Competition for FDI and profit shifting: On the effects of subsidies and tax breaks

We investigate competition for FDI within a region when a foreign multinational rm can profitably exploit differences in statutory corporate tax rates by shifting taxable pro ts to lower-tax jurisdictions. In such framework we show that targeted tax competition may lead to higher welfare for the region as a whole than lump-sum subsidies when the difference in statutory corporate tax rates and/or their average is high enough. Tax competition is also preferable from an efficiency point of view (overall surplus) by changing the firm's investment decision when pro t shifting motivations induce the rm to locate in the (before tax) least pro table country.

A utilização dos preços de transferência pelas empresas multinacionais como mecanismo de evasão fiscal

Dissertação de mestrado em Direito Tributário e Fiscal

Siirtohinnoittelun kehitys ja tulevaisuus vuosien 1994–2014 ammattilehtikirjoitusten perusteella

Pro gradu-tutkimuksen tarkoituksena on selvittää, miten siirtohinnoittelun kehitys näkyy ammattikirjoituksissa 20 vuoden aikana sekä mihin suuntaan siirtohinnoittelu on kehittymässä tulevaisuudessa. Mitkä ovat siirtohinnoittelun riskit ja edut tutkimusaineiston perusteella ja minkälaisista näkökulmista siirtohinnoittelusta on 20 vuoden aikana kirjoitettu. Artikkeleista pyritään löytämään, minkälaisia eroja on suomalaisen ja kansainvälisen kirjoittelun väliltä. Tämä on laadullinen tutkimus, jossa käytetään tutkimusmenetelmänä sisällönanalyysia. Tutkimuksessa on sisällönanalyysin mukaisesti luokittelua, teemoittelua sekä vertailua. Tutkimusaineisto koostuu kolmesta lehdestä Verotus, Tilintarkastus-lehti, nykyään Balanssi ja The Accounting Review. Lehdistä on kerätty siirtohinnoittelua käsittelevät artikkelit 20 vuoden ajalta. Tutkimustulosten perusteella näkyy siirtohinnoittelun kehitys sekä kuinka aiheesta on tullut entistä keskeisempi. Siirtohinnoittelu on nyt merkittävässä roolissa kansainvälisessä verotuksessa. Haasteena nähdään markkinaehtoisen hinnan asettaminen oikeaan arvoon. Tärkeänä luokkana nousi siirtohinnoittelun kehittäminen. Myös valtioiden uhka siitä, että siirtohinnoittelun kautta verovaroja siirtyy toisiin valtioihin, oli yksi esiin noussut teema. Johtopäätöksenä voidaan todeta, että siirtohinnoittelu on problemaattinen verotuksen aihe, koska selkeää suoraa siirtohintaa ei aina pystytä antamaan tuotteelle, palvelulle tai rahoitukselle, vaan hinta on veteen piirretty viiva. Siirtohinnoittelua pidetään uhkana valtioiden veropohjan rappeutumiselle, jos sen avulla siirretään varoja alemman verotuksen valtioihin. Konsernit toimivat entistä laajemmin eri valtioissa, joten niiden tavoitteena on suunnitella eri konsernin osien tulosta. Tulevaisuudessa on paljon kehityskohtia ja tarpeita siirtohinnoittelun alueella. Kehitykseen vaikuttavat valtioiden yhteisöveropoliittiset päätökset sekä valtioiden omat lainsäädännöt sekä valtioiden sitoutuminen OECD:n säännöksiin, joiden avulla pyritään yhtenäisiin toimintamalleihin. Jatkossa tutkimusta voisi laajentaa kansainvälisemmäksi sekä vielä syvemmin voisi miettiä myös kehityksen suuntia ja niiden vaikutuksia.

