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.

Labour flexibility and gender in the service sector: A study of employment practices in law and accounting firms

In seeking to increase the flexibility of their use of employee time, employers can pursue strategies based on the employment of casual and part-time workers (numerical flexibility) or strategies based on ad hoc variation of the working hours of permanent employees (working time flexibility). Patterns of flexibility strategies and their implications are examined in the context of a highly feminised sector of work-clerical and administrative employment in law and accounting firms. We consider whether, as is often assumed, working time flexibility strategies are generally better for employees because they avoid the substitution of core, high quality jobs with the peripheral, relatively insecure employment often associated with casualisation. Analysing data drawn from a survey of law and accounting firms, we argue that there are three distinct flexibility strategies adopted by employers, and that the choice of strategy is influenced by the size of the firm and the extent of feminisation. The quality of employment conditions associated with each strategy is investigated through an analysis of the determinants of training provision for clerical and administrative workers. Rather than an expected simple linear relationship between increasing casualisation and decreasing training provision, we find that firm size and feminisation are implicated. Larger firms that tend to employ at least some men and use a combination of working time and numerical flexibility strategies tend to provide more training than the small, more fully feminised firms that tend to opt for either casualisation or working time flexibility strategies. This suggests that, from an employee perspective, working time flexibility may not be as benevolent as is often thought.

Long-run growth effects of taxation in a non-scale growth model with innovation

In previous studies, taxing income or consumption hinders long-run growth. Incorporating saving and leisure into the non-scale Schumpeterian model of [Journal of Political Economy 107 (1999) 715-730], we show that the usual growth effects of taxing consumption and labor income do not exist. (C) 2002 Elsevier Science B.V. All rights reserved.

A reduced load approximation accounting for link interactions in a loss network

This paper is concerned with evaluating the performance of loss networks. Accurate determination of loss network performance can assist in the design and dimen- sioning of telecommunications networks. However, exact determination can be difficult and generally cannot be done in reasonable time. For these reasons there is much interest in developing fast and accurate approximations. We develop a reduced load approximation that improves on the famous Erlang fixed point approximation (EFPA) in a variety of circumstances. We illustrate our results with reference to a range of networks for which the EFPA may be expected to perform badly.