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.

Diffusion of Administrative Innovation: TQM Implementation and Effectiveness in a Global

The main objective of this dissertation is to create new knowledge on an administrative innovation, its adoption, diffusion and finally its effectiveness. In this dissertation the administrative innovation is approached through a widely utilized management philosophy, namely the total quality management (TQM) strategy. TQM operationalizes a self-assessment procedure, which is based on continual improvement principles and measuring the improvements. This dissertation also captures the theme of change management as it analyzes the adoption and diffusion of the administrative innovation. It identifies innovation characteristics as well as organisational and individual factors explaining the adoption and implementation. As a special feature, this study also explores the effectiveness of the innovation based on objective data. For studying the administrative innovation (TQM model), a multinational Case Company provides a versatile ground for a deep, longitudinal analysis. The Case Company started the adoption systematically in the mid 1980s in some of its units. As part of their strategic planning today, the procedure is in use throughout the entire global company. The empirical story begins from the innovation adoption decision that was made in the Case Company over 22 years ago. In order to be able to capture the right atmosphere and backgrounds leading to the adoption decision, key informants from that time were interviewed, since the main target was to clarify the dynamics of how an administrative innovation develops. In addition, archival material was collected and studied, available memos and data relating to the innovation, innovation adoption and later to the implementation contained altogether 20500 pages of documents. A survey was furthermore conducted at the end of 2006 focusing on questions related to the innovation, organization and leadership characteristics and the response rate totalled up to 54%. For measuring the effectiveness of the innovation implementation, the needed longitudinal objective performance data was collected. This data included the profit unit level experience of TQM, the development of the self assessment scores per profit unit and performance data per profit unit measured with profitability, productivity and customer satisfaction. The data covered the years 1995-2006. As a result, the prerequisites for the successful adoption of an administrative innovation were defined, such as the top management involvement, support of the change agents and effective tools for implementation and measurement. The factors with the greatest effect on the depth of the implementation were the timing of the adoption and formalization. The results also indicated that the TQM model does have an effect on the company performance measured with profitability, productivity and customer satisfaction. Consequently this thesis contributes to the present literature (i) by taking into its scope an administrative innovation and focusing on the whole innovation implementation process, from the adoption, through diffusion until its consequences, (ii) because the studied factors with an effect on the innovation adoption and diffusion are multifaceted and grouped into individual, organizational and environmental factors, and a strong emphasis is put on the role of the individual change agents and (iii) by measuring the depth and consistency of the administrative innovation. This deep analysis was possible due to the availability of longitudinal data with triangulation possibilities.

Calculation analysis of energy saving tools for fan and pump applications

This thesis analyses the calculation of FanSave and PumpSave energy saving tools calculation. With these programs energy consumption of variable speed drive control for fans and pumps can be compared to other control methods. With FanSave centrifugal and axial fans can be examined and PumpSave deals with centrifugal pumps. By means of these programs also suitable frequency converter can be chosen from the ABB collection. Programs need as initial values information about the appliances like amount of flow and efficiencies. Operation time is important factor when calculating the annual energy consumption and information about it are the length and profile. Basic theory related to fans and pumps is introduced without more precise instructions for dimensioning. FanSave and PumpSave contain various methods for flow control. These control methods are introduced in the thesis based on their operational principles and suitability. Also squirrel cage motor and frequency converter are introduced because of their close involvement to fans and pumps. Second part of the thesis contains comparison between results of FanSave’s and PumpSave’s calculation and performance curve based calculation. Also laboratory tests were made with centrifugal and axial fan and also with centrifugal pump. With the results from this thesis the calculation of these programs can be adjusted to be more accurate and also some new features can be added.

