Profit repatriation of a Polish subsidiary from tax planning point of view of an international corporation

The main purpose of this study was to examine and compare the possibilities of profit repatriation from the point of view of tax planning of an international corporation, in such a case that a Finnish parent company has a subsidiary in Poland. The main research problem was divided into two sub research problems: 1) to examine concepts and principles of international taxation and tax planning from the point of view of international corporations and 2) to discuss the main features of Polish Companies-, Accounting- and Tax Act from the point of view a Finnish parent company. The research method of this study is mainly decision making, comparative analysis. In this study have been discussed the possibilities of international profit repatriation for supporting the decision making of the management of a Finnish parent company. In addition different repatriation possibilities have been compared. In this study has been noticed that a Finnish parent company can repatriate profit of its Polish subsidiary either directly as dividends or by using indirect methods such as interests, royalties, management fees and transfer pricing of goods. The total tax burden of dividends is heavier than the tax burden of indirect methods. It was also concluded that during the last years the Polish legislation has been renewed in order to prevent hidden dividend distribution. This has been done by implementing new rules of transfer pricing and thin capitalization.

Evaluation of Teacher Education Programs by Students and Graduates

The purpose of this research was to do a repeated cross-sectional research on class teachers who study in the 4th year and also graduated at the Faculty of Education, University of Turku between the years of 2000 through 2004. Specifically, seven research questions were addressed to target the main purpose of the study: How do class teacher education masters’ degree senior students and graduates rate “importance; effectiveness; and quality” of training they have received at the Faculty of Education? Are there significant differences between overall ratings of importance; effectiveness and quality of training by year of graduation, sex, and age (for graduates) and sex and age (for senior students)? Is there significant relationship between respondents’ overall ratings of importance; effectiveness and their overall ratings of the quality of training and preparation they have received? Are there significant differences between graduates and senior students about importance, effectiveness, and quality of teacher education programs? And what do teachers’ [Graduates] believe about how increasing work experience has changed their opinions of their preservice training? Moreover the following concepts related to the instructional activities were studied: critical thinking skills, communication skills, attention to ethics, curriculum and instruction (planning), role of teacher and teaching knowledge, assessment skills, attention to continuous professional development, subject matters knowledge, knowledge of learning environment, and using educational technology. Researcher also tried to find influence of some moderator variables e.g. year of graduation, sex, and age on the dependent and independent variables. This study consisted of two questionnaires (a structured likert-scale and an open ended questionnaire). The population in study 1 was all senior students and 2000-2004 class teacher education masters’ degree from the departments of Teacher Education Faculty of Education at University of Turku. Of the 1020 students and graduates the researcher was able to find current addresses of 675 of the subjects and of the 675 graduates contacted, 439 or 66.2 percent responded to the survey. The population in study 2 was all class teachers who graduated from Turku University and now work in the few basic schools (59 Schools) in South- West Finland. 257 teachers answered to the open ended web-based questions. SPSS was used to produce standard deviations; Analysis of Variance; Pearson Product Moment Correlation (r); T-test; ANOVA, Bonferroni post-hoc test; and Polynomial Contrast tests meant to analyze linear trend. An alpha level of .05 was used to determine statistical significance. The results of the study showed that: A majority of the respondents (graduates and students) rated the overall importance, effectiveness and quality of the teacher education programs as important, effective and good. Generally speaking there were only a few significant differences between the cohorts and groups related to the background variables (gender, age). The different cohorts were rating the quality of the programs very similarly but some differences between the cohorts were found in the importance and effectiveness ratings. Graduates of 2001 and 2002 rated the importance of the program significantly higher than 2000 graduates. The effectiveness of the programs was rated significantly higher by 2001 and 2003 graduates than other groups. In spite of these individual differences between cohorts there were no linear trends among the year cohorts in any measure. In respondents’ ratings of the effectiveness of teacher education programs there was significant difference between males and females; females rated it higher than males. There were no significant differences between males’ and females’ ratings of the importance and quality of programs. In the ratings there was only one difference between age groups. Older graduates (35 years or older) rated the importance of the teacher training significantly higher that 25-35 years old graduates. In graduates’ ratings there were positive but relatively low correlations between all variables related to importance, effectiveness and quality of Teacher Education Programs. Generally speaking students’ ratings about importance, effectiveness and quality of teacher education program were very positive. There was only one significant difference related to the background variables. Females rated higher the effectiveness of the program. The comparison of students’ and graduates’ perception about importance, effectiveness, and quality of teacher education programs showed that there were no significant differences between graduates and students in the overall ratings. However there were differences in some individual variables. Students rated higher in importance of “Continuous Professional Development”, effectiveness of “Critical Thinking Skills” and “Using Educational Technology” and quality of “Advice received from the advisor”. Graduates rated higher in importance of “Knowledge of Learning Environment” and effectiveness of “Continuous Professional Development”. According to the qualitative data of study 2 some graduates expressed that their perceptions have not changed about the importance, effectiveness, and quality of training that they received during their study time. They pointed out that teacher education programs have provided them the basic theoretical/formal knowledge and some training of practical routines. However, a majority of the teachers seems to have somewhat critical opinions about the teacher education. These teachers were not satisfied with teacher education programs because they argued that the programs failed to meet their practical demands in different everyday situations of the classroom e.g. in coping with students’ learning difficulties, multiprofessional communication with parents and other professional groups (psychologists and social workers), and classroom management problems. Participants also emphasized more practice oriented knowledge of subject matter, evaluation methods and teachers’ rights and responsibilities. Therefore, they (54.1% of participants) suggested that teacher education departments should provide more practice-based courses and programs as well as closer collaboration between regular schools and teacher education departments in order to fill gap between theory and practice.

