lnternational transfer pricing strategies for minimizing global income taxes

Optimal financiai strategies are criticai for long term survival in competitive international markets. Financial strategies pertaining to transfer pricing have become increasingly important as income tax authorities seek additional revenues through increased monitoring of company practices. In this first of two articles, optimal tax strategies are presented after reviewing the transfer pricing concept and the rationale underlying governments' increased focus on transfer pricing. In the second forthcoming article, we analyze the effect of government restrictions on optimal pricing strategies.

International transfer pricing restrictions: impact on corporate financial policy

Transfer pricing is a pervasive issue that presents significant tax savings potential concerning international enterprises. The authors discuss company incentives to manage transfer prices in an article appearing in the preceding issue of this journal. In response to these incentives, governments have increasingly enacted and enforced domestic restrictions on transfer prices. In this article, contemporary norms restricting transfer pricing are analyzed. The OEGO and US pricing standards are assessed and Brazil's recent application of these standards is considered. Transfer pricing methods are described and evidence of their use is presented. We conclude by describing an intercompany transfer pricing policy intended to facilitate internaI financiaI management and minimize externaI tax threats.

Taking the "cross" out of cross-cultural transfer of management practice

Multi-national enterprises often attempt to replicate successful management practices in "foreign" environments. However, such practices may be ethnocentric because they fit the assumptions, behaviors, expectations, and values of the home cultural environment. Unless the underlying assumptions are shared, transfer to a differing environment may fail. Even if the focus is shifted from cultural differences to implementation, implementation approaches may also be criticized as ethnocentric for the same reasons. In this article, a non-ethnocentric model is expanded and used to test the portability of one management practice, performance appraisal, from the USA to Brazil. This "Test of Portability" may help managers understand which management practices are portable, and, perhaps even more valuable, provide a rationale for adaptation or rejection.

THE ROLE OF EARNINGS PERSISTENCE IN VALUATION ACCURACY AND THE TIME HORIZON

ABSTRACT Based on the assumption that earnings persistence has implications for both financial analysis and compensation contracts, the aim of this paper is to investigate the role of earnings persistence assuming that (i) more persistent earnings are likely to be a better input to valuation models and (ii) more persistent earnings are likely to serve as a proxy for long-term market and managerial orientation. The analysis is based on Brazilian listed firms from 1995 to 2013, and while we document strong support for the relevance of earnings persistence in financial analysis and valuation, we fail to document a significant relationship between earnings persistence and long-term value orientation. These results are sensitive to different specifications, and additional results suggest that firms' idiosyncratic risk (total risk) is relevant to explain the focus on short-term outcomes (short-termism) across firms. The main contribution of this paper is to offer empirical evidence for the relevance of accounting numbers in both valuation and contractual theories in an emergent market.

Health, sleep and lack of time: relations to domestic and paid work in nurses

OBJECTIVE: To assess whether reported morbidity and complaints of lack of time and sleep are associated with the burden of professional work and housework among nurses. METHODS: A cross-sectional exploratory study was carried out among female nurses and nurse assistants (N=206) of a public hospital in Rio de Janeiro, Brazil. Data were collected by means of a questionnaire. The prevalence ratio and 95% confidence intervals were estimated. RESULTS: Mean duration of professional work and housework time was 40.4 and 31.6 hours/week, respectively. Long professional working time (over 44 hours/week) were associated with mild emotional disorders (PR=1.37; 95% CI: 1.05-1.80), complaints of lack of time for resting/leisure (PR=1.61; 95% CI: 1.31-1.97), housework (PR=1.48; 95% CI: 1.12-1.97), and childcare (PR=1.99; 95% CI: 1.51-2.63). Long housework time (over 28 hours/week) was associated with lower prevalence of lack of time for childcare (PR=0.62; 95% CI: 0.46-0.84). High housework load was associated with lack of personal time and complaints of varicose veins (PR=1.31; 95% CI: 1.14-1.50 and PR=1.31; 95% CI: 1.08-1.58, respectively). Complaints of varicose veins were also frequent among female nurses with a total work load above 84 hours (PR=1.30; 95% CI: 1.05-1.61), though this group has shown a lower prevalence of arterial hypertension and recurrent headaches (PR=0.35; 95% CI: 0.15-0.83 and PR=0.53; 95% CI: 0.32-0.89, respectively). CONCLUSIONS: Results suggest that both professional and home environments are relevant in the evaluation of work overload on nurses' health and their family and social life. It is stressed the need for instruments for analyzing total workload among female populations.