New insights on measuring bank branches efficiency through DEA:transactional, operational, and profit assessments

This thesis presents a number of methodological developments that were raised by a real life application to measuring the efficiency of bank branches. The advent of internet banking and phone banking is changing the role of bank branches from a predominantly transaction-based one to a sales-oriented role. This fact requires the development of new forms of assessing and comparing branches of a bank. In addition, performance assessment models must also take into account the fact that bank branches are service and for-profit organisations to which providing adequate service quality as well as being profitable are crucial objectives. This study analyses bank branches performance in their new roles in three different areas: their effectiveness in fostering the use of new transaction channels such as the internet and the telephone (transactional efficiency); their effectiveness in increasing sales and their customer base (operational efficiency); and their effectiveness in generating profits without compromising the quality of service (profit efficiency). The chosen methodology for the overall analysis is Data Envelopment Analysis (DEA). The application attempted here required some adaptations to existing DEA models and indeed some new models so that some specialities of our data could be handled. These concern the development of models that can account for negative data, the development of models to measure profit efficiency, and the development of models that yield production units with targets that are nearer to their observed levels than targets yielded by traditional DEA models. The application of the developed models to a sample of Portuguese bank branches allowed their classification according to the three performance dimensions (transactional, operational and profit efficiency). It also provided useful insights to bank managers regarding how bank branches compare between themselves in terms of their performance, and how, in general, the three performance dimensions are connected between themselves.

Scanning electron microscopic study of the in situ effect of salivary stimulation on erosion and abrasion in human and bovine enamel

This in situ study investigated, using scanning electron microscopy, the effect of stimulated saliva on the enamel surface of bovine and human substrates submitted to erosion followed by brushing abrasion immediately or after one hour. During 2 experimental 7-day crossover phases, 9 previously selected volunteers wore intraoral palatal devices, with 12 enamel specimens (6 human and 6 bovine). In the first phase, the volunteers immersed the device for 5 minutes in 150 ml of a cola drink, 4 times a day (8h00, 12h00, 16h00 and 20h00). Immediately after the immersions, no treatment was performed in 4 specimens (ERO), 4 other specimens were immediately brushed (0 min) using a fluoride dentifrice and the device was replaced into the mouth. After 60 min, the other 4 specimens were brushed. In the second phase, the procedures were repeated but, after the immersions, the volunteers stimulated the salivary flow rate by chewing a sugar-free gum for 30 min. Enamel superficial alterations of all specimens were then evaluated using a scanning electron microscope. Enamel prism core dissolution was seen on the surfaces submitted to erosion, while on those submitted to erosion and to abrasion (both at 0 and 60 min) a more homogeneous enamel surface was observed, probably due to the removal of the altered superficial prism layer. For all the other variables - enamel substrate and salivary stimulation -, the microscopic pattern of the enamel specimens was similar.

Relationship between maxillary and mandibular base lengths and dental crowding in patients with complete Class II malocclusions

Objective: To verify the relationship between maxillary and mandibular effective lengths and dental crowding in patients with Class II malocclusions. Materials and Methods: The sample comprised 80 orthodontic patients with complete Class II malocclusions in the permanent dentition (47 male, 33 female) who were divided into two groups according to the amount of mandibular tooth-arch size discrepancy. The maxillary and mandibular effective lengths (Co-A and Co-Gn) and tooth-arch size discrepancies were measured on the initial cephalograms and dental casts, respectively. Intergroup comparisons of apical base lengths were performed with independent t-tests. Correlation between base length and dental crowding was examined by means of Pearson's correlation coefficient (P < .05). Results: Patients with Class II malocclusion and moderate to severe crowding had significantly smaller maxillary and mandibular effective lengths than subjects with the same malocclusion and slight mandibular crowding. A weak inverse correlation was also found between maxillary and mandibular effective lengths and the severity of dental crowding. Conclusion: Decreased maxillary and mandibular effective lengths constitute an important factor associated with dental crowding in patients with complete Class II malocclusion. (Angle Orthod. 2011;81:217-221.)

