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.

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.

A JOINT EXPERIMENTAL ANALYSIS OF INVESTOR BEHAVIOR IN IPO PRICING METHODS

This article jointly examines the differences of laboratory versions of the Dutch clock open auction, a sealed-bid auction to represent book building, and a two-stage sealed bid auction to proxy for the “competitive IPO”, a recent innovation used in a few European equity initial public offerings. We investigate pricing, seller allocation, and buyer welfare allocation efficiency and conclude that the book building emulation seems to be as price efficient as the Dutch auction, even after investor learning, whereas the competitive IPO is not price efficient, regardless of learning. The competitive IPO is the most seller allocative efficient method because it maximizes offer proceeds. The Dutch auction emerges as the most buyer welfare allocative efficient method. Underwriters are probably seeking pricing efficiency rather than seller or buyer welfare allocative efficiency and their discretionary pricing and allocation must be important since book building is prominent worldwide.

Follicle and corpus luteum size and vascularity as predictors of fertility at the time of artificial insemination and embryo transfer in beef cattle

Abstract:Two ultrasound based fertility prediction methods were tested prior to embryo transfer (ET) and artificial insemination (AI) in cattle. Female bovines were submitted to estrous synchronization prior to ET and AI. Animals were scanned immediately before ET and AI procedure to target follicle and corpus luteum (CL) size and vascularity. In addition, inseminated animals were also scanned eleven days after insemination to target CL size and vascularity. All data was compared with fertility by using gestational diagnosis 35 days after ovulation. Prior to ET, CL vascularity showed a positive correlation with fertility, and no pregnancy occurred in animals with less than 40% of CL vascularity. Prior to AI and also eleven days after AI, no relationship with fertility was seen in all parameters analyzed (follicle and CL size and vascularity), and contrary, cows with CL vascularity greater than 70% exhibit lower fertility. In inseminated animals, follicle size and vascularity was positive related with CL size and vascularity, as shown by the presence of greater CL size and vascularity originated from follicle with also greater size and vascularity. This is the first time that ultrasound based fertility prediction methods were tested prior to ET and AI and showed an application in ET, but not in AI programs. Further studies are needed including hormone profile evaluation to improve conclusion.

Exogenous induction of ovarian activity and ovulation and transfer of fresh embryos of domestic cat (Felis catus)

The objective of the present study was the exogenous stimulation of ovarian activity and definition of embryo collection, and transfer protocols, in the domestic cat for potential application in non-domestic endangered species. Sixteen adult queens and two adult male reproducers kept in the experimental cat house at the Morphology sector at the Veterinary Department (DVT), UFV, were used in this study. All the queens received a single application of 150 IU Equine Chorionic Gonadotropin (eCG) in the post estrus to induce ovarian activity and 80 to 84 hours later, received a single application of 100 UI Human Chorionic Gonadotropin (hCG) to induce ovulation. After hCG application, only the donor queens were naturally mated. The receptor queens received extra stimulus for induction of ovulation through manipulation of an intravaginal swab. Five to six days after hCG application, the donor queens were subjected to a laparotomy for embryo collection that was performed by trans-horn uterine washing. On average, six embryos were surgically inovulated. They were classified as type I and III compact morula and blastocysts in four receptor queens. Three animals presented pregnancy confirmed by ultrasound at day 36 and two of these animals gave birth to litters of two and four offsprings, respectively, at 66 and 63 days after induction of ovulation. Except for one still birth, all the offspring developed normally.

Methods to classify maize cultivars in use efficiency and response to nitrogen

n plant breeding programs that aim to obtain cultivars with nitrogen (N) use efficiency, the focus is on methods of selection and experimental procedures that present low cost, fast response, high repeatability, and can be applied to a large number of cultivars. Thus, the objectives of this study were to classify maize cultivars regarding their use efficiency and response to N in a breeding program, and to validate the methodology with contrasting doses of the nutrient. The experimental design was a randomized block with the treatments arranged in a split-plot scheme with three replicates and five N doses (0, 30, 60, 120 and 200 kg ha-1) in the plots, and six cultivars in subplots. We compared a method examining the efficiency and response (ER) with two contrasting doses of N. After that, the analysis of variance, mean comparison and regression analysis were performed. In conclusion, the method of the use efficiency and response based on two N levels classifies the cultivars in the same way as the regression analysis, and it is appropriate in plant breeding routine. Thus, it is necessary to identify the levels of N required to discriminate maize cultivars in conditions of low and high N availability in plant breeding programs that aim to obtain efficient and responsive cultivars. Moreover, the analysis of the interaction genotype x environment at experiments with contrasting doses is always required, even when the interaction is not significant.

