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.

The Pursuit of Efficient Copyright Licensing : How Some Rights Reserved Attempts to Solve the Problems of All Rights Reserved

This dissertation analyses the growing pool of copyrighted works, which are offered to the public using Creative Commons licensing. The study consist of analysis of the novel licensing system, the licensors, and the changes of the "all rights reserved" —paradigm of copyright law. Copyright law reserves all rights to the creator until seventy years have passed since her demise. Many claim that this endangers communal interests. Quite often the creators are willing to release some rights. This, however, is very difficult to do and needs help of specialized lawyers. The study finds that the innovative Creative Commons licensing scheme is well suited for low value - high volume licensing. It helps to reduce transaction costs on several le¬vels. However, CC licensing is not a "silver bullet". Privacy, moral rights, the problems of license interpretation and license compatibility with other open licenses and collecting societies remain unsolved. The study consists of seven chapters. The first chapter introduces the research topic and research questions. The second and third chapters inspect the Creative Commons licensing scheme's technical, economic and legal aspects. The fourth and fifth chapters examine the incentives of the licensors who use open licenses and describe certain open business models. The sixth chapter studies the role of collecting societies and whether two institutions, Creative Commons and collecting societies can coexist. The final chapter summarizes the findings. The dissertation contributes to the existing literature in several ways. There is a wide range of prior research on open source licensing. However, there is an urgent need for an extensive study of the Creative Commons licensing and its actual and potential impact on the creative ecosystem.

Некоторые наблюдения по поводу построения компьютерного морфологического анализатора марийского языка. [Problems in writing a two-level model of Mari morphology]

The article describes some concrete problems that were encountered when writing a two-level model of Mari morphology. Mari is an agglutinative Finno-Ugric language spoken in Russia by about 600 000 people. The work was begun in the 1980s on the basis of K. Koskenniemi’s Two-Level Morphology (1983), but in the latest stage R. Beesley’s and L. Karttunen’s Finite State Morphology (2003) was used. Many of the problems described in the article concern the inexplicitness of the rules in Mari grammars and the lack of information about the exact distribution of some suffixes, e.g. enclitics. The Mari grammars usually give complete paradigms for a few unproblematic verb stems, whereas the difficult or unclear forms of certain verbs are only superficially discussed. Another example of phenomena that are poorly described in grammars is the way suffixes with an initial sibilant combine to stems ending in a sibilant. The help of informants and searches from electronic corpora were used to overcome such difficulties in the development of the two-level model of Mari. The variation of the order of plural markers, case suffixes and possessive suffixes is a typical feature of Mari. The morphotactic rules constructed for Mari declensional forms tend to be recursive and their productivity must be limited by some technical device, such as filters. In the present model, certain plural markers were treated like nouns. The positional and functional versatility of the possessive suffixes can be regarded as the most challenging phenomenon in attempts to formalize the Mari morphology. Cyrillic orthography, which was used in the model, also caused problems. For instance, a Cyrillic letter may represent a sequence of two sounds, the first being part of the word stem while the other belongs to a suffix. In some cases, letters for voiced consonants are also generalized to represent voiceless consonants. Such orthographical conventions distance a morphological model based on orthography from the actual (morpho)phonological processes in the language.

Boundary identification in the domain of a parabolic partial differential equation