Effect of Different Fluoride Concentrations of Experimental Dentifrices on Enamel Erosion and Abrasion

It has been suggested that fluoride products are able to reduce erosive tooth wear. Thus, the purpose of this in vitro study was to evaluate the effect of dentifrices with different fluoride concentrations as well as of a low-fluoridated dentifrice supplemented with trimetaphosphate (TMP) on enamel erosion and abrasion. One hundred twenty bovine enamel blocks were assigned to the following experimental dentifrices: placebo, 1,100 mu g F/g, 500 mu g F/g plus 3% TMP and 5,000 mu g F/g. The groups of enamel blocks were additionally subdivided into conditions of erosion (ERO) and of erosion plus abrasion (ERO + ABR). For 7 days, the blocks were subjected to erosive challenges (immersion in Sprite (R) 4 times a day for 5 min each time) followed by a remineralizing period (immersion in artificial saliva between erosive challenges for 2 h). After each erosive challenge, the blocks were exposed to slurries of the dentifrices (10 ml/sample for 15 s). Sixty of the blocks were additionally abraded by brushing using an electric toothbrush (15 s). The alterations of the enamel were quantified using the Knoop hardness test and profilometry (measurements in micrometers). The data were analyzed using a 2-way ANOVA test followed by a Bonferroni correction (p < 0.05). In in vitro conditions, the 5,000 mu g F/g and 500 mu g F/g plus 3% TMP dentifrices had a greater protective effect when compared with the 1,100 mu g F/g dentifrice, under both ERO and ERO + ABR conditions. The results suggest that dentifrices alone are not capable of completely inhibiting tooth wear. Copyright (C) 2010 S. Karger AG, Basel

The efficacy of a highly concentrated fluoride dentifrice on bovine enamel subjected to erosion and abrasion

Background. Researchers have proposed the use of fluoride for the prevention of enamel wear; however, only limited information is available about the impact of fluoridated dentifrices. Because tooth wear is a well-recognized dental problem, the authors conducted an in situ, ex vivo study to assess the efficacy of a highly concentrated fluoride dentifrice on bovine enamel subjected to erosion and abrasion. Methods. The authors conducted a double-blind, crossover in situ study consisting of three phases (seven days each). In each phase, the authors tested one of the dentifrices (5,000 parts per million fluoride [F]; 1,100 ppm F; no F). They performed erosive challenges with the use of cola drink (60 seconds, four times per day) and abrasive challenges via toothbrushing (30 seconds, four times per day). The authors determined the enamel loss via profilometry. Results. The authors tested the data by using two-way analysis of variance (P <.05). For the erosion-plus-abrasion condition, the study results showed that enamel wear was significantly higher than that with erosion alone. The findings showed no significant differences between the dentifrices regarding enamel wear. Conclusions. Within the in situ, ex vivo conditions of this study, the authors concluded that the highly concentrated fluoride dentifrice did not have a protective effect on enamel against erosion and erosion plus toothbrushing abrasion. Clinical Implications. Patients at risk of developing enamel erosion should benefit from preventive measures other than fluoride dentifrice, because even a highly concentrated fluoride dentifrice does not appear to prevent enamel erosion.

Citrate- vs. acetate-based dialysate in bicarbonate haemodialysis: consequences on haemodynamics, coagulation, acid-base status, and electrolytes.

