what you are going to eat for the week then shop accordingly. With all of the meal delivery services you can even avoid the grocery store for already prepped meals. These services can be a huge help for those people with a full schedule and not enough time to cook on a daily basis.
The one thing about the reunion is that people are going to look for those people that have aged the most. Proper skincare can leave you looking as healthy as ever but it will take a proactive approach. If you are going to want to have a tan for the reunion then it is important to slowly do this. A tanning bed is not a healthy option but rather going out in the sun consistently without being burned is. Moisturizing is important after time in the sun and use a cream to get rid of bags under your eyes. If you smoke it is time to quit as this can age you must faster than almost anything besides time.
You are going to want to look your best at your high school reunion as the reason most people go is to see how people have aged. Impress everyone with the way that you look by doing the above things!


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Get the WHOLE you in its highest vibration so your mental neural network, your nervous system, your heart and your soul's purpose are ALL in alignment
Access the wisdom of your body, heart, mind and spirit working with Catherine. She is a mental health therapist, yoga therapist, energy worker and spiritual guide.
Reach out for a free phone consultation now
Your body, your posture and your habitual movements represent the incarnation of who you are in any given moment. But how can mindful embodiment help you to represent your authentic self in the flesh and bone?
We are spiritual beings having a human experience and the universal truth of living in a mortal flesh body on planet earth unites us all. How can energy work help you tap into this connection and healing potential?
Words and images give us the power to name, create relationship, express and honor, manifest and attract. What words, sounds and images are you using to call in the highest version of yourself?
The complex web of life entails a dynamic flow of mutuality, of giving and receiving, of planting and harvesting; of offering and communion. How can intentional ritual help you break the illusions of separation and isolation to one of belonging to the larger web and to the magic of it all?
Catherine's gentle nature and lovingly crafted space create a safe, nurturing environment to find authentic energetic healing and release. Her use of pure essential oils and mindfully selected crystals add an extra layer of sweetness and soothing to this beautiful, transforming experience.
About Me
Catherine Fixe Chapin
20 years experience as a Mental Health Therapist
15 years experience as yoga instructor / body-centered therapist
Trilingual in English, French and Spanish and comfortable in multicultural dynamics
Trained in EMDR/2010, Sensorimotor Psychotherapy/2013
Member of International Association of Yoga Therapists since 2008
Bach Flower Remedies Certification - 2020 / Veronica Hidalgo Carle, Chile
Family Constellation Certification - 2020 / Angela Fontes, Mexico
Trauma-Informed Yoga Certificate 2007 / Emerson & Van Der Kolk
Certified Holistic Yoga Therapist TM 2017 / Annie Adamson
Member of Yoga Alliance since 2004 - E-200RYT/500YRT
Mindfulness Based Stress Reduction (MBSR) 2010 / Kimberly Carson
Mentorship in Spiritual Traditions of the Andes with Marcela Pantigozo, Peru / 2014 to present
Catherine started her journey as a mental health provider working with trauma and the Latino community. She herself is an immigrant with her own story and struggle of becoming bicultural and creating a new identity.
A gymnast in her youth, she discovered yoga after an abdominal surgery left her weak and depleted. Yoga helped her regain her strength and flexibility and through meditation she also opened the door to exploring her spirituality. Twenty five years later, yoga therapeutics and yoga philosophy continue to be a great source of support for her transition into the middle stage of her life.
In recent years she has been guided to reclaim and deepen her connection to earth medicine and energy work. Her spiritual practice includes meditation, creating and holding altars and ceremonies, , shamanic journeying, plant medicine and more. She is very connected to Peru and its ancient healing practices and regularly travels there to study with her teacher and visit the sacred temples and land.
My Approach
An Integrated Healing Approach:
Somatic, Emotional, Cognitive & Spiritual
I offer a unique integrative healing modality that helps you access your authentic self and breaks away the illusions so that you may manifest your full divine potential. We all have our challenges, traumas and difficulties which make us feel separate and lacking. And we also have a healing system that fragments our bodies, our emotions, our minds and our spirits while isolating individual healing from the collective and from that of our planet. I believe that you are already whole, healed and wise. In our work together, you will identify, witness, listen and befriend the parts of yourself that have gotten lost in order to rediscover the wellbeing of your united and integrated self.
In order to rewire the brain and create new patterns, the more parts of the brain we access, the stronger the pathways become. As the saying goes "neurons that fire together, wire together" and as a result, we will be using a variety of techniques to create new experiences on the physical, emotional , intellectual and spiritual realm. There are many doorways or pathways to the inner self and by honing in on a particular aspect of our being, be it bodywork; psychotherapy; energy healing; spiritual rituals; earth medicine etc we can strengthen the pathways necessary. And I also believe that it is through the integration of these pathways that we transcend a linear individual healing process and make room for the real magic to come through, a healing that is also mutual, collective and universal.
As an experienced mental health therapist, yoga therapist and energy healer, I believe that the body, heart, mind and spirit are 4 essential pathways we can use to strengthen and integrate. In a session with me, you will explore one or several of these pathways and you will restore and enhance your resiliency and your ability to bring compassion, balance and equilibrium to the present moment in honor of your complete vibrant self.
Offering you the opportunity to express your body, heart, mind and spirit to find your inner well-being.
Sessions are $108 & UP
No insurance accepted at this time.
Limited sliding scale available
"When you touch one thing with deep awareness,
you touch everything."
- Lao Tzu


