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.

Career research in a post-modern era

In recent years, career theory and practice has been challenged to revise and reinvigorate itself in order to remain relevant in the post- modern world. The most fundamental challenge is to produce an identity for career practice that is congruent with the post-modern world. Career research is facing a similar challenge as it has been dominated by methodologies that emanate out of the positivist worldview of the modern era and has been mainly quantitative in nature. In their recent research, the authors have been examining methodologies that accommodate the tenets of the post-modern world – post-modernism, constructivism and career psychology. This article overviews post- modern considerations by exploring the possibilities offered by the Systems Theory Framework of career development and the 'My System of Career Influence' reflection activity as research tools. Examples of recent research are briefly described.

Modern Drama: Defining the Field

Theatre, like other subjects in the humanities, has recently undergone quintessential changes in theory, approach, and research. Modern Drama - a collection of twelve essays from leading theatre and drama scholars - investigates the contemporary meanings and the cultural and political resonances of the terms inherent in the concepts of 'modern' and 'drama, ' delving into a range of theoretical questions on the history of modernism, modernity, post-modernism, and postmodernity as they have intersected with the shifting histories of drama, theatre, and performance.

Reweaving the Silk Road through outsourcing and offshoring: The need for an externalisation theory

The reweaving and repaving of the modern Silk Road passes through outsourcing and offshoring activities that have a profound impact on both global business psyche and landscape. Firms, in particular, and their global value chain are being shaped and reshaped through a complex concoction of vertical integration and disintegration. The boundary of the firm and the firm/market interface has been of interest to students of organisation and economics for some time. It has provided the context for Internalisation Theory. Within the new economy, the twin trends of globalisation and advancing technologies are giving rise to a hitherto unknown “worldwide market for market transactions? and increased opportunities for international expansion by firms via market-based modes of organisation. We describe these trends and offer an early modeling approach for explaining why some firm’s externalise the marginal transaction in the so-called new economy. The paper further draws attention on the need to articulate an “Externalisation Theory? that adequately accounts for the firm’s offshoring and outsourcing activities, and that parallels as well as complement “Internalisation Theory? for a full explanation of today’s firms behaviour.