Mobile Subscription Acquisition and Retention Costs - An Actvity-Based Model

The objective of this master’s thesis was to develop a model for mobile subscription acquisition cost, SAC, and mobile subscription retention cost, SRC, by applying activity-based cost accounting principles. The thesis was conducted as a case study for a telecommunication company operating on the Finnish telecommunication market. In addition to activity-based cost accounting there were other theories studied and applied in order to establish a theory framework for this thesis. The concepts of acquisition and retention were explored in a broader context with the concepts of customer satisfaction, loyalty and profitability and eventually customer relationship management to understand the background and meaning of the theme of this thesis. The utilization of SAC and SRC information is discussed through the theories of decision making and activity-based management. Also, the present state and future needs of SAC and SRC information usage at the case company as well as the functions of the company were examined by interviewing some members of the company personnel. With the help of these theories and methods it was aimed at finding out both the theory-based and practical factors which affect the structure of the model. During the thesis study it was confirmed that the existing SAC and SRC model of the case company should be used as the basis in developing the activity-based model. As a result the indirect costs of the old model were transformed into activities and the direct costs were continued to be allocated directly to acquisition of new subscriptions and retention of old subscriptions. The refined model will enable managing the subscription acquisition, retention and the related costs better through the activity information. During the interviews it was found out that the SAC and SRC information is also used in performance measurement and operational and strategic planning. SAC and SRC are not fully absorbed costs and it was concluded that the model serves best as a source of indicative cost information. This thesis does not include calculating costs. Instead, the refined model together with both the theory-based and interview findings concerning the utilization of the information produced by the model will serve as a framework for the possible future development aiming at completing the model.

Engendering Group Support Based Foresight for Capital Intensive Manufacturing Industries - Case Paper and Steel Industry Scenarios by 2018

In recent times of global turmoil, the need for uncertainty management has become ever momentous. The need for enhanced foresight especially concerns capital-intensive industries, which need to commit their resources and assets with long-term planning horizons. Scenario planning has been acknowledged to have many virtues - and limitations - concerning the mapping of the future and illustrating the alternative development paths. The present study has been initiated to address both the need of improved foresight in two capital-intensive industries, i.e. the paper and steel industries and the imperfections in the current scenario practice. The research problem has been approached by engendering a problem-solving vehicle, which combines, e.g. elements of generic scenario process, face-to-face group support methods, deductive scenario reasoning and causal mapping into a fully integrated scenario process. The process, called the SAGES scenario framework, has been empirically tested by creating alternative futures for two capital-intensive industries, i.e. the paper and steel industries. Three scenarios for each industry have been engendered together with the identification of the key megatrends, the most important foreign investment determinants, key future drivers and leading indicators for the materialisation of the scenarios. The empirical results revealed a two-fold outlook for the paper industry, while the steel industry future was seen as much more positive. The research found support for utilising group support systems in scenario and strategic planning context with some limitations. Key perceived benefits include high time-efficiency, productivity and lower resource-intensiveness. Group support also seems to enhance participant satisfaction, encourage innovative thinking and provide the users with personalised qualitative scenarios.