Use of Statistical Methods in Demand Planning

In a very volatile industry of high technology it is of utmost importance to accurately forecast customers’ demand. However, statistical forecasting of sales, especially in heavily competitive electronics product business, has always been a challenging task due to very high variation in demand and very short product life cycles of products. The purpose of this thesis is to validate if statistical methods can be applied to forecasting sales of short life cycle electronics products and provide a feasible framework for implementing statistical forecasting in the environment of the case company. Two different approaches have been developed for forecasting on short and medium term and long term horizons. Both models are based on decomposition models, but differ in interpretation of the model residuals. For long term horizons residuals are assumed to represent white noise, whereas for short and medium term forecasting horizon residuals are modeled using statistical forecasting methods. Implementation of both approaches is performed in Matlab. Modeling results have shown that different markets exhibit different demand patterns and therefore different analytical approaches are appropriate for modeling demand in these markets. Moreover, the outcomes of modeling imply that statistical forecasting can not be handled separately from judgmental forecasting, but should be perceived only as a basis for judgmental forecasting activities. Based on modeling results recommendations for further deployment of statistical methods in sales forecasting of the case company are developed.

Facilitating coordination improvement efforts in cross-functional process development programs

Business process improvement is a common approach in increasing the effectiveness of an organization. It can be seen as an effort to increase coordination between units. Process improvement has proved to be challenging, and most management consultation firms facilitate organizations in this kind of initiatives. Cross-functional improvement is one of the main areas for internal consultants as well. However, the needs, challenges and means of cross-functional help have been rarely discussed in the literature. The objective of this thesis is on one hand to present a conceptual and descriptive framework to help understand the challenges of facilitating coordination improvement efforts in cross-functional improvement programs, and on the other hand to develop and test feasible solutions for some facilitation situations. The research questions are: 1. Why and in what kind of situations do organizations need help in developing coordination in cross-functional processes? 2. How can a facilitator help organizations in improving coordination to develop cross-functional processes? The study consists of two parts. The first part is an overview of the dissertation, and the second part comprises six research publications. The theoretical background for the study are the differentiation causing challenges in cross-functional settings, the coordination needed to improve processes, change management principles, methods and tools, and consultation practises. Three of the publications introduce tools for helping in developing prerequisites, planning responsibilities and supporting learning during the cross-functional program. The three other papers present frameworks to help understand and analyse the improvement situation. The main methodological approaches used in this study are design science research, action research and case research. The research data has been collected from ten cases representing different kinds of organizations, processes and developing situations. The data has been collected mainly by observation, semi-structured interviews and questionnaires. The research contributes to the rare literature combining coordination theories and process improvement practises. It also provides additional understanding of a holistic point of view in process improvement situations. The most important contribution is the addition to the theories of facilitating change in process improvement situations. From the managerial point of view, this study gives advice to managers and consultants in planning and executing cross-functional programs. The main factors increasing the need for facilitation are the challenges for differentiation, challenges of organizational change in general, and the novelty of initiatives and improvement practices concerning process development. Organizations need help in creating the prerequisites to change, in planning initiatives, easing conflict management and collaboration between groups, as well as supporting the learning of cross-functional improvement. The main challenges of facilitation are combining the different roles as a consultant, maintaining the ownership for the improvement project with the client, and supporting learning in the client organization.

Customer driven business model – connecting customer value to firm resources in ICT value networks

The objective of this thesis is to provide a business model framework that connects customer value to firm resources and explains the change logic of the business model. Strategic supply management and especially dynamic value network management as its scope, the dissertation is based on basic economic theories, transaction cost economics and the resource-based view. The main research question is how the changing customer values should be taken into account when planning business in a networked environment. The main question is divided into questions that form the basic research problems for the separate case studies presented in the five Publications. This research adopts the case study strategy, and the constructive research approach within it. The material consists of data from several Delphi panels and expert workshops, software pilot documents, company financial statements and information on investor relations on the companies’ web sites. The cases used in this study are a mobile multi-player game value network, smart phone and “Skype mobile” services, the business models of AOL, eBay, Google, Amazon and a telecom operator, a virtual city portal business system and a multi-play offering. The main contribution of this dissertation is bridging the gap between firm resources and customer value. This has been done by theorizing the business model concept and connecting it to both the resource-based view and customer value. This thesis contributes to the resource-based view, which deals with customer value and firm resources needed to deliver the value but has a gap in explaining how the customer value changes should be connected to the changes in key resources. This dissertation also provides tools and processes for analyzing the customer value preferences of ICT services, constructing and analyzing business models and business concept innovation and conducting resource analysis.

