676 resultados para dynamic pricing policy


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China has experienced an extraordinary level of economic development since the 1990s, following excessive competition between different regions. This has resulted in many resource and environmental problems. Land resources, for example, are either abused or wasted in many regions. The strategy of development priority zoning (DPZ), proposed by the Chinese National 11th Five-Year Plan, provides an opportunity to solve these problems by coordinating regional development and protection. In line with the rational utilization of land, it is proposed that the DPZ strategy should be integrated with regional land use policy. As there has been little research to date on this issue, this paper introduces a system dynamic (SD) model for assessing land use change in China led by the DPZ strategy. Land use is characterized by the prioritization of land development, land utilization, land harness and land protection (D-U-H-P). By using the Delphi method, a corresponding suitable prioritization of D-U-H-P for the four types of DPZ, including optimized development zones (ODZ), key development zones (KDZ), restricted development zones (RDZ), and forbidden development zones (FDZ) are identified. Suichang County is used as a case study in which to conduct the simulation of land use change under the RDZ strategy. The findings enable a conceptualization to be made of DPZ-led land use change and the identification of further implications for land use planning generally. The SD model also provides a potential tool for local government to combine DPZ strategy at the national level with land use planning at the local level.

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Each year the Australian Federal Treasury releases its Tax Expenditures Statement providing details of concessions, benefits, and incentives delivered through the tax regime to Australian taxpayers. The current Tax Expenditures Statement, released on 25 January 2008, lists approximately 300 tax expenditures and reports on the estimated pecuniary value in terms of revenue foregone, estimated to be a total of $50.12 billion for the 2006-07 financial year. Apart from the annual Tax Expenditures Statement, and despite the recurring fiscal impact, there is very little other scrutiny of Australia’s Federal tax expenditures program. This is despite tax expenditures often being seen as an alternative to direct expenditures with similar impact on the Federal budget. The object of tax expenditures is to provide government assistance and meet government objectives, and, as such, tax expenditures are departures from the revenue raising aspect of the tax regime. Within this context, this article examines the fundamental concept of tax expenditures as contrasted with direct expenditures and considers the role they play in the current tax regime.

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The taxation of multinational banks currently is governed by the general principles of international tax. However, it is arguable that there are characteristics exclusive to multinational banks that may warrant the consideration of a separate taxing regime. This article argues that because of the unique nature of multinational banks, the traditional international tax rules governing jurisdiction to tax and allocation of income do not produce a result which is optimal, as it does not reflect economic reality. That is, the current system does not produce a result that accurately reflects the economic source of the income or the location of the economic activity. The suggested alternative is unitary taxation using global formulary apportionment. Formulary apportionment is considered as an alternative that reflects economic reality by recognising the unique nature of multinational banks and allocating the income to the location of the economic activity. The unique nature of multinational banking is recognised in the fact that formulary apportionment does not attempt to undertake a transactional division of a highly integrated multinational entity. Rather, it allocates income to the jurisdictions based on an economically justifiable formula. Starting from this recognition, the purpose of this article is to demonstrate that formulary apportionment is a theoretically superior (or optimal) model for the taxation of multinational banks. An optimal regime, for the purposes of this article, is considered to be one that distributes the taxing rights in an equitable manner between the relevant jurisdictions, while, simultaneously allowing decisions of the international banks to be tax neutral. In this sense, neutrality is viewed as an economic concept and equity is regarded as a legal concept. A neutral tax system is one in which tax rules do not affect economic choices about commercial activities. Neutrality will ideally be across jurisdictions as well as across traditional and non-traditional industries. The primary focus of this article is jurisdictional neutrality. A system that distributes taxing rights in an equitable manner between the relevant jurisdictions ensures that each country receives its fair share of tax revenue. Given the increase in multinational banking, jurisdictions should be concerned that they are receiving their fair share. Inter-nation equity is concerned with re-determining the proper division of the tax base among countries. Richard and Peggy Musgrave argue that sharing of the tax base by countries of source should be seen as a matter of inter-nation equity requiring international cooperation. The rights of the jurisdiction of residency will also be at issue. To this extent, while it is agreed that inter-nation equity is an essential attribute to an international tax regime, there is no universal agreement as to how to achieve it. The current system attempts to achieve such equity through a combined residency and source regime, with the transfer pricing rules used to apportion income between the relevant jurisdictions. However, this article suggests, that as an alternative to the current regime, equity would be achieved through formulary apportionment. Opposition to formulary apportionment is generally based on the argument that it is not a theoretically superior (or optimal) model because of the implementation difficulties. Yet these are two separate issues. As such, this article is divided into two core parts. The first part examines the theoretical soundness of the formulary apportionment model concluding that it is theoretically superior to the arm’s length pricing requirement of the traditional transfer pricing regime. The second part examines the practical implications of accepting formulary apportionment as an optimal model with a view to disclosing the issues that arise when a formulary apportionment regime is adopted. Prior to an analysis of the theoretical and practical application of formulary apportionment to multinational banks, the unique nature of these banks is considered. The article concludes that, while there are significant implementation, compliance, and enforcement issues to overcome, the unitary taxation model may be theoretically superior to the current arm’s length model which applies to multinational banks. This conclusion is based on the unitary taxation model providing greater alignment with the unique features of these banks.