Delay reduction in courts of justice – possibilities and challenges of process improvement in professional public organizations

Delays in the justice system have been undermining the functioning and performance of the court system all over the world for decades. Despite the widespread concern about delays, the solutions have not kept up with the growth of the problem. The delay problem existing in the justice courts processes is a good example of the growing need and pressure in professional public organizations to start improving their business process performance.This study analyses the possibilities and challenges of process improvement in professional public organizations. The study is based on experiences gained in two longitudinal action research improvement projects conducted in two separate Finnish law instances; in the Helsinki Court of Appeal and in the Insurance Court. The thesis has two objectives. First objective is to study what kinds of factors in court system operations cause delays and unmanageable backlogs and how to reduce and prevent delays. Based on the lessons learned from the case projects the objective is to give new insights on the critical factors of process improvement conducted in professional public organizations. Four main areas and factors behind the delay problem is identified: 1) goal setting and performance measurement practices, 2) the process control system, 3) production and capacity planning procedures, and 4) process roles and responsibilities. The appropriate improvement solutions include tools to enhance project planning and scheduling and monitoring the agreed time-frames for different phases of the handling process and pending inventory. The study introduces the identified critical factors in different phases of process improvement work carried out in professional public organizations, the ways the critical factors can be incorporated to the different stages of the projects, and discusses the role of external facilitator in assisting process improvement work and in enhancing ownership towards the solutions and improvement. The study highlights the need to concentrate on the critical factors aiming to get the employees to challenge their existing ways of conducting work, analyze their own processes, and create procedures for diffusing the process improvement culture instead of merely concentrating of finding tools, techniques, and solutions appropriate for applications from the manufacturing sector

Socially Competent Leadership - predictors, impacts and skilling in engineering

Earlier management studies have found a relationship between managerial qualities and subordinate impacts, but the effect of managers‘ social competence on leader perceptions has not been solidly established. To fill the related research gap, the present work embarks on a quantitative empirical effort to identify predictors of successful leadership. In particular, this study investigates relationships between perceived leader behavior and three selfreport instruments used to measure managerial capability: 1) the WOPI Work Personality Inventory, 2) Raven‘s general intelligence scale, and 3) the Emotive Communication Scale (ECS). This work complements previous research by resorting to both self-reports and other-reports: the results acquired from the managerial sample are compared to subordinate perceptions as measured through the ECS other-report and the WOPI360 multi-source appraisal. The quantitative research is comprised of a sample of 8o superiors and 354 subordinates operating in eight Finnish organizations. The strongest predictive value emerged from the ECS self- and other-reports and certain personality dimensions. In contrast, supervisors‘ logical intelligence did not correlate with leadership perceived as socially competent by subordinates. 16 of the superiors rated as most socially competent by their subordinates were selected for case analysis. Their qualitative narratives evidence the role of life history and post-traumatic growth in developing managerial skills. The results contribute to leadership theory in four ways. First, the ECS self-report devised for this research offers a reliable scale for predicting socially competent leader ability. Second, the work identifies dimensions of personality and emotive skills that can be considered predictors of managerial ability and benefited from in leader recruitment and career planning. Third, the Emotive Communication Model delineated on the basis of the empirical data allows for a systematic design and planning of communication and leadership education. Fourth, this workfurthers understanding of personal growth strategies and the role of life history in leader development and training. Finally, this research advances educational leadership by conceptualizing and operationalizing effective managerial communications. The Emotive Communication Model devised directs the pedagogic attention in engineering to assertion, emotional availability and inspiration skills. The proposed methodology addresses classroom management strategies drawing from problem-based learning, student empowerment, collaborative learning, and so-called socially competent teachership founded on teacher immediacy and perceived caring, all constituting strategies moving away from student compliance and teacher modelling. The ultimate educational objective embraces the development of individual engineers and organizational leaders that not only possess traditional analytical and technical expertise and substantive knowledge but are intelligent also creatively, practically, and socially.

Coercion, Perceived Care and Quality of Life Among Patients in Psychiatric Hospitals

The goals of the study were to describe patients’ perceptions of care after experiencing seclusion/restraint and their quality of life. The goal was moreover to identify methodological challenges related to studies from the perspective of coerced patients. The study was conducted in three phases between September 2008 and April 2012. In the first phase, the instrument Secluded/ Restrained Patients’ Perception of their Treatment (SR-PPT) was developed and validated in Japan in cooperation with a Finnish research group (n = 56). Additional data were collected over one year from secluded/restrained patients using the instrument (n = 90). In the second phase, data were collected during the discharge process (n = 264). In the third phase, data were collected from electronic databases. Methodological and ethical issues were reviewed (n = 32) using systematic review method. Patients perceived that co-operation with the staff was poor; patients’ opinions were not taken into account, treatment targets collated and treatment methods were seen in different ways. Patients also felt that their concerns were not well enough understood. However, patients received getting nurses’ time. In particular, seclusion/restraint was considered unnecessary. The patients felt that they benefited from the isolation in treating their problems more than they needed it, even if the benefit was seen to be minor. Patients treated on forensic wards rated their treatment and care significantly lower than in general units. During hospitalization secluded/restrained patients evaluated their quality of life, however, better than did non-secluded/restrained patients. However, no conclusion is drawn to the effect that the better quality of life assessment is attributable to the seclusion/restraint because patients’ treatment period after the isolation was long and because of many other factors, as rehabilitation, medication, diagnostic differences, and adaptation. According to the systematic mixed studies review variation between study designs was found to be a methodological challenge. This makes comparison of the results more difficult. A research ethical weakness is conceded as regards descriptions of the ethical review process (44 %) and informed consent (32 %). It can be concluded that patients in psychiatric hospital care and having a voice as an equal expert require special attention to clinical nursing, decision-making and service planning. Patients and their family members will be consulted in plans of preventive and alternative methods for seclusion and restraint. The study supports the theory that in ethical decision-making situations account should be taken of medical indications, in addition to the patients’ preferences, the effect of treatment on quality of life, and this depends on other factors. The connection between treatment decisions and a patient’s quality of life should be evaluated more structurally in practice. Changing treatment culture towards patients’ involvement will support daily life in nursing and service planning taking into account improvements in patients’ quality of life.

