Case study analysis of a Destination Marketing Organisation (DMO)
Our company, the ARCHTYPE GROUP (or “the GROUP”) is one of the leading multinational company within the Architecture industry, being one of the largest private construction consultancies in Europe, Asia and America with core services in Architecture & Master Planning, Building & Infrastructure Engineering, Industrial & Process Engineering and Project, Construction & Cost Management. The GROUP was founded in Mexico and covers key construction sectors such as buildings & real estate, industry & manufacturing and energy & infrastructure. Since 2012, the GROUP has been involved in many prestigious real estate projects on a worldwide basis.
ARCHTYPE GROUP has now increased to more than 250 employees following the acquisition of local architecture firms in different countries, firms that were already well-known for its work in this sector. As of today, ARCHTYPE GROUP has 12 offices including subsidiaries all over the world, with 40 employees in Mexico City (Mexico), 20 in its subsidiary in Amsterdam (The Netherlands), 20 in Birmingham (UK), 20 in Rome (Italy), 25 in Abu Dhabi (UAE), 30 in Singapore (Singapore), among others.
Currently the GROUP is recognized as a leading service provider within the LATAM region, Canada and the US and its core business in those specific regions are (i) architecture design services of hotel and real estate projects, (ii) consulting services on architecture and design (interior design and lighting design), (iii) sale of architecture and design components, (iv) rental services of design software developed by the Group; and, (v) rental services of highly specialised machinery.
During these two last years, most of the clients pay the ARCHTYPE GROUP for three specific services:
1) A royalty for technical advice and rental of design software;
2) a fee for provision of consulting services; and,
3) a monthly rent for machines they need to rent for the development of their projects.
As part of its business strategy, the GROUP has incorporated a subsidiary based in Paris (France). After some months of work, the subsidiary is extremely excited to initially engaged a new client, which will be the first client in Colombia, a country with excellent real estate/urban planning projects and consulting services prospects.
This is the first month that the GROUP´s Paris subsidiary is invoicing new clients with the 3 services described above, and it turns out that there is a withholding tax in Colombia for the 3 services provided by the GROUP (e.g., technical advice and software’ fee, consulting services; and, monthly rent of equipment).
The truth is that ARCHTYPE GROUP colleagues in Paris should have consulted a tax specialist before entered into a contract with this new client, but unfortunately, they did not do so. The execution of these services is having a financial impact for the operating income of the Paris subsidiary, a fact that is concerning the.
Currently, after a further discussion within the ARCHTYPE GROUP tax advisors, they are thinking about to incorporate a Spanish subsidiary to handle the provision of services of LATAM and US and Canada clients because it may help to optimize the business structure from an overall tax perspective:
1) The ARCHTYPE GROUP has executed relevant transactions from a tax perspective:
a) Which are those relevant transactions and why those shall be further analysed?
b) Which are the legal instruments that shall be considered before executing an international transaction from a tax perspective?
2) If ARCHTYPE GROUP had thought more carefully, and execute the different 3 type of services from the Spanish subsidiary instead of Paris with their Colombian clients:
a) How would the withholding tax have applied (or not applied)?
b) Are there any tax benefits in business negotiations between the Spanish subsidiary and the Colombian client instead of the Paris subsidiary?
c) What would the Spanish subsidiary have had to do to avoid this withholding tax?
3) The Dutch holding company ARCHTYPE HOLDINGS N.V. is the 100% owner of the European subsidiaries (including of course the Spanish and Paris subsidiaries).
a) What is the tax treatment of the dividends flowing from the Paris subsidiary into the Dutch holding company?
b) Is there any difference between the tax treatment of the dividends flowing from the Spanish subsidiary into the Dutch holding company? What is the parent-subsidiary directive?
Questions also answered
Now more than ever, music has become a democratic tool that has been used for political, cultural, and social equality. It is evident that music is changing as society changes, an indicator that the tool is in tandem with democracy.
A Gallup poll of 1236 adults showed that 12% of the respondents believe that it is bad luck to walk under a ladder. Consider the probability that among 30 randomly selected people from the 1236 who were polled, there are at least 2 who have that belief. Given that the subjects surveyed were selected without replacement, the events are not independent. Can the probability be found by using the binomial probability formula? Why or why not?
Unit 2 Discussion: Probability and Probability Distributions
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Pirated Software
Pirated software is the use of software that allows others to copy, distribute, and operate other programs. Pirated software is an ethical issue due to digital theft and denying another individual who has rightfully designed a life out of software development (Cascavilla et al., 2021). The consequences of using pirated software are that other software developers have been led to legal risks owing to the respective demands of their users. This paper focuses on determining how pirated software is an ethical issue when marketing connected devices.
Volkert, D., Candela, L., & Bernacki, M. (2018). Student motivation, stressors, and intent to leave nursing doctoral study: A national study using path analysis. Nurse Education Today, 61, 210–215. https://doi.org/10.1016/j.nedt.2017.11.033
Part I: Comprehension
Introduction
· Yes, the authors are qualified as all of them are scholars and teach at various universities, such as the University of West Georgia and the University of Nevada in the Department of Nursing and psychology, which are relevant to the study.
Germany
Germany is one of the largest countries in Europe by land mass; this has largely contributed to its popularity, making it one of the most known countries of the Nordic region. Besides being populous, the country enjoys the largest economy in Europe, which is mainly driven by three sectors: agriculture, service, and industry sectors. The country's large portion of the population is middle-income and is largely contributed by the service, industry, and agriculture sectors. Ever since its unification in the 20th century, the country has seen numerous politically motivated events that have seen the country be plunged into the First and Second World Wars, with the latter leaving the country divided between two political ideologies. The focus of this paper is to determine how culture, legislation, economic and political systems have impacted the conduction of business in the country.
The manager should not be allowed to disclose the information of a tenant as the latter has a reasonable expectation of privacy unless the information is relevant in regard to the safety of other tenants (Porro, 2019). Thus, the manager should ensure that other tenants follow through with the directive and not have their indifferences determine their tenancy. In summation, the manager should withhold the information to prevent others from having access to it and should accord the new applicant as a potential tenant who has no bearing in regard to political indifferences that have caused a rift between the two parties.
Policy topic: GUN CONTROL
Directions: Do some research and find 3 existing or proposed recent U.S. policies (laws, statutes, etc.) published or proposed on this topic. Do not describe policies proposed/implemented prior to 2000. In addition to a brief description of the policy, you will also indicate the stance (for or against), level of implementation, and provide a link to the actual policy.
Policy 1
Policy name (Precise bill/policy/legislation name): Bipartisan Safer Communities Act (BSCA) gun safety bill.
Policy link (Include a direct link to the policy. Do not use Wikipedia, news articles, etc. Go directly to the source for information): https://www.whitehouse.gov/briefing-room/statements-releases/2023/03/14/fact-sheet-president-biden-announces-new-actions-to-reduce-gun-violence-and-make-our-communities-safer/
A multicultural workplace has become a trend rather than an exception in many organizations. In the worldwide community where every organization strives to contribute, and this stage of profound globalization is unfolding. Organizations that do not adapt to diversity in its workplace will have difficulty staying competitive (Tamn et al., 2019). Over the past two decades, companies have appreciated employee diversity as crucial to economic sustainability (Shah et al., 2021). Diversity at the workspace is of priceless value, because it coalesces numerous latent capabilities and experiences, ultimately optimizing efficiency and effectiveness of the whole organization (Inegbedion and his colleagues, 2020).
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