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Are you ready to grab the family and have a little picnic? April 23 is National Picnic Day. And though I often plan impromptu frolics ( I know, I said plan and impromptu in the same sentence) on the lawn that might not have been on your schedule today. So here are the 5 Things You Need for an Impromptu Family Picnic Today.
I know, I know, for most people impromptu means no planning. But the impromptu portion is for the rest of the family not for you. Just imagine the looks on your families face when you tell them we're going to have a picnic outside or dinner is going to be a picnic. They'll be so excited.
We're going to make this a great family picnic. I've got your back boo!! Here are 5 Things you need for an Impromptu Family Picnic.
1. Blanket
Personally, I don't care if you don't have food. It's not a picnic without a blanket. A blanket is an essential part of a great picnic. A nice thick large blanket helps to keep you food and other items from flying away, it more comfortable to sit on and if necessary it can keep you warm. As a family of 6, I always keep a big blanket in my car. But, I also have a special blanket just for picnics.
2. Food & Beverages
Leaving my house without food or drink is a big no, no on. Food is the ultimate toddler tamer so I try to never leave home without it. For an impromptu picnic I typically keep it simple with sandwiches, chips, fruit and juice boxes. Add the foods your family loves to a your picnic bag. Whether that's chip or hot dogs. It's all about having fun.
Notice, the items I mentioned for our picnic requires no utensils or plates. If your picnic is really impromptu don't hesitate to pick something up from your local restaurant or grocery store. Just don't forget the utensils and plates.
Oh, and bring an extra bottle of water just incase you need to rinse something (or someone) off.
3.Wipes and Towels
So, funny little tidbit I drive around with paper towels in my trunk. Hey, as a mom of 4 I know there are going to be messes. And the goal is to make this picnic fun (and low stress), for my family and me. So that means eating with our hands. So there is always hand sanitizer and anti bacterial wipes on hand. It's a must because my littles love to dig in the dirt and today is all about fun so I am not going to stop them. Even if your children don't dig in the dirt anti bacterial wipes and towels are great to have if someone scrapes a knee or you need to clean something off.
4. Trash Bag
It's now glamorous, but it is necessary. Bring a trash bag to your picnic. At the end of your wonderful family time some clean up will be required. And no one likes a slob. I typically bring at least at least two trash bags with me for our picnics. One is specific for food and juice boxes and the second as a just in case.
5. Fun Activities
Don't forget to bring the fun. What do I mean by fun? Hmm, maybe Connect Four? No really you love to do as a family is what you should bring. We typically have a soccer ball or a basket ball in our car, so that's our go to family fun activity. But sometimes if I have the time (and if I remember) I dig in the "Summer Fun" basket and bring out the bubbles or a kite for our picnic.
This post contains affiliate links. Which means I may earn a commission if you click through and purchase an item. Please see our disclosure statement for more information.
So are you ready to have an impromptu picnic with the family? In the end, it's all about getting outside with the family and enjoying the day. Oh, and if the day isn't beautiful just have your picnic inside.
Happy National Picnic Day!! What's in your picnic basket?


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I mentioned I didn't get all the girls caught and put in with the bucks. I actually did better than I thought I might. I was impressed I got Hilda in with Xerxes. She was supposed to be with Zeus, but there's no way I was dragging her there. At least she's with a buck.
Still, I have four girls that I didn't get caught. After dragging Daisy across the barnyard to put with Zeus, there's no way I was trying another difficult one.
LilyAnn is in that same category. She is way too much like her big sister Vinnie. I'll get her with a buck for June.
Sidney would not have been bad to catch, but she did struggle raising her boys this year, so I thought I'd give her another copper capsule that could go just to her. We'll see if she gets a year off or if I put her with a boy for June babies.
Joani is also still looking like she needs a rest.
After all, she did raise my only set of triplets this year, and she still has Wendy with her.
Then there's Maisie. I just looked at her and decided she was fat and nasty tempered, and I was not about to deal with that while I was sick.
We'll put her with Fionn for June babies (but not in the Love Shack).


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Majid Al Futtaim shopping malls in the UAE – Mall of the Emirates and City Centres – are once again spreading the message of generosity and compassion this Ramadan with the 'Make a Difference, Together' initiative, which encourages families to come together and do good for those in need.
Now in its 13th year, the campaign, which is in partnership with UAE's Red Crescent Society, encourages visitors to donate toys, clothes and books for the less fortunate. Visitors can drop their contributions at the malls' donation boxes throughout the holy month of Ramadan.
"Ramadan is a time of compassion in action. Our 'Make a Difference, Together' campaign, which we have been committed to for more than a decade with UAE's Red Crescent Society, gives visitors the opportunity to show compassion by coming together and bringing smiles to the faces of those in need," says Fuad Mansoor Sharaf, managing director for Majid Al Futtaim Properties, Shopping Malls (UAE, Bahrain & Oman).
"Our initiative also aims to encourage parents to instill the value of giving rather than receiving and to create a new ritual of donation together, as a family. We encourage parents to select items that they would like to donate with their children so that they are part of the process and create great moments together this Ramadan," he adds.
The malls will also be transformed with elegant, traditional décor to mark the holy month. Visitors are invited to enjoy the soothing and spiritual ambiance and participate in cultural activities all through the month. The sparkling cultural symbols hanging from the ceiling and bright arabesque motifs that adorn every corner of the malls reflect the spirit of peace, tranquillity and hospitality during the holy month.


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Choosing to leave your marriage will be one of the most difficult decisions you will ever have to make in your life. Don't try and sort through the question, doubt and fear alone.
Hire me as your "thinking partner". My job is to help you focus on "right now" and getting you to realize what it is you truly want. My number one goal is for you to look back, only once, and recognize that you made the right choices for your best outcome with your integrity intact and your heart, healed or on it's way!
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