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.

O efeito da distribuição sobre o market share em diferentes canais

Apesar dos avanços nos estudos sobre os efeitos das estratégias de canais de distribuição, a relação entre distribuição e participação de mercado é ainda um tópico pouco explorado, especialmente em mercados emergentes. Por essa razão, a proposta central deste artigo é investigar a relação entre a variáveis de distribuição e market share no mercado brasileiro, especificamente no setor de bebidas, comparando dois importantes tipos de canais do mercado de consumo: grandes e pequenos supermercados. Para tanto, foi conduzida uma pesquisa empírica com base em um banco de dados contando com mais de 180 Stock Keeping Unit (SKUs) comercializados por três fabricantes na região sudeste do Brasil. Por meio de análises estatísticas, os resultados indicam existir uma relação convexa e crescente entre as variáveis estudadas, ou seja, existe um ponto de inflexão no qual o crescimento do market share é mais acentuado em razão da distribuição. Além disso, verificou-se que as curvas que descrevem essas variáveis apresentam efeitos diferentes quando comparados grandes e pequenos supermercados.

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.

Extracts of Ascaris suum egg and adult worm share similar immunosuppressive properties

Adult Ascaris suum body extract (Asc) prepared from male and female worms (with stored eggs) down-regulates the specific immune response of DBA/2 mice to ovalbumin (OA) and preferentially stimulates a Th2 response to its own components, which is responsible for the suppression of the OA-specific Th1 response. Here, we investigated the participation of soluble extracts prepared from male or female worms or from eggs (E-Asc) in these immunological events. Extracts from either sex (1 mg/animal) or E-Asc (0.35 or 1 mg protein/animal) suppressed the delayed-type hypersensitivity (DTH) reaction (60-85%), proliferative response (50-70%), IL-2 and IFN-gamma secretion (below detection threshold) and IgG1 antibody production (70-90%) of DBA/2 mice to OA. A dose of 0.1 mg E-Asc/animal did not change DTH or proliferation, but was as effective as 0.35 mg in suppressing IL-2 and IFN-gamma, and OA-specific IgG1 antibodies. Lymph node cells from DBA/2 mice injected with Asc (1 mg/animal) or a high dose of E-Asc (1 mg protein/animal) secreted IL-4 upon in vitro stimulation with concanavalin A. As previously demonstrated for Asc, the cytokine profile obtained with the E-Asc was dose dependent and changed towards Th1 when a low dose (0.1 mg protein/animal) was used. Taken together, these results suggest that adult worms of either sex and eggs induce the same type of T cell response and share similar immunosuppressive properties.

Heparan sulphate, its derivatives and analogues share structural characteristics that can be exploited, particularly in inhibiting microbial attachment

Heparan sulphate (HS) and the related polysaccharide, heparin, exhibit conformational and charge arrangement properties, which provide a degree of redundancy allowing several seemingly distinct sequences to exhibit the same activity. This can also be mimicked by other sulphated polysaccharides, both in overall effect and in the details of interactions and structural consequences of interactions with proteins. Together, these provide a source of active compounds suitable for further development as potential drugs. These polysaccharides also possess considerable size, which bestows upon them an additional useful property: the capability of disrupting processes comprising many individual interactions, such as those characterising the attachment of microbial pathogens to host cells. The range of involvement of HS in microbial attachment is reviewed and examples, which include viral, bacterial and parasitic infections and which, in many cases, are now being investigated as potential targets for intervention, are identified.

Sugarcane spirit market share simulation: an application of conjoint analysis

This study evaluated the influence of packaging and labeling attributes of sugarcane spirit on consumers' behavior by applying the results of conjoint analysis in sugarcane spirit market share simulation. Firstly, a conjoint analysis was performed aiming to estimate the part-worths of each consumer for some sugarcane spirit packaging and labeling attributes. These part-worths were used in the market share simulation using the maximum utility model. It was observed that some packaging and labeling attributes affected consumer's purchase intention and that most consumers showed a similar preference pattern regarding these attributes. These consumers showed preference for the Seleta brand, which was bottled in 700 mL clear glass bottles with a metal screw cap that bore a label illustration unrelated to sugarcane spirit production process and had the information "aged 36 months in oak barrels". This study also showed that conjoint analysis and the use of its results in the market share simulation proved important tools to better understand consumer behavior towards intention to purchase sugarcane spirit.