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.

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.

UM MODELO FUZZY-DEA-GAME PARA ESTRATÉGIAS DE PRODUÇÃO SOB INCERTEZA

Este trabalho desenvolve um novo modelo Fuzzy-DEA-Game (FDG) para apoiar o estabelecimento de estratégias de produção. Esse modelo combina a Análise Envoltória de Dados (DEA) com conceitos da Teoria dos Conjuntos Fuzzy e do Jogo da Barganha de Nash. O modelo permite uma avaliação da eficiência produtiva e econômica dos produtos, o que pode resultar num portfólio de produtos mais rentáveis e de interesse do mercado consumidor. O modelo foi aplicado em uma empresa do segmento de energia. Os resultados obtidos com a aplicação do modelo FDG mostraram-se aderentes à realidade da empresa estudada e forneceram metas para a redução dos níveis de recursos (entradas) necessários para a fabricação dos produtos e para aumento dos níveis de resultados (saídas) oriundos da comercialização desses produtos. Como resultado adicional importante, o modelo FDG permitiu a identificação dos produtos do portfólio que são mais sensíveis à ocorrência de incerteza.

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.

Realism in Gameplay: Digital Fiction and Embodiment

In this article we argue that digital simulations promote and explore complex relations between the player and the machines cybernetic system with which it relates through gameplay, that is, the real application of tactics and strategies used by participants as they play the game. We plan to show that the realism of simulation, together with the merger of artificial objects with the real world, can generate interactive empathy between players and their avatars. In this text, we intend to explore augmented reality as a means to visualise interactive communication projects. With ARToolkit, Virtools and 3ds Max applications, we aim to show how to create a portable interactive platform that resorts to the environment and markers for constructing the games scenario. Many of the conventional functions of the human eye are being replaced by techniques where images do not position themselves in the traditional manner that we observe them (Crary, 1998), or in the way we perceive the real world. The digitalization of the real world to a new informational layer over objects, people or environments, needs to be processed and mediated by tools that amplify the natural human senses.

Climate strategies of firms in the automotive and pulp & paper industries in Brazil: insights from an international perspective

This article focuses on the results of the final stage of research into the climate strategies of firms in the automotive and pulp-and-paper industries in Brazil, a country that is becoming increasingly important also in terms of climate change issues. In the first stage, the Climate Strategy Model (CSM) was developed to assess whether firms were adopting the necessary practices to assure the successful implementation of climate strategies. In the second, the CSM was applied to firms in the above mentioned industries that were chosen because of their important role in the domestic economy. In the final stage, interviews with executives of these firms were conducted to identify root causes of climate strategy implementation deficiencies and obtain new insights from an international perspective.

Scenario Planning and Evaluation of Pricing Strategies in the Portuguese Bulk LPG Market

Portugal has the largest LPG (Liquefied Petroleum Gas) share of primary energy demand in the EU (about 5%). Due to the increasing international cost of LPG in the last years and the high price sensitivity of the consumers the preference for substitute energy sources in new and existing consumers has been increasing. To select the kind of energy, some consumer estimate and compare the total costs while others follow agents (equipment sellers) recommendations. It takes time to build agents perception about the most advantageous source of energy, which is seen as an important resource that drives client resource accumulation and retention. Marketing strategies have to take into consideration some market dynamic effects derived from the accumulation and depletion of these resources. A simple system dynamics model was built, combined with Economic Value Added framework, to evaluate some pricing strategies under different scenarios of LPG international cost.

Scenario Planning and Evaluation of Pricing Strategies in the Portuguese Bulk LPG Market

Portugal has the largest LPG (Liquefied Petroleum Gas) share of primary energy demand in the EU (about 5%). Due to the increasing international cost of LPG in the last years and the high price sensitivity of the consumers the preference for substitute energy sources in new and existing consumers has been increasing. To select the kind of energy, some consumer estimate and compare the total costs while others follow agents (equipment sellers) recommendations. It takes time to build agents perception about the most advantageous source of energy, which is seen as an important resource that drives client resource accumulation and retention. Marketing strategies have to take into consideration some market dynamic effects derived from the accumulation and depletion of these resources. A simple system dynamics model was built, combined with Economic Value Added framework, to evaluate some pricing strategies under different scenarios of LPG international cost.

Investigation on the development of bidding strategies for a wind farm owner

In this paper, the development of bidding strategies is investigated for a wind farm owner. The optimization model is characterized by making the analysis of scenarios. The proposed approach allows evaluating alternative production strategies in order to submit bids to the electricity market with the goal of maximizing profits. The problem is formulated as a linear programming problem. An application to a case study is presented

Learning in higher education: strategies to overcome challenges faced by adult students - lessons drawn from two studies in portugal

Int’l J. of Information and Communication Technology Education, 3(2), 1-14, April-June 2007

Comparative study of power converter topologies and control strategies for the harmonic performance of variable-speed wind turbine generator systems

Power converters play a vital role in the integration of wind power into the electrical grid. Variable-speed wind turbine generator systems have a considerable interest of application for grid connection at constant frequency. In this paper, comprehensive simulation studies are carried out with three power converter topologies: matrix, two-level and multilevel. A fractional-order control strategy is studied for the variable-speed operation of wind turbine generator systems. The studies are in order to compare power converter topologies and control strategies. The studies reveal that the multilevel converter and the proposed fractional-order control strategy enable an improvement in the power quality, in comparison with the other power converters using a classical integer-order control strategy. (C) 2010 Elsevier Ltd. All rights reserved.

Agent-based simulation of electronic marketplaces with decision support

This paper presents a Multi-Agent Market simulator designed for analyzing agent market strategies based on a complete understanding of buyer and seller behaviors, preference models and pricing algorithms, considering user risk preferences and game theory for scenario analysis. The system includes agents that are capable of improving their performance with their own experience, by adapting to the market conditions, and capable of considering other agents reactions.