Differentiation of Metabolically Distinct Areas within Head and Neck Region using Dynamic 18F-FDG Positron Emission Tomography Imaging

Positron Emission Tomography (PET) using ¹⁸F-FDG is playing a vital role in the diagnosis and treatment planning of cancer. However, the most widely used radiotracer, ¹⁸F-FDG, is not specific for tumours and can also accumulate in inflammatory lesions as well as normal physiologically active tissues making diagnosis and treatment planning complicated for the physicians. Malignant, inflammatory and normal tissues are known to have different pathways for glucose metabolism which could possibly be evident from different characteristics of the time activity curves from a dynamic PET acquisition protocol. Therefore, we aimed to develop new image analysis methods, for PET scans of the head and neck region, which could differentiate between inflammation, tumour and normal tissues using this functional information within these radiotracer uptake areas. We developed different dynamic features from the time activity curves of voxels in these areas and compared them with the widely used static parameter, SUV, using Gaussian Mixture Model algorithm as well as K-means algorithm in order to assess their effectiveness in discriminating metabolically different areas. Moreover, we also correlated dynamic features with other clinical metrics obtained independently of PET imaging. The results show that some of the developed features can prove to be useful in differentiating tumour tissues from inflammatory regions and some dynamic features also provide positive correlations with clinical metrics. If these proposed methods are further explored then they can prove to be useful in reducing false positive tumour detections and developing real world applications for tumour diagnosis and contouring.

Demand forecasting process design and methods in medium sized enterprise

The purpose of this thesis was to study the design of demand forecasting processes and management of demand. In literature review were different processes found and forecasting methods and techniques interviewed. Also role of bullwhip effect in supply chain was identified and how to manage it with information sharing operations. In the empirical part of study is at first described current situation and challenges in case company. After that will new way to handle demand introduced with target budget creation and how information sharing with 5 products and a few customers would bring benefits to company. Also the new S&OP process created within this study and organization for it.

Modelling of changes in electricity end-use and their impacts on electricity distribution

The electricity distribution sector will face significant changes in the future. Increasing reliability demands will call for major network investments. At the same time, electricity end-use is undergoing profound changes. The changes include future energy technologies and other advances in the field. New technologies such as microgeneration and electric vehicles will have different kinds of impacts on electricity distribution network loads. In addition, smart metering provides more accurate electricity consumption data and opportunities to develop sophisticated load modelling and forecasting approaches. Thus, there are both demands and opportunities to develop a new type of long-term forecasting methodology for electricity distribution. The work concentrates on the technical and economic perspectives of electricity distribution. The doctoral dissertation proposes a methodology to forecast electricity consumption in the distribution networks. The forecasting process consists of a spatial analysis, clustering, end-use modelling, scenarios and simulation methods, and the load forecasts are based on the application of automatic meter reading (AMR) data. The developed long-term forecasting process produces power-based load forecasts. By applying these results, it is possible to forecast the impacts of changes on electrical energy in the network, and further, on the distribution system operator’s revenue. These results are applicable to distribution network and business planning. This doctoral dissertation includes a case study, which tests the forecasting process in practice. For the case study, the most prominent future energy technologies are chosen, and their impacts on the electrical energy and power on the network are analysed. The most relevant topics related to changes in the operating environment, namely energy efficiency, microgeneration, electric vehicles, energy storages and demand response, are discussed in more detail. The study shows that changes in electricity end-use may have radical impacts both on electrical energy and power in the distribution networks and on the distribution revenue. These changes will probably pose challenges for distribution system operators. The study suggests solutions for the distribution system operators on how they can prepare for the changing conditions. It is concluded that a new type of load forecasting methodology is needed, because the previous methods are no longer able to produce adequate forecasts.