BACKGROUND: A concentrate for bicarbonate haemodialysis acidified with citrate instead of acetate has been marketed in recent years. The small amount of citrate used (one-fifth of the concentration adopted in regional anticoagulation) protects against intradialyser clotting while minimally affecting the calcium concentration. The aim of this study was to compare the impact of citrate- and acetate-based dialysates on systemic haemodynamics, coagulation, acid-base status, calcium balance and dialysis efficiency. METHODS: In 25 patients who underwent a total of 375 dialysis sessions, an acetate dialysate (A) was compared with a citrate dialysate with (C+) or without (C) calcium supplementation (0.25 mmol/L) in a randomised single-blind cross-over study. Systemic haemodynamics were evaluated using pulse-wave analysis. Coagulation, acid-base status, calcium balance and dialysis efficiency were assessed using standard biochemical markers. RESULTS: Patients receiving the citrate dialysate had significantly lower systolic blood pressure (BP) (-4.3 mmHg, p < 0.01) and peripheral resistances (PR) (-51 dyne.sec.cm-5, p < 0.001) while stroke volume was not increased. In hypertensive patients there was a substantial reduction in BP (-7.8 mmHg, p < 0.01). With the C+ dialysate the BP gap was less pronounced but the reduction in PR was even greater (-226 dyne.sec.cm-5, p < 0.001). Analyses of the fluctuations in PR and of subjective tolerance suggested improved haemodynamic stability with the citrate dialysate. Furthermore, an increase in pre-dialysis bicarbonate and a decrease in pre-dialysis BUN, post-dialysis phosphate and ionised calcium were noted. Systemic coagulation activation was not influenced by citrate. CONCLUSION: The positive impact on dialysis efficiency, acid-base status and haemodynamics, as well as the subjective tolerance, together indicate that citrate dialysate can significantly contribute to improving haemodialysis in selected patients.

Reconsolidation of the soil surface after tillage discontinuity, with and without cultivation, related to erosion and its prediction with RUSLE

Site-specific regression coefficient values are essential for erosion prediction with empirical models. With the objective to investigate the surface-soilconsolidation factor, Cf, linked to the RUSLE's prior-land-use subfactor, PLU, an erosion experiment using simulated rainfall on a 0.075 m m-1 slope, sandy loam Paleudult soil, was conducted at the Agriculture Experimental Station of the Federal University of Rio Grande do Sul (EEA/UFRGS), in Eldorado do Sul, State of Rio Grande do Sul, Brazil. Firstly, a row-cropped area was excluded from cultivation (March 1995), the existing crop residue removed from the field, and the soil kept clean-tilled the rest of the year (to get a degraded soil condition for the intended purpose of this research). The soil was then conventional-tilled for the last time (except for a standard plot which was kept continuously cleantilled for comparison purposes), in January 1996, and the following treatments were established and evaluated for soil reconsolidation and soil erosion until May 1998, on duplicated 3.5 x 11.0 m erosion plots: (a) fresh-tilled soil, continuously in clean-tilled fallow (unit plot); (b) reconsolidating soil without cultivation; and (c) reconsolidating soil with cultivation (a crop sequence of three corn- and two black oats cycles, continuously in no-till, removing the crop residues after each harvest for rainfall application and redistributing them on the site after that). Simulated rainfall was applied with a Swanson's type, rotating-boom rainfall simulator, at 63.5 mm h-1 intensity and 90 min duration, six times during the two-and-half years of experimental period (at the beginning of the study and after each crop harvest, with the soil in the unit plot being retilled before each rainfall test). The soil-surface-consolidation factor, Cf, was calculated by dividing soil loss values from the reconsolidating soil treatments by the average value from the fresh-tilled soil treatment (unit plot). Non-linear regression was used to fit the Cf = e b.t model through the calculated Cf-data, where t is time in days since last tillage. Values for b were -0.0020 for the reconsolidating soil without cultivation and -0.0031 for the one with cultivation, yielding Cf-values equal to 0.16 and 0.06, respectively, after two-and-half years of tillage discontinuation, compared to 1.0 for fresh-tilled soil. These estimated Cf-values correspond, respectively, to soil loss reductions of 84 and 94 %, in relation to soil loss from the fresh-tilled soil, showing that the soil surface reconsolidated intenser with cultivation than without it. Two distinct treatmentinherent soil surface conditions probably influenced the rapid decay-rate of Cf values in this study, but, as a matter of a fact, they were part of the real environmental field conditions. Cf-factor curves presented in this paper are therefore useful for predicting erosion with RUSLE, but their application is restricted to situations where both soil type and particular soil surface condition are similar to the ones investigate in this study.