Bakgrunden och inspirationen till föreliggande studie är tidigare forskning i tillämpningar på randidentifiering i metallindustrin. Effektiv randidentifiering möjliggör mindre säkerhetsmarginaler och längre serviceintervall för apparaturen i industriella högtemperaturprocesser, utan ökad risk för materielhaverier. I idealfallet vore en metod för randidentifiering baserad på uppföljning av någon indirekt variabel som kan mätas rutinmässigt eller till en ringa kostnad. En dylik variabel för smältugnar är temperaturen i olika positioner i väggen. Denna kan utnyttjas som insignal till en randidentifieringsmetod för att övervaka ugnens väggtjocklek. Vi ger en bakgrund och motivering till valet av den geometriskt endimensionella dynamiska modellen för randidentifiering, som diskuteras i arbetets senare del, framom en flerdimensionell geometrisk beskrivning. I de aktuella industriella tillämpningarna är dynamiken samt fördelarna med en enkel modellstruktur viktigare än exakt geometrisk beskrivning. Lösningsmetoder för den s.k. sidledes värmeledningsekvationen har många saker gemensamt med randidentifiering. Därför studerar vi egenskaper hos lösningarna till denna ekvation, inverkan av mätfel och något som brukar kallas förorening av mätbrus, regularisering och allmännare följder av icke-välställdheten hos sidledes värmeledningsekvationen. Vi studerar en uppsättning av tre olika metoder för randidentifiering, av vilka de två första är utvecklade från en strikt matematisk och den tredje från en mera tillämpad utgångspunkt. Metoderna har olika egenskaper med specifika fördelar och nackdelar. De rent matematiskt baserade metoderna karakteriseras av god noggrannhet och låg numerisk kostnad, dock till priset av låg flexibilitet i formuleringen av den modellbeskrivande partiella differentialekvationen. Den tredje, mera tillämpade, metoden kännetecknas av en sämre noggrannhet förorsakad av en högre grad av icke-välställdhet hos den mera flexibla modellen. För denna gjordes även en ansats till feluppskattning, som senare kunde observeras överensstämma med praktiska beräkningar med metoden. Studien kan anses vara en god startpunkt och matematisk bas för utveckling av industriella tillämpningar av randidentifiering, speciellt mot hantering av olinjära och diskontinuerliga materialegenskaper och plötsliga förändringar orsakade av “nedfallande” väggmaterial. Med de behandlade metoderna förefaller det möjligt att uppnå en robust, snabb och tillräckligt noggrann metod av begränsad komplexitet för randidentifiering.

Value added logistics in supply and demand chain : COSTFIX : New operation model for maintenance material logistics in paper industry

This research report illustrates and examines new operation models for decreasing fixed costs and transforming them into variable costs in the field of paper industry. The report illustrates two cases – a new operation model for material logistics in maintenance and an examination of forklift truck fleet outsourcing solutions. Conventional material logistics in maintenance operation is illustrated and some problems related to conventional operation are identified. A new operation model that solves some of these problems is presented including descriptions of procurement and service contracts and sources of added value. Forklift truck fleet outsourcing solutions are examined by illustrating the responsibilities of a host company and a service provider both before and after outsourcing. The customer buys outsourcing services in order to improve its investment productivity. The mechanism of how these services affect the customer company’s investment productivity is illustrated.

Libyan breast cancer: Health services and biology. Diagnosis delay and prognostic value of DNA pploidy, S-phase fraction, and Ki-67 and Bcl-2 immunohistochemistry