Leisure-time physical activity during pregnancy in the 2004 Pelotas Birth Cohort Study

OBJECTIVE: Physical activity during pregnancy is a poorly investigated subject on population level. The study aimed to describe duration, type and frequency of leisure-time physical activity during pregnancy, and to explore its associated factors. METHODS: A population-based study was carried out during 2004 in Southern Brazil. A total of 4,471 mothers were interviewed soon after delivery. Physical activity was measured using a questionnaire, developed for the study. Results were obtained by Poisson regression. RESULTS: In the sample, 14.8% of women reported to engage in some type of physical activity prior to pregnancy and 12.9% during pregnancy. In the first trimester, 10.4% of all mothers engaged in some type of physical activity; 8.5% in the second trimester and 6.5% in the third trimester. Only 194 mothers (4.3%) were active during the whole pregnancy. In the adjusted analysis, leisure-time physical activity was positively associated with schooling, physical activity advice during prenatal care, and family income (p<0.001), being employed during pregnancy (p=0.05), and number of pregnancies (p=0.02). Walking was the most frequent activity. CONCLUSIONS: The prevalence of leisure-time physical activity is low among Brazilian pregnant women. Although physical activity is not perceived as being pregnancy-threatening, and current guidelines recommend it, this population's behavior does not seem to be changing. Active lifestyle for both pregnant women and future mothers should be encouraged.

Adaptação cultural da versão brasileira do Godin-Shephard Leisure-Time Physical Activity Questionnaire

OBJETIVO: Realizar adaptação cultural para versão brasileira do questionário de atividade física no tempo de lazer e avaliar a validade de conteúdo, praticabilidade, aceitabilidade e confiabilidade.MÉTODOS: Foram realizadas as etapas de tradução, síntese, retrotradução, avaliação por comitê de especialistas e pré-teste, seguidos pela avaliação da praticabilidade, aceitabilidade e confiabilidade (teste-reteste). Os juízes avaliaram as equivalências semântico-idiomática, conceitual, cultural e metabólica. A versão adaptada foi submetida ao pré-teste (n = 20) e teste-reteste (n = 80) em indivíduos saudáveis e pacientes com doenças cardiovasculares, em Limeira, SP, entre 2010 e 2011. A proporção de concordância do comitê de juízes foi quantificada por meio do Índice de Validade de Conteúdo. A confiabilidade foi avaliada segundo critério de estabilidade, com intervalo de 15 dias entre as aplicações, a praticabilidade pelo tempo gasto na entrevista e a aceitabilidade pelo percentual de itens não respondidos e proporção de pacientes que responderam a todos os itens.RESULTADOS: A versão traduzida do questionário apresentou equivalências semântico-idiomática, conceitual, cultural e metabólica adequadas, com substituição de algumas atividades físicas mais adequadas para a população brasileira. A análise da praticabilidade evidenciou curto tempo de aplicação do instrumento (média de 3,0 min). Quanto à aceitabilidade, todos os pacientes responderam a 100% dos itens. A análise do teste-reteste sugeriu estabilidade temporal do instrumento (Índice de Correlação Intraclasse = 0,84).CONCLUSÕES: A versão brasileira do questionário apresentou propriedades de medida satisfatórias. Recomenda-se sua aplicação a populações diversas em estudos futuros, a fim de disponibilizar propriedades de medida robustas.