Unitary taxation : The case for global formulary apportionment

Unitary taxation is the taxation of the worldwide income of a multinational enterprise (MNE) and is normally based on a formulary apportionment method, which allocates income to the relevant jurisdictions based on a percentage of the MNE's world-wide profits. The unitary taxation model has several advantages over the existing arm's length model: 1. Where MNEs are highly integrated, unitary taxation has greater consistency with economic reality. 2. Greater certainty is provided to taxpayers. 3. Unitary taxation conforms to the aim of efficient operations within the MNE. 4. The aim of unitary taxation, to find an equitable split of profits between the jurisdictions, should ultimately be the overall aim of any tax regime. The advantages and disadvantages associated with the adoption of a unitary taxation model through the implementation of a formulary apportionment approach to the taxation of MNEs are examined.

'Black international business': Critical issues and ethical dilemmas

In this chapter, we explore the 'darker' faces of international business (IB). Over a decade ago, Eden and Len way (2001) raised the need for examining both the 'bright' and the 'dark' side of globalization in order to achieve a better understanding of the concept and of its impact on IB activities. In doing this, they posited the multinational enterprise (MNE) as the 'key agent' and 'f.1ee' of globalization and discussed, primarily, the relationship between MNEs and nation-states as the central interf.1ce of its impact. Additionally, they posited that, by and large, the community of IB scholars positioned themselves at the bright end of the globalization spectrum, seeing it as essentially positive, whilst most non-governmental organizations (NGOs) and international political economy (IPE) academics set themselves at the dark end. Whilst they acknowledged their own 'bright side' tendencies, they called for a more nuanced consideration of MNEs as what they referred to as the Janus bee' of globalization.

Multiple roles of transfer prices: One vs. two books

This paper investigates multiple roles of transfer prices for shipments of goods and services between entities of a multinational enterprise. At the center is the role of transfer pricing (TP) in tax manipulation, but other roles having to do with internal operations or strategic delegation, etc. are also considered. The interesting question is to what extent and how the different roles of TPs interfere with each other. The answer depends on whether companies use one or two books, i.e. whether they (can) apply different TPs for different purposes. We illustrate, in a stylized model, the competing aims of tax manipulation and strategic delegation. Finally, we briefly look at selected reform proposals, concluding that either TP problems are not addressed, or else new distortions will be introduced instead.

Using performance measurement models for benefit realization with enterprise systems: The Queensland Government approach (Case Study)

A range of influences, technical and organizational, has encouraged the wide spread adaption of Enterprise Systems (ES). Nevertheless, there is a growing consensus that Enterprise Systems have in the many cases failed to provide the expected benefits to organizations. This paper presents ongoing research, which analyzes the benefits realization approach of the Queensland Government. This approach applies a modified Balance Scorecard. First, history and background of Queensland Government’s Enterprise Systems initiative is introduced. Second, the most common reasons for ES under performance are related. Third, relevant performance measurement models and the Balanced Scorecard in particular are discussed. Finally, the Queensland Government initiative is evaluated in light of this overview of current work in the area. In the current and future work, the authors aim to use their active involvement in Queensland Government’s benefits realization initiative for an Action Research based project investigating the appropriateness of the Balanced Scorecard for the purposes of Enterprise Systems benefits realization.

Contemplating Open Source Enterprise Systems

Until recently, integration of enterprise systems has been supported largely by monolithic architectures. From a technical perspective, this approach has been challenged by the suggestion of component-based enterprise systems. Lately, the nature of software as proprietary item has been questioned through the increased use of open source software in business computing in general. This suggests the potential for altered technological and commercial constellations for the design of enterprise systems, which are presented in four scenarios. © Springer-Verlag 2004.

Identifying the knowledge management structures in enterprise systems projects

Enterprise System (ES) implementation and management are knowledge intensive tasks that inevitably draw upon the experience of a wide range of people with diverse knowledge capabilities. Knowledge Management (KM) has been identified as a critical success factor in ES projects. Despite the recognized importance of managing knowledge for ES benefits realization, systematic attempts to conceptualize KM-structures have been few. Where the adequacy of KM-structures is assessed, the process and measures are typically idiosyncratic and lack credibility. Using the ‘KM-process’, itself based in sociology of knowledge, this paper conceptualizes four main constructs to measure the adequacy of KM-structures. The SEM model is tested using 310 responses gathered from 27 ES installations that had implemented SAP R/3. The findings reveal six constructs for KM-structure. Furthermore, the paper demonstrates the application of KM-structures in the context of ES using the Adaptive Structuration Theory. The results demonstrate that having adequate KM-structures in place, while necessary, is not sufficient. These rules and resources must be appropriated to have greater positive influence on the Enterprise System. Furthermore, the study provides empirical support for knowledge-based theory by illustrating the importance of knowledge use/re-use (vs. knowledge creation) as the most important driver in the process of KM.