The aim of this study was to investigate the diagnosis delay and its impact on the stage of disease. The study also evaluated a nuclear DNA content, immunohistochemical expression of Ki-67 and bcl-2, and the correlation of these biological features with the clinicopathological features and patient outcome. 200 Libyan women, diagnosed during 2008–2009 were interviewed about the period from the first symptoms to the final histological diagnosis of breast cancer. Also retrospective preclinical and clinical data were collected from medical records on a form (questionnaire) in association with the interview. Tumor material of the patients was collected and nuclear DNA content analysed using DNA image cytometry. The expression of Ki-67 and bcl-2 were assessed using immunohistochemistry (IHC). The studies described in this thesis show that the median of diagnosis time for women with breast cancer was 7.5 months and 56% of patients were diagnosed within a period longer than 6 months. Inappropriate reassurance that the lump was benign was an important reason for prolongation of the diagnosis time. Diagnosis delay was also associated with initial breast symptom(s) that did not include a lump, old age, illiteracy, and history of benign fibrocystic disease. The patients who showed diagnosis delay had bigger tumour size (p<0.0001), positive lymph nodes (p<0.0001), and high incidence of late clinical stages (p<0.0001). Biologically, 82.7% of tumors were aneuploid and 17.3% were diploid. The median SPF of tumors was 11% while the median positivity of Ki-67 was 27.5%. High Ki-67 expression was found in 76% of patients, and high SPF values in 56% of patients. Positive bcl-2 expression was found in 62.4% of tumors. 72.2% of the bcl-2 positive samples were ER-positive. Patients who had tumor with DNA aneuploidy, high proliferative activity and negative bcl-2 expression were associated with a high grade of malignancy and short survival. The SPF value is useful cell proliferation marker in assessing prognosis, and the decision cut point of 11% for SPF in the Libyan material was clearly significant (p<0.0001). Bcl-2 is a powerful prognosticator and an independent predictor of breast cancer outcome in the Libyan material (p<0.0001). Libyan breast cancer was investigated in these studies from two different aspects: health services and biology. The results show that diagnosis delay is a very serious problem in Libya and is associated with complex interactions between many factors leading to advanced stages, and potentially to high mortality. Cytometric DNA variables, proliferative markers (Ki-67 and SPF), and oncoprotein bcl-2 negativity reflect the aggressive behavior of Libyan breast cancer and could be used with traditional factors to predict the outcome of individual patients, and to select appropriate therapy.

Modeling of fireside deposit formation in two industrial furnaces

Fireside deposits can be found in many types of utility and industrial furnaces. The deposits in furnaces are problematic because they can reduce heat transfer, block gas paths and cause corrosion. To tackle these problems, it is vital to estimate the influence of deposits on heat transfer, to minimize deposit formation and to optimize deposit removal. It is beneficial to have a good understanding of the mechanisms of fireside deposit formation. Numerical modeling is a powerful tool for investigating the heat transfer in furnaces, and it can provide valuable information for understanding the mechanisms of deposit formation. In addition, a sub-model of deposit formation is generally an essential part of a comprehensive furnace model. This work investigates two specific processes of fireside deposit formation in two industrial furnaces. The first process is the slagging wall found in furnaces with molten deposits running on the wall. A slagging wall model is developed to take into account the two-layer structure of the deposits. With the slagging wall model, the thickness and the surface temperature of the molten deposit layer can be calculated. The slagging wall model is used to predict the surface temperature and the heat transfer to a specific section of a super-heater tube panel with the boundary condition obtained from a Kraft recovery furnace model. The slagging wall model is also incorporated into the computational fluid dynamics (CFD)-based Kraft recovery furnace model and applied on the lower furnace walls. The implementation of the slagging wall model includes a grid simplification scheme. The wall surface temperature calculated with the slagging wall model is used as the heat transfer boundary condition. Simulation of a Kraft recovery furnace is performed, and it is compared with two other cases and measurements. In the two other cases, a uniform wall surface temperature and a wall surface temperature calculated with a char bed burning model are used as the heat transfer boundary conditions. In this particular furnace, the wall surface temperatures from the three cases are similar and are in the correct range of the measurements. Nevertheless, the wall surface temperature profiles with the slagging wall model and the char bed burning model are different because the deposits are represented differently in the two models. In addition, the slagging wall model is proven to be computationally efficient. The second process is deposit formation due to thermophoresis of fine particles to the heat transfer surface. This process is considered in the simulation of a heat recovery boiler of the flash smelting process. In order to determine if the small dust particles stay on the wall, a criterion based on the analysis of forces acting on the particle is applied. Time-dependent simulation of deposit formation in the heat recovery boiler is carried out and the influence of deposits on heat transfer is investigated. The locations prone to deposit formation are also identified in the heat recovery boiler. Modeling of the two processes in the two industrial furnaces enhances the overall understanding of the processes. The sub-models developed in this work can be applied in other similar deposit formation processes with carefully-defined boundary conditions.