Kokonaisvaltaisen toiminnanohjausratkaisun hankinta elintarvikealan yrityksessä

Tämä diplomityö käsittelee toiminnanohjausjärjestelmän hankintaprosessia elintarvikealan yrityksessä. Tutkimuksen lähtökohtana toimivat nykyisessä toiminnanohjausmallissa havaittavat ongelmat sekä uudelle tietojärjestelmäratkaisulle asetetut vaatimukset. Tutkimuksessa keskitytään löytämään kohdeyrityksen vaatimukset täyttävä järjestelmäratkaisu sekä arvioimaan sen vaikutuksia kohdeyrityksen liiketoimintaan. Työn teoriaosuus käsittelee tietojärjestelmän hankintaa yrityksessä; hankinnan taustalla olevia syitä, sen eri vaiheita sekä tietojärjestelmäprojektin kilpailutusta. Lisäksi työssä käsitellään uuden tietojärjestelmän vaikutuksia yrityksen toimintaan. Tietojärjestelmän uusimisen lähtökohta on yrityksen tarve muuttaa nykyistä toimintatapaansa. Tämän tutkimuksen tuloksena kohdeyritykseen valittiin toiminnanohjausratkaisu, joka tukee parhaiten sen liiketoiminnallisia tavoitteita. Uusien työkalujen kautta toiminnanohjausjärjestelmä muuttaa merkittävästi kohdeyrityksen tapaa toimia, ja samalla vaikuttaa radikaalisti tiedon ja prosessien kulkuun yrityksen sisällä.

”Kyllähän nyt pitäs olla jo semmonen aika, että pääsis niin kö keskustelemhan näistä asioista.” Tutkimus lappilaisten sotavankien, partisaanien uhrien ja huutolaisten elämänkulusta, voimavaroista, terveydestä ja sairauksista

Research into the course of life, mental stamina and health status of wartime prisoners, victims of Soviet partisan attacks, and paupers in Finnish Lapland The basis of this research comprised the issues raised during the interviews conducted in my work as a general practitioner in Lapland, regarding factors that have possibly affected the life stories and health conditions of Lappish people who had lived through the war as war prisoners, victims of partisan attacks, or paupers. The purpose of the study was to describe how the different life phases and experiences emerged from the interviewees’ stories and to identify their mental stamina. Another goal was to make observations on their health status, in which the main emphasis became to address mental symptoms. The cohort consisted of elderly Finns who lived in Lapland during the war and experienced war imprisonment, pauperism, or became victims of partisan attacks. All three groups consisted of 12 interviewees. The interview transcripts were read several times and then investigated using the content analysis methods applicable to the material. The research methodology was based on building awareness and understanding. Thematic tagging and data coding were used as structured analysis tools. In all three groups most of the interviewees clearly identified their mental stamina, the most fundamental of which were home, family and work. The war prisoners’ injuries and nervous sensibility symptoms had been shown in earlier studies on war prisoners, and on this basis they had been granted disability pensions. However, many of them had suppressed their traumatic experiences and mental difficulties, and they could not talk about these issues until at the time of these interviews held at old age. Four of them still suffered from a post-traumatic stress disorder. The victims of Soviet partisans had had to carry their mental load alone for decades before the cruel ravages on civilians in remote areas of Lapland became publicly known. Most of them still had disturbing nervous sensibility symptoms. Four interviewees had a post-traumatic stress disorder, and in addition to these, the mental symptoms of one had developed into a post-traumatic stress disorder during old age. Many of the interviewees who had been left paupers remembered their childhood as filled with grief and feelings of inferiority, and had nightmares relating to their wartime experiences. Yet none of them suffered from post-traumatic stress disorder. The results showed that the exceptional suffering caused by the war, the wartime imprisonment and the devastating attacks by Soviet partisans had led especially to mental difficulties. These were left almost completely unnoticed in the post-war conditions, and the war victims were unable to seek help on their own. Based on the results, our health care for the elderly should focus on familiarization with the individual experiences and life stories of each elderly person. This can facilitate geriatric diagnostics and individual therapy planning. Empathic familiarization with the life experiences of the elderly may strengthen their mental stamina and improve the quality of successful aging.