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The current transfer pricing rules contained in Australia’s taxation regime are designed to counter the underpayment of tax by businesses engaged in international related-party dealings. Currently, these transactions must take place at an arm’s length price, a requirement which is becoming increasingly difficult to demonstrate. This results in an increased risk of an audit by the Australian Taxation Office. If a taxpayer wishes to avoid the risk of an audit, and any ensuing penalties, there is one option: an advance pricing arrangement (‘APA’). An APA is an agreement whereby the future transfer pricing methodology to be used to determine the arm’s length price is agreed to by the taxpayer and the relevant tax authority or authorities. This article investigates the use of APAs as a solution to the problem of transfer pricing and considers their impact on stakeholders. It is argued that while APAs provide a valuable practical tool for multinational entities facing the challenges of the taxation of global trading under the current regime, they may not be a practical long term solution.

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This book is an empirical study of strategic management practices in the construction industry. It examines the dynamic capabilities paradigm within the context of the Indonesian construction industry. The characteristics of asset-capability combinations were found to be significant determinants of the competitive advantage of the Indonesian construction enterprises, and that such advantage sequentially contributes to organizational performance. In doing so, this study fills an important gap in the empirical literature and reinforces the dynamic capabilities framework’s recognition as a rigorous theory of strategic management. As the dynamic capabilities framework can work in the context of Indonesia, it suggests that the framework has potential applicability in other emerging and developing countries

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Effective enterprise information security policy management requires review and assessment activities to ensure information security policies are aligned with business goals and objectives. As security policy management involves the elements of policy development process and the security policy as output, the context for security policy assessment requires goal-based metrics for these two elements. However, the current security management assessment methods only provide checklist types of assessment that are predefined by industry best practices and do not allow for developing specific goal-based metrics. Utilizing theories drawn from literature, this paper proposes the Enterprise Information Security Policy Assessment approach that expands on the Goal-Question-Metric (GQM) approach. The proposed assessment approach is then applied in a case scenario example to illustrate a practical application. It is shown that the proposed framework addresses the requirement for developing assessment metrics and allows for the concurrent undertaking of process-based and product-based assessment. Recommendations for further research activities include the conduct of empirical research to validate the propositions and the practical application of the proposed assessment approach in case studies to provide opportunities to introduce further enhancements to the approach.

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The search for new multipoint, multidirectional strain sensing devices has received a new impetus since the discovery of carbon nanotubes. The excellent electrical, mechanical, and electromechanical properties of carbon nanotubes make them ideal candidates as primary materials in the design of this new generation of sensing devices. Carbon nanotube based strain sensors proposed so far include those based on individual carbon nanotubes for integration in nano or micro elecromechanical systems (NEMS/MEMS) [1], or carbon nanotube films consisting of spatially connected carbon nanotubes [2], carbon nanotube - polymer composites [3,4] for macroscale strain sensing. Carbon nanotube films have good strain sensing response and offer the possibility of multidirectional and multipoint strain sensing, but have poor performance due to weak interaction between carbon nanotubes. In addition, the carbon nanotube film sensor is extremely fragile and difficult to handle and install. We report here the static and dynamic strain sensing characteristics as well as temperature effects of a sandwich carbon nanotube - polymer sensor fabricated by infiltrating carbon nanotube films with polymer.