Strategic management of value networks: how to create value in cross-sector collaboration and partnerships

Cross-sector collaboration and partnerships have become an emerging and desired strategy in addressing huge social and environmental challenges. Despite its popularity, cross-sector collaboration management has proven to be very challenging. Even though cross-sector collaboration and partnership management have been widely studied and discussed in recent years, their effectiveness as well as their ability to create value with respect to the problems they address has remained very challenging. There is little or no evidence of their ability to create value. Regarding all these challenges, this study aims to explore how to manage cross-sector collaborations and partnerships to be able to improve their effectiveness and to create more value for all partners involved in collaboration as well as for customers. The thesis is divided into two parts. The first part comprises an overview of relevant literature (including strategic management, value networks and value creation theories), followed by presenting the results of the whole thesis and the contribution made by the study. The second part consists of six research publications, including both quantitative and qualitative studies. The chosen research strategy is triangulation, as the study includes four types of triangulation: (1) theoretical triangulation, (2) methodological triangulation, (3) data triangulation and (4) researcher triangulation. Two publications represent conceptual development, which are based on secondary data research. One publication is a quantitative study, carried out through a survey. The other three publications represent qualitative studies, based on case studies, where data was collected through interviews and workshops, with participation of managers from all three sectors: public, private and the third (nonprofit). The study consolidates the field of “strategic management of value networks,” which is proposed to be applied in the context of cross-sector collaboration and partnerships, with the aim of increasing their effectiveness and the process of value creation. Furthermore, the study proposes a first definition for the strategic management of value networks. The study also proposes and develops two strategy tools that are recommended to be used for the strategic management of value networks in cross-sector collaboration and partnerships. Taking a step forward, the study implements the strategy tools in practice, aiming to show and to demonstrate how new value can be created by using the developed strategy tools for the strategic management of value networks. This study makes four main contributions. (1) First, it brings a theoretical contribution by providing new insights and consolidating the field of strategic management of value networks, also proposing a first definition for the strategic management of value networks. (2) Second, the study makes a methodical contribution by proposing and developing two strategy tools for value networks of cross-sector collaboration: (a) value network mapping, a method that allows us to assess the current and the potential value network and (b) the Value Network Scorecard, a method of performance measurement and performance prediction in cross-sector collaboration. (3) Third, the study has managerial implications, offering new solutions and empirical evidence on how to increase the effectiveness of cross-sector collaboration and also allow managers to understand how new value can be created in cross-sector partnerships and how to get the full potential of collaboration. (4) And fourth, the study also has practical implications, allowing managers to understand how to use in practice the strategy tools developed in this study, providing discussions on the limitations regarding the proposed tools as well as general limitations involved in the study.

Value added KPI service delivery with quality function deployment: Multiple case study in asset & real estate management

The aim of this study is to investigate value added service concept for an asset and real estate management case company. The initial purpose was to recognize the most value adding key performance indicators (KPIs) information delivered for its customers, real estate investors with value added service. The multiple case study strategy included two focus group interviews with five case interviews in total. Additionally, quality function deployment (QFD) was used in order to form up the service process. The study starts with introduction and methodology explaining the demand for the thesis study. The subsequent chapter presents the theoretical background on real estate management KPIs in four main points of views and quality function deployment from the service development point of view. The chapter also defines research gap for the case study. According to the case study interviews, the most favored KPIs to deliver for the clients are income maturity of lease agreements and leasing activity. These KPIs and quality characteristics are translated into the QFD. In total, the service QFD explains the service planning, process control, and action plan phases.

Designing new learning experiences? : exploring corporate E-learners’ self-regulated learning