Comparison of different methods for the determination of total organic carbon and humic substances in Brazilian soils

ABSTRACTAiming to compare three different methods for the determination of organic carbon (OC) in the soil and fractions of humic substances, seventeen Brazilian soil samples of different classes and textures were evaluated. Amounts of OC in the soil samples and the humic fractions were measured by the dichromate-oxidation method, with and without external heating in a digestion block at 130 °C for 30 min; by the loss-on-ignition method at 450 °C during 5 h and at 600 °C during 6 h; and by the dry combustion method. Dry combustion was used as reference in order to measure the efficiency of the other methods. Soil OC measured by the dichromate-oxidation method with external heating had the highest efficiency and the best results comparing to the reference method. When external heating was not used, the mean recovery efficiency dropped to 71%. The amount of OC was overestimated by the loss-on-ignition methods. Regression equations obtained between total OC contents of the reference method and those of the other methods showed relatively good adjustment, but all intercepts were different from zero (p < 0.01), which suggests that more accuracy can be obtained using not one single correction factor, but considering also the intercept. The Walkley-Black method underestimated the OC contents of the humic fractions, which was associated with the partial oxidation of the humin fraction. Better results were obtained when external heating was used. For the organic matter fractions, the OC in the humic and fulvic acid fractions can be determined without external heating if the reference method is not available, but the humin fraction requires the external heating.

Impacts of vinasse and methods of sugarcane harvesting on the availability of K and carbon stock of an Argisol

ABSTRACT Soils of tropical regions are more weathered and in need of conservation managements to maintain and improve the quality of its components. The objective of this study was to evaluate the availability of K, the organic matter content and the stock of total carbon of an Argisol after vinasse application and manual and mechanized harvesting of burnt and raw sugarcane, in western São Paulo.The data collection was done in the 2012/2013 harvest, in a bioenergy company in Presidente Prudente/SP. The research was arranged out following a split-plot scheme in a 5x5 factorial design, characterized by four management systems: without vinasse application and harvest without burning; with vinasse application and harvest without burning; with vinasse application and harvest after burning; without vinasse application and harvest after burning; plus native forest, and five soil sampling depths (0-10 10-20, 20-30, 30-40, 40-50 cm), with four replications. In each treatment, the K content in the soil and accumulated in the remaining dry biomass in the area, the levels of organic matter, organic carbon and soil carbon stock were determined. The mean values were compared by Tukey test. The vinasse application associated with the harvest without burning increased the K content in soil layers up to 40 cm deep. The managements without vinasse application and manual harvest after burning, and without vinasse application with mechanical harvesting without burning did not increase the levels of organic matter, organic carbon and stock of total soil organic carbon, while the vinasse application and harvest after burning and without burning increased the levels of these attributes in the depth of 0-10 cm.

Comparison of methods for classification of the coefficient of variation in papaya

ABSTRACT The objective of this work was to study the distribution of values of the coefficient of variation (CV) in the experiments of papaya crop (Carica papaya L.) by proposing ranges to guide researchers in their evaluation for different characters in the field. The data used in this study were obtained by bibliographical review in Brazilian journals, dissertations and thesis. This study considered the following characters: diameter of the stalk, insertion height of the first fruit, plant height, number of fruits per plant, fruit biomass, fruit length, equatorial diameter of the fruit, pulp thickness, fruit firmness, soluble solids and internal cavity diameter, from which, value ranges were obtained for the CV values for each character, based on the methodology proposed by Garcia, Costa and by the standard classification of Pimentel-Gomes. The results obtained in this study indicated that ranges of CV values were different among various characters, presenting a large variation, which justifies the necessity of using specific evaluation range for each character. In addition, the use of classification ranges obtained from methodology of Costa is recommended.