Drivers and Barriers of Collaboration in the Value Chain of Paperboard-Packed Consumer Goods

Value chain collaboration has been a prevailing topic for research, and there is a constantly growing interest in developing collaborative models for improved efficiency in logistics. One area of collaboration is demand information management, which enables improved visibility and decrease of inventories in the value chain. Outsourcing of non-core competencies has changed the nature of collaboration from intra-enterprise to cross-enterprise activity, and this together with increasing competition in the globalizing markets have created a need for methods and tools for collaborative work. The retailer part in the value chain of consumer packaged goods (CPG) has been studied relatively widely, proven models have been defined, and there exist several best practice collaboration cases. The information and communications technology has developed rapidly, offering efficient solutions and applications to exchange information between value chain partners. However, the majority of CPG industry still works with traditional business models and practices. This concerns especially companies operating in the upstream of the CPG value chain. Demand information for consumer packaged goods originates at retailers' counters, based on consumers' buying decisions. As this information does not get transferred along the value chain towards the upstream parties, each player needs to optimize their part, causing safety margins for inventories and speculation in purchasing decisions. The safety margins increase with each player, resulting in a phenomenon known as the bullwhip effect. The further the company is from the original demand information source, the more distorted the information is. This thesis concentrates on the upstream parts of the value chain of consumer packaged goods, and more precisely the packaging value chain. Packaging is becoming a part of the product with informative and interactive features, and therefore is not just a cost item needed to protect the product. The upstream part of the CPG value chain is distinctive, as the product changes after each involved party, and therefore the original demand information from the retailers cannot be utilized as such – even if it were transferred seamlessly. The objective of this thesis is to examine the main drivers for collaboration, and barriers causing the moderate adaptation level of collaborative models. Another objective is to define a collaborative demand information management model and test it in a pilot business situation in order to see if the barriers can be eliminated. The empirical part of this thesis contains three parts, all related to the research objective, but involving different target groups, viewpoints and research approaches. The study shows evidence that the main barriers for collaboration are very similar to the barriers in the lower part of the same value chain; lack of trust, lack of business case and lack of senior management commitment. Eliminating one of them – the lack of business case – is not enough to eliminate the two other barriers, as the operational model in this thesis shows. The uncertainty of the future, fear of losing an independent position in purchasing decision making and lack of commitment remain strong enough barriers to prevent the implementation of the proposed collaborative business model. The study proposes a new way of defining the value chain processes: it divides the contracting and planning process into two processes, one managing the commercial parts and the other managing the quantity and specification related issues. This model can reduce the resistance to collaboration, as the commercial part of the contracting process would remain the same as in the traditional model. The quantity/specification-related issues would be managed by the parties with the best capabilities and resources, as well as access to the original demand information. The parties in between would be involved in the planning process as well, as their impact for the next party upstream is significant. The study also highlights the future challenges for companies operating in the CPG value chain. The markets are becoming global, with toughening competition. Also, the technology development will most likely continue with a speed exceeding the adaptation capabilities of the industry. Value chains are also becoming increasingly dynamic, which means shorter and more agile business relationships, and at the same time the predictability of consumer demand is getting more difficult due to shorter product life cycles and trends. These changes will certainly have an effect on companies' operational models, but it is very difficult to estimate when and how the proven methods will gain wide enough adaptation to become standards.