The context of this study is corporate e-learning, with an explicit focus on how digital learning design can facilitate self-regulated learning (SRL). The field of e-learning is growing rapidly. An increasing number of corporations use digital technology and elearning for training their work force and customers. E-learning may offer economic benefits, as well as opportunities for interaction and communication that traditional teaching cannot provide. However, the evolving variety of digital learning contexts makes new demands on learners, requiring them to develop strategies to adapt and cope with novel learning tools. This study derives from the need to learn more about learning experiences in digital contexts in order to be able to design these properly for learning. The research question targets how the design of an e-learning course influences participants’ self-regulated learning actions and intentions. SRL involves learners’ ability to exercise agency in their learning. Micro-level SRL processes were targeted by exploring behaviour, cognition, and affect/motivation in relation to the design of the digital context. Two iterations of an e-learning course were tested on two groups of participants (N=17). However, the exploration of SRL extends beyond the educational design research perspective of comparing the effects of the changes to the course designs. The study was conducted in a laboratory with each participant individually. Multiple types of data were collected. However, the results presented in this thesis are based on screen observations (including eye tracking) and video-stimulated recall interviews. These data were integrated in order to achieve a broad perspective on SRL. The most essential change evident in the second course iteration was the addition of feedback during practice and the final test. Without feedback on actions there was an observable difference between those who were instruction-directed and those who were self-directed in manipulating the context and, thus, persisted whenever faced with problems. In the second course iteration, including the feedback, this kind of difference was not found. Feedback provided the tipping point for participants to regulate their learning by identifying their knowledge gaps and to explore the learning context in a targeted manner. Furthermore, the course content was consistently seen from a pragmatic perspective, which influenced the participants’ choice of actions, showing that real life relevance is an important need of corporate learners. This also relates to assessment and the consideration of its purpose in relation to participants’ work situation. The rigidity of the multiple choice questions, focusing on the memorisation of details, influenced the participants to adapt to an approach for surface learning. It also caused frustration in cases where the participants’ epistemic beliefs were incompatible with this kind of assessment style. Triggers of positive and negative emotions could be categorized into four levels: personal factors, instructional design of content, interface design of context, and technical solution. In summary, the key design choices for creating a positive learning experience involve feedback, flexibility, functionality, fun, and freedom. The design of the context impacts regulation of behaviour, cognition, as well as affect and motivation. The learners’ awareness of these areas of regulation in relation to learning in a specific context is their ability for design-based epistemic metareflection. I describe this metareflection as knowing how to manipulate the context behaviourally for maximum learning, being metacognitively aware of one’s learning process, and being aware of how emotions can be regulated to maintain volitional control of the learning situation. Attention needs to be paid to how the design of a digital learning context supports learners’ metareflective development as digital learners. Every digital context has its own affordances and constraints, which influence the possibilities for micro-level SRL processes. Empowering learners in developing their ability for design-based epistemic metareflection is, therefore, essential for building their digital literacy in relation to these affordances and constraints. It was evident that the implementation of e-learning in the workplace is not unproblematic and needs new ways of thinking about learning and how we create learning spaces. Digital contexts bring a new culture of learning that demands attitude change in how we value knowledge, measure it, define who owns it, and who creates it. Based on the results, I argue that digital solutions for corporate learning ought to be built as an integrated system that facilitates socio-cultural connectivism within the corporation. The focus needs to shift from designing static e-learning material to managing networks of social meaning negotiation as part of a holistic corporate learning ecology.

Measurement of social value creation with non-financial measures

This research examines the concept of social entrepreneurship which is a fairly new business model. In the field of business it has become increasingly popular in recent years. The growing awareness of the environment and concrete examples of impact created by social entrepreneurship have encouraged entrepreneurs to address social problems. Society’s failures are tried to redress as a result of business activities. The purpose of doing business is necessarily no longer generating just profits but business is run in order to make a social change with the profit gained from the operations. Successful social entrepreneurship requires a specific nature, constant creativity and strong desire to make a social change. It requires constant balancing between two major objectives: both financial and non-financial issues need to be considered, but not at the expense of another. While aiming at the social purpose, the business needs to be run in highly competitive markets. Therefore, both factors need equally be integrated into an organization as they are complementary, not exclusionary. Business does not exist without society and society cannot go forward without business. Social entrepreneurship, its value creation, measurement tools and reporting practices are under discussion in this research. An extensive theoretical basis is covered and used to support the findings coming out of the researched case enterprises. The most attention is focused on the concept of Social Return on Investment. The case enterprises are analyzed through the SROI process. Social enterprises are mostly small or medium sized. Naturally this sets some limitations in implementing measurement tools. The question of resources requires the most attention and therefore sets the biggest constraints. However, the size of the company does not determine all – the nature of business and the type of social purpose need to be considered always. The mission may be so concrete and transparent that in all cases any kind of measurement would be useless. Implementing measurement tools may be of great benefit – or a huge financial burden. Thus, the very first thing to carefully consider is the possible need of measuring value creation.

