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.

Chinese multinational corporations in Brazil: strategies and implications in energy and telecom sectors

This study aims to understand how Chinese enterprises acted in Brazilian energy and telecommunication sectors in the past ten years and whether they would be leading to an increase in the asymmetries between Brazil and China. It argues that the asymmetries presented in the relations are due in large part to successful Chinese enterprises' strategies.

Economic sanctions and human rights: an analysis of competing enforcement strategies in Latin America

This article addresses the consequences of economic sanctions for the protection of human rights in Latin America. The literature on sanctions and compliance informs three hypotheses, which investigate the relationship between sanctions and the level of rights protection in two groups of countries: those that were targeted by sanctions and those that were not. Using data from the Political Terror Scale (PTS) and from Freedom House, I find empirical evidence that sanctions do improve the level of protection in countries that were not targeted. This finding can be explained by the deterrent effect attributed to sanctions by the compliance literature, broadly interpreted. The presence of economic sanctions in a given year increases the probability of observing better human rights practices by almost 50%. These results hold for the 12 Latin American countries that were not subject to economic sanctions for the period 1976-2004.

Rooting of hardwood cuttings of Roxo de Valinhos fig (Ficus carica L.) with different propagation strategies

The objective of this study was to evaluate the substrate, cuttings collection time, the position and the cutting depth, and the propagation environment on rooting of 'Purple Valinhos' fig tree cuttings in Southwestern Paraná, Brazil. Two experiments were carried out at UTFPR, Câmpus Dois Vizinhos, with hardwoods cuttings from Roxo de Valinhos fig tree. The first experiment used a randomized block design, in 3 x 3 x 2 factorial (substrate x environment x collection time), with four replications of 10 cuttings per plot. The cuttings were collected in the first fifteen days of July and August. The substrates were sand, soil and the mixture of these [1:1 (v / v)]. The environments used were open sky, tunnel with plastic cover and tunnel with half-shade black net cover. The second experiment used a randomized block design, 2 x 2 x 3 factorial (shoot cutting position x soil cover x shoot cutting depth), with four replications of 12 cuttings per plot. In the factor position, the vertically (0 º inclination) and inclined (45 º inclination) shoot cuttings were evaluated. Soil cover was tested with mulching plastic cover or not. The tested depths were 1/3, 1/2 and 2/3 in relation to the total length of the shoot cutting. In both experiments, the following were analyzed: rooting and mortality indices, number of leaves and primary shoots, length of the three largest roots per cutting. It was conclude that, the protected environment with plastic cover on sand as substrate must recommended for the rooting of fig estaca, collecting them in the first half of July. The inclination position and cutting depth of the estaca and the substrate coverage with plastic mulching did not influence the results.

Financial strategies for minimizing corporate income taxes under Brazil's new global tax system

In 1996, Brazil adopted a worldwide income tax system for corporations. This system represents a fundamental change in how the Brazílian government treats multinational transactions and the tax minimizing strategies relevant to businesses. In this article, we describe the conceptual basis for worldwide tax systems and the problem of double taxation that they create. Responses to double taxation by both the governments and the priva te sector are considered. Namely, the imperfect mechanisms developed by Brazil and other countries for mitigating double taxation are analyzed. We ultimately focus on the strategies that companies utilize in order not only to avoid double texetion, but also to take advantage of tax havens.

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.

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.

STRATEGIES FOR SUPERIOR PERFORMANCE IN RECESSIONS: PRO OR COUNTER-CYCLICAL?

Recessions are recurring events in which most firms suffer severe impacts while others are less affected or may even prosper. Strategic management has made little progress in understanding such performance differences. In a scenario of decreased demand, intensified competition, and higher uncertainty, most firms try to survive by pro-cyclically cutting costs and investments. But firms could take advantage of undervalued resources in the market to counter-cyclically invest in new business opportunities to overtake competitors. We survey Brazilian firms in various industries about the 2008-2009 recession and analyze data using PLS-SEM. We find that while most firms pro-cyclically reduce costs and investments in recessions, a counter-cyclical strategy of investing in opportunities created by changes in the market enables superior performance. Most successful are firms with a propensity to recognize opportunities, an entrepreneurial orientation to invest, and the flexibility to efficiently implement investments.

Evaluation of collaborative strategies for ecotourism and recreational activities in natural parks of Rio de Janeiro

In the city of Rio de Janeiro, the management agencies of environmental conservation units of the park type have been attempting to meet five primary objectives set by the National System for Conservation Units (NSCU), using participatory management guidelines for these units. Two of these objectives relate to the development of recreation activities that involve contact with nature and ecological tourism. This article presents the analyses and conclusions regarding the implementation of collaborative strategies with businesses to achieve such objectives; it is part of a series of research studies having a broader scope. Case studies were conducted in eight parks by means of dozens of interviews with managers and other interested social actors, as well as by documentary research and direct observation. The results suggest that the ecotourism objective is still far from being reached, and that the collaborative strategies used are not sufficient to compensate for the organizational, material and human limitations that encumber these agencies. It was also concluded for the sample that there lacks a strategic vision on the part of the three branches of government involved in the management of these parks in the sense of viewing ecotourism in the city's conservation units as a powerful means to foster local sustainable development.