Varasto- ja hankintamodulin kehittäminen toiminnanohjausjärjestelmään

Tässä diplomityössä tarkoituksena on kerätä yhteen toiminnanohjausjärjestelmän varasto- ja hankintamodulin kehittämisessä tarvittavaa teoriatietoa, sekä Nestix Oy:n asiakkaiden ja joidenkin muiden yritysten tarpeita kyseiselle ohjelmistolle. Teoria ja tarpeet yhdistetään karkeaksi ohjelmiston tarvemäärittelyksi, jonka perusteella Nestix Oy toteuttaa uudet modulit toiminnanohjausjärjestelmäänsä. Tutkimuksissa havaittiin, että yrityksillä on hyvin samankaltaisia tarpeita varastojen ja hankintojen hallintaan. Varastoinnin ja hankinnan prosessit poikkeavat hyvin vähän yritysten välillä. Samoja perinteisiä logistiikan perustyökaluja käytetään miltei kaikissa yrityksissä. Tulevaisuuden houkuttelevimpana kehitysalueena voidaan pitää ohjelmistojen internet-pohjaisuutta, joka mahdollistaa ohjelmiston käyttämisen mistäpäin maailmaa tahansa ilman erillisiä ohjelmistoasennuksia. Tutkimuksen jälkeen Nestix-ohjelmistoperheeseen toteutettiin integroidut hankinnan sekä varastoinnin modulit. Ohjelmaa on kehitetty tutkimuksen tekemisen jälkeen eteenpäin ja sitä on myyty useaan Euroopan maahan osana Nestix toiminnanohjausjärjestelmää.

Tilastollinen tutkimus ohjelmiston laatuun vaikuttavista tekijöistä

Tämä työ on tehty osana MASTO-tutkimushanketta, jonka tarkoituksena on kehittää ohjelmistotestauksen adaptiivinen referenssimalli. Työ toteutettiin tilastollisena tutkimuksena käyttäen survey-menetelmää. Tutkimuksessa haastateltiin 31 organisaatioyksikköä eri puolelta suomea, jotka tekevät keskikriittisiä sovelluksia. Tutkimuksen hypoteeseina oli laadun riippuvuus ohjelmistokehitysmenetelmästä, asiakkaan osallistumisesta, standardin toteutumisesta, asiakassuhteesta, liiketoimintasuuntautuneisuudesta, kriittisyydestä, luottamuksesta ja testauksen tasosta. Hypoteeseista etsittiin korrelaatiota laadun kanssa tekemällä korrelaatio ja regressioanalyysi. Lisäksi tutkimuksessa kartoitettiin minkälaisia ohjelmistokehitykseen liittyviä käytäntöjä, menetelmiä ja työkaluja organisaatioyksiköissä käytettiin, ongelmia ja parannusehdotuksia liittyen ohjelmistotestaukseen, merkittävimpiä tapoja asiakkaan vaikuttamiseksi ohjelmiston laatuun sekä suurimpia hyötyjä ja haittoja ohjelmistokehityksen tai testauksen ulkoistamisessa. Tutkimuksessa havaittiin, että laatu korreloi positiivisesti ja tilastollisesti merkitsevästi testauksen tason, standardin toteutumisen, asiakasosallistumisen suunnitteluvaiheessa sekä asiakasosallistumisen ohjaukseen kanssa, luottamuksen ja yhden asiakassuhteeseen liittyvän osakysymyksen kanssa. Regressioanalyysin perusteella muodostettiin regressioyhtälö, jossa laadun todettiin positiivisesti riippuvan standardin toteutumisesta, asiakasosallistumisesta suunnitteluvaiheessa sekä luottamuksesta.

Logistisen tiedon hallita toimitusprojektissa

Distributed supply chains, tight delivery times and tailor made products are typical for international project business. This type of environment sets great challenges for logistics management. The scope of this work was to study logistics and information management in delivery projects. The logistic information of delivery project is divided into four categories: The information used to plan, execute and follow up the material flow and the information directly embedded into material flow. On the practical study the operations of the target company are dived into main processes supporting project execution. Logistic information is studied by modelling information flows between the processes. The aim was to identify the information crucial for project materials management and describe the flow of information between the processes. Results of the study show that the information related to execution of material flow is usually emphasized when it comes to operations and tools for data management. The traditional system tools poorly support the planning of material flow in project environment. In addition the significance of clearly defined and documented practices is highlighted.