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This series of research vignettes is aimed at sharing current and interesting research findings from our team and other international Entrepreneurship researchers. In this vignette, Professor Helene Ahl from Jonkoping University considers the consequences for gender equality of policy for women's entrepreneurship in two countries with distinctly different welfare state regimes.

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This article examines the current transfer pricing regime to consider whether it is a sound model to be applied to modern multinational entities. The arm's length price methodology is examined to enable a discussion of the arguments in favour of such a regime. The article then refutes these arguments concluding that, contrary to the very reason multinational entities exist, applying arm's length rules involves a legal fiction of imagining transactions between unrelated parties. Multinational entities exist to operate in a way that independent entities would not, which the arm's length rules fail to take into account. As such, there is clearly an air of artificiality in applying the arm's length standard. To demonstrate this artificiality with respect to modern multinational entities, multinational banks are used as an example. The article concluded that the separate entity paradigm adopted by the traditional transfer pricing regime is incongruous with the economic theory of modern multinational enterprises.

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Australia’s domestic income tax legislation and double tax agreements contain transfer pricing rules which are designed to counter the underpayment of tax by businesses engaged in international dealings between related parties. The current legislation and agreements require that related party transactions take place at a value which reflects an arm’s length price, that is, a price which would be charged between unrelated parties. For a host of reasons, it is increasingly difficult for multinational entities to demonstrate that they are transferring goods and services at a price which is reflective of the behaviour of independent parties, thereby making it difficult to demonstrate compliance with the relevant legislation. Further, where an Australian business undertakes cross-border related party transactions there is the risk of an audit by the Australian Tax Office (ATO). If a business wishes to avoid the risk of an audit, and any ensuing penalties, there is one option: an advance pricing arrangement (APA). An APA is an agreement whereby the future transfer pricing methodology to be used to determine the arm’s length price is agreed to by the taxpayer and the relevant tax authority or authorities. The ATO views the APA process as an important part of its international tax strategy and believes that there are complementary benefits provided to both the taxpayer and the ATO. The ATO promotes the APA process on the basis of creating greater certainty for all parties while reducing compliance costs and the risk of audit and penalty. While the ATO regards the APA system as a success, it may be argued that the implementation of such a system is simply a practical solution to an ongoing problem of an inherent failure in both the legislation and ATO interpretation and application of this legislation to provide certainty to the taxpayer. This paper investigates the use of APAs as a solution to the problem of transfer pricing and considers whether they are the success the ATO claims. It is argued that there is no doubt that APAs provide a valuable practical tool for multinational entities facing the challenges of the taxation of global trading under the current transfer pricing regime. It does not, however, provide a long term solution. Rather, the long term solution may be in the form of legislative amendment.

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This article sketches some of the ways in which the language and concepts of cultural diversity are being taken up internationally. The debate has been driven in part by concerns about the treatment of cultural goods, services and knowledge in trade agreements. But it also involves larger questions about the role of the state, the role of non-state actors in domestic policy formation, and the shape and function of international policy communities comprising both state and non-state actors. The extent of the discussion of cultural diversity internationally is described through new formal and informal cultural networks and work towards an international instrument for cultural diversity to lay our ground rules for international trade, cultural exchange and policy principles to guide governmental responsibilities. The article concludes with analysis of some of these new networks, and investigates why Canada has been so prominent in these international efforts.

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Over the last twenty years or so, Australian cinema's international relations in production and policy have expanded and become more complex, while those with Hollywood have been transformed. The boundaries of the national cinema stretch much further than the national territory. Australian production and postproduction companies work in Australia with international partners or on international projects. In this article I will trace some of the material and discursive entailments of this new international turn to explore how dynamic and shifting relations between the local/national and the international have transformed the ways in which we might think about what constitutes Australian cinema, and to illustrate how relations of commonality and continuity with the international called up in the new arrangements challenge the dominant articulation in policy of difference from 'other kinds of filmmaking' as the basis of Australian cinema. I draw on Deb Verhoeven's work on simultaneously national and international films and filmmakers, and adapt Doreen Massey's concept of 'outwardlookingness' to consider Australian cinema's international aspects.