The traditional rationale of the arm’s length approach to transfer pricing : should the separate accounting model be maintained for modern multinational entities?

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.

Four years on – are the Gazelles still running? A longitudinal study of firm performance after a period of rapid growth

Gazelles, or very rapidly growing firms, are important because they contribute disproportionately to economic growth. There is a concern that some of these firms pursue growth too aggressively resulting in lower subsequent performance. We investigate the relationship between growth and subsequent profitability for gazelle firms, and how this is moderated by firm strategy. Previous empirical research regarding the growth-profitability relationship for firms in general is rather inconclusive, with only one study specifically investigating gazelle firms. Likewise, there are theoretical arguments both for and against growth leading to profitability that equally apply to gazelle firms. Further, while contingency theory might suggest the relationship depends on the firm’s strategy, earlier studies have not investigated this relationship. We address these questions using longitudinal data (seven years) for a sample of 964 Danish Gazelle firms. Our study finds a clear positive relationship between growth and subsequent profitability among gazelle firms. Moreover, this relationship is stronger for firms pursuing a broad market strategy rather than a focus or niche strategy. An important managerial implication is that the growth strategy should be clearly integrated with the general strategic orientation of the firm.

Taxation of multinational banks : using formulary apportionment to reflect economic reality

The taxation of multinational banks is currently governed by general principles of international tax. However, there are characteristics exclusive to multinational banks that may warrant consideration of a separate taxing regime, as 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.

An Econometric Analysis of Inter-Firm Labour Mobility

This paper utilizes the Survey of Work History (1981) data to examine the importance of non-random sampling in the context of a model of interfirm labour mobility. The paper adopts Heckman's two-step procedure in order to estimate a three-equation model incorporating an individual's mobility status as endogenously determined. The main conclusion is that in estimating wage equations it is important to consider the role of job mobility and to correct for the effects of sample-selection bias. The results generally accord with those reported by Osberg et al. (1986) in the only previous Canadian study of job mobility in a sample-selection context.

Multiple founders and firm value

In this paper, we highlight the existence of multi-founder firms, which were founded by multiple individuals (with no family connections) who are still actively involved in the firm as directors and/or managers. These firms provide a unique setting to shed further light on the net valuation effects of founder involvement. In particular, multi-founder firms provide us with the opportunity to examine the benefits and costs to shareholders of multiple founders involved as directors, CEOs and managers in the same firm. Our analysis indicates that multi-founder firms are more valuable than all other types of firms, including single-founder firms and family firms, with the valuation premium positively related to the number of founders involved in the firm. Further analysis confirms that this valuation premium is linked to the direct involvement of the multiple founders as directors and CEOs. However, further founder involvement in vice president positions has a negative relationship with firm value.

Waving or drowning? Managing resource constraints in entrepreneurial firm with bricolage as a response to the global financial crisis

These are challenging times for new entrepreneurial firms. The development of the Global Financial Crisis shook the very foundations of global markets and institutions that most firms relied on to do business (Claessens, et al., forthcoming). In the midst of institutional flux and resource constraints, entrepreneurial firms, which have been shown to make a range of contributions to the economy (van Praag & Versloot 2007) faced increasing constraints. The Australian Federal Government quickly implemented the Green Loan program in response to the financial crisis. Unfortunately, the green loans program was flawed with obsolete processes and information (Faulkner, 2011), further constraining new firms. Prior research provides few clues regarding how resource-constrained entrepreneurial firms deal with these institutional flaws within institutional change and how they might overcome these challenges and prosper. One promising theory that evaluates behavioural responses to constraints and institutional flaws is bricolage (Levi Strauss, 1967). Bricolage aligns with notions of resourcefulness: defined here as “making do by applying combinations of the resources at hand to new problems and opportunities” (Baker and Nelson 2005: 333). Using three case studies, we consider how institutional flaws impact firm behaviours and illustrate the use of bricolage in attempts to reinforce, shape and change the GL program further extending bricolage domains of Baker and Nelson (2005).