Value creation in intelligent packaging value chains

The goal of this thesis is to look for and point out problems and bottlenecks related to value chains and networks in initiation and implementation of intelligent packaging. The research is based on interviews in different case companies and is qualitative by nature. The interview results are examined through a framework built upon relevant theory, with the aim to present a useful recommendation for a supplier company for advancing intelligent packaging business. The perspective that is attained through the research questions demonstrates the potential customer companies’ views of possibilities and problems. The key results suggest that intellectual property of relevant products is in an important position from the customers’ perspective. If the supplier does not own a product technology, a sufficiently large company can consider working as an integrator in a network where smaller companies make use of a compiled offering from other smaller actors. The foundation for these networks and company relationships is value creation, which has to be based on profound customer knowledge and research. The framework that is created for this study builds upon earlier research to provide a model that better serves intelligent packaging implementation and includes the notion of importance of value proposition and continuous value co-creation.

Kaupallisen sekajätteen mekaaniset käsittelyprosessit ja laitos investoinnin kannattavuus

Työn tavoitteena oli tutkia mekaanisia käsittelylaitteita ja -prosesseja kaupalliselle sekajätteelle ja selvittää mahdollisen laitoshankkeen kannattavuutta case-yritykselle. Jätehuollon yritykset ovat jatkuvan muutoksen alla kasvavien keräys- ja käsittelykustannusten takia, joka vaatii säästöjen etsimistä. Sekajäte sisältää arvokkaita kierrätysraaka-aineita ja näiden erottelu voisi luoda lisäarvoa alentuneina hävityskustannuksina ja lisääntyneinä myyntituottoina. Työssä selvitettiin kaupallisen sekajätteen koostumusta lajittelukokeen ja muiden sekajätetutkimusten avulla. Mekaanisia käsittelylaitteita tutkittiin kirjallisuuden ja case-esimerkkien kautta. Laitoshakkeen kannattavuutta arvioitiin taulukkolaskentamallin avulla. Laitosvaihtoehtoja tarkasteltiin 10-30 tuhannen tonnin kapasiteetin välillä. Laskelmien ja kirjallisuustutkimuksen pohjalta kannattavimpana vaihtoehtona nähtiin SRF kierrätyspolttoainetta valmistava laitos. Kirjallisuustutkimuksen ja case-laitosten pohjalta luotiin kaksi investointiskenaariota, joille laskettiin taulukkolaskentamallin avulla yksikkökustannukset, nettonykyarvot ja sisäiset korot. Kustannusaineisto oli peräisin case-yritykseltä ja muista laitostutkimuksista. Kannattavuuslaskelmien mukaan skenaario 2, jossa SRF-tuotannon lisäksi eroteltaisiin sekalaisia muoveja, on kannattavampi. Skenaarioiden 1 ja 2 kriittiset pisteet olivat noin 15,3 ja 13,6 tuhatta tonnia vuodessa. Kumpikaan skenaarioista ei kuitenkaan ole kannattava case-yrityksen omilla vuotuisilla kuormilla (10 000 tonnia). Lisää käsiteltävää jätettä tulisi hankkia ulkopuolisilta yrityksiltä taloudellisesti edullisen vaakamaksun avulla. Skenaarion 2 ongelmaksi kuitenkin muodostuu sekalaisten muovien poistuminen SRF:n komponenttina, mikä vaikuttaa SRF:n markkinoitavuuteen tehollisen lämpöarvon alenemisen takia.