Multinational contracting into Australia: Developing Dunning's theory and case study design

In response to the need to leverage private finance and the lack of competition in some parts of the Australian public sector infrastructure market, the Australian Federal government has demonstrated its desire to attract new sources of in-bound foreign direct investment (FDI) by multinational contractors. This study aims to update progress towards an investigation into the determinants of multinational contractors’ willingness to bid for Australian public sector major road and bridges. This research deploys Dunning’s eclectic theory for the first time in terms of in-bound FDI by multinational contractors into Australia. Elsewhere, the authors have developed Dunning’s principal hypothesis to suit the context of this research and to address a weakness arising in this hypothesis that is based on a nominal (yes or no) approach to the ownership, location and internalisation factors in Dunning's eclectic framework and which fails to speak to the relative explanatory power of these factors. The authors have completed a first stage test of this development of Dunning's hypothesis based on publically available secondary data, in which it was concluded tentatively that the location factor appears to have the greatest explanatory power. This paper aims to present, for the first time, a further and novel development of the operation of Dunning's eclectic paradigm within the context of multinational contracting, as well as a preview of the design and planned analysis of the next empirical stage in this research concerning case studies. Finally, and beyond the theoretical contributions expected, other expected contributions are mentioned concerning research method and practical implications.

The relationship between firm survival and innovation : an introduction to the literature

The rapid growth in use of the Internet as a business tool provides a new perspective in the study of the organizational challenges of new technologies. The innovation literature has grown vastly since its establishment in the 1920s, covering a broad range of disciplines (Foxall 1984) and measures a wide variety of variables (Rogers 1995). At first glance, studies that look at the relationship between innovation and firm survival appear contradictory. However, the results appear compatible when additional factors, such as industry type, organizational age, company size or the duration of the study are taken into account.

The role of knowledge intermediaries in developing firm learning capabilities

Regional innovation systems (RISs) literature has emphasized the critical role of interactive learning and knowledge exchange amongst firms and a variety of spatially connected innovation institutions as the foundation of regional innovation. Knowledge intermediaries have been analysed in terms of the technology-transaction services they provide firms and/or knowledge producers such as universities and therefore the role they play in facilitating interaction within the RIS. However, innovation also depends on the capability of the firm to learn. Some studies have suggested that intermediaries also play a role in that regard as participation in intermediary knowledge transfer programmes can contribute to the development of firm capabilities for problem-solving and learning. Our research is based on two case study intermediary programmes involving interviews with facilitators and participants. Our data show that knowledge intermediaries affect organizational learning capabilities by impacting on firms' network relationships, internal and external communication channels and internal learning processes which in turn affect the ability to interpret and use knowledge within the firm. This suggests that the role of knowledge intermediaries might be greater than facilitating interactions in the innovation system, as knowledge intermediation may affect the ability of firms to learn and absorb knowledge from their environment.

International entrepreneurship for SME business growth : a resource and dynamic capability view of the firm : an internet context

This research explores the relationship between international business Internet capabilities and international entrepreneurial characteristics. It has been suggested, that the accumulation of a firms Internet capability can assist international operations, especially when operating in fast changing dynamic environments. However, the international entrepreneurial characteristics which are seen as a precursor to leveraging such capabilities are still vague. Given this finding a conceptual framework is constructed and research issues are then developed in order to focus attention on the relationship between the Internet and a firm’s resource base, dynamic capabilities and international market performance.

ACE research vignette 023 : Does firm location make a difference to the export performance of SME's?

This series of research vignettes is aimed at sharing current and interesting research findings from our team of international Entrepreneurship researchers. This vignette, written by Mr. Darren Kavenagh and Professor Per Davidsson, deals with export capacity of Australian SMEs.

ACE research vignette 024 : New firm formation and job creation by type of firm an type of region.

This series of research vignettes is aimed at sharing current and interesting research findings from our team of international Entrepreneurship researchers. This vignette, written by Mr. Darren Kavanagh and Professor Per Davidsson, takes a closer look at job creation by new firms.