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.

A high-throughput screening method for general cytotoxicity part I Chemical toxicity

Foi desenvolvido um método destinado a fazer a triagem rápida e o escalonamento da toxicidade geral exercida por xenobióticos tendo como modelo o Saccharomyces cerevisiae. Para padronizar as condições de experimentação foi estabelecida a relação entre a absorvência a 525 nm e o número de células em suspensão por mililitro de meio de cultura e calculadas uma curva padrão e respectiva equação definidora (Y=6,8219E-08X + 0,0327) Culturas de Saccharomyces cerevisiae em meio completo para leveduras (YPD - 1% de glucose 2%, de peptona 0,5% e extracto de levedura 1%) foram expostas a diferentes concentrações de nicotina e a inibição do crescimento avaliada.

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.

An appraisal of the health planning method proposed by the Pan-American Health Organization for Latin America

A brief description of the main features of the health planning technique developed by the "Centro de Estudios del Desarrollo" (CENDES) in Venezuela, and proposed by the Pan-American Health Organization for use in Latin America, is presented. This presentation is followed by an appraisal of the planning method which includes comments both upon its positive aspects and upon its negative points. Comments are also made referring to other recent publications of the WHO/PAHO on health planning. In conclusion, the CENDES technique is considered a health planning method of great potential for use especially in underdeveloped areas, the success of its application depending upon the hability of the health planners to introduce the necessary modifications to adapt to the local circunstamces.

The use of wide-mesh gauze impregnated with lambda-cyhalothrin covering wall openings in huts as a vector control method in Suriname

An alternative vector control method, using lambda-cyhalothrin impregnated wide-mesh gauze covering openings in the walls of the houses was developed in an area in the Eastern part of the interior of Suriname. Experimental hut observations showed that Anopheles darlingi greatly reduced their biting activity (99-100%) during the first 5 months after impregnation. A model assay showed high mortality both of mosquitoes repelled by the gauze as well as of those that succeeded in getting through it. A field application test in 270 huts showed good acceptance by the population and good durability of the applied gauze. After introducing the method in the entire working area, replacing DDT residual housespraying, the malaria prevalence, of 25-37% before application dropped and stabilized at between 5 and 10% within one year. The operational costs were less than those of the previously used DDT housespraying program, due to a 50% reduction in the cost of materials used. The method using widemesh gauze impregnated with lambdacyhalothrin strongly affects the behavior of An. darlingi. It is important to examine the effect of the method on malaria transmission further, since data indirectly obtained suggest substantial positive results.

Nonlinear optimization method for short-term hydro scheduling considering head-dependency

This paper is on the problem of short-term hydro scheduling, particularly concerning head-dependent reservoirs under competitive environment. We propose a new nonlinear optimization method to consider hydroelectric power generation as a function of water discharge and also of the head. Head-dependency is considered on short-term hydro scheduling in order to obtain more realistic and feasible results. The proposed method has been applied successfully to solve a case study based on one of the main Portuguese cascaded hydro systems, providing a higher profit at a negligible additional computation time in comparison with a linear optimization method that ignores head-dependency.

A method to analyse the alignment of core values in collaborative networked organisations

Since collaborative networked organisations are usually formed by independent and heterogeneous entities, it is natural that each member holds his own set of values, and that conflicts among partners might emerge because of some misalignment of values. In contrast, it is often stated in literature that the alignment between the value systems of members involved in collaborative processes is a prerequisite for successful co-working. As a result, the issue of core value alignment in collaborative networks started to attract attention. However, methods to analyse such alignment are lacking mainly because the concept of 'alignment' in this context is still ill defined and shows a multifaceted nature. As a contribution to the area, this article introduces an approach based on causal models and graph theory for the analysis of core value alignment in collaborative networks. The potential application of the approach is then discussed in the virtual organisations' breeding environment context.

Constructing good deals in discrete time arbitrage-free dynamic pricing models

Recent literature has proved that many classical pricing models (Black and Scholes, Heston, etc.) and risk measures (V aR, CV aR, etc.) may lead to “pathological meaningless situations”, since traders can build sequences of portfolios whose risk leveltends to −infinity and whose expected return tends to +infinity, i.e., (risk = −infinity, return = +infinity). Such a sequence of strategies may be called “good deal”. This paper focuses on the risk measures V aR and CV aR and analyzes this caveat in a discrete time complete pricing model. Under quite general conditions the explicit expression of a good deal is given, and its sensitivity with respect to some possible measurement errors is provided too. We point out that a critical property is the absence of short sales. In such a case we first construct a “shadow riskless asset” (SRA) without short sales and then the good deal is given by borrowing more and more money so as to invest in the SRA. It is also shown that the SRA is interested by itself, even if there are short selling restrictions.

Model risk in the pricing of exotic options

The growth experimented in recent years in both the variety and volume of structured products implies that banks and other financial institutions have become increasingly exposed to model risk. In this article we focus on the model risk associated with the local volatility (LV) model and with the Variance Gamma (VG) model. The results show that the LV model performs better than the VG model in terms of its ability to match the market prices of European options. Nevertheless, both models are subject to significant pricing errors when compared with the stochastic volatility framework.

Pricing intraday dynamics across EUAS and CERS markets

The relative contribution of European Union Allowances (EUAs) and Certified Emission Reductions (CERs) to the price discovery of their common true value has been empirically studied using daily data with inconclusive results. In this paper, we study the short-run and long-run price dynamics between EUAs and CERs future contracts using intraday data. We report a bidirectional feedback causality relationship both in the short-run and in the long-run, with the EUA's market being the leader.

A real time pricing approach to deal with excessive wind power situations

The introduction of wind power generation in several countries around the world, including in European countries, where energy policy directives have encouraged the use of renewables, led to several changes in market and power systems operation. The intensive integration of these sources has led to situations in which the demand is lower than the available renewable resources. In these situations a part of the available generation is wasted if not used for storage or to supply additional demand. This paper proposes a real time demand response methodology based on changing the electricity price for the consumers expecting an increase in the demand in the periods in which that demand is lower than the available renewable generation. The consumers response to the changes in electricity price is characterized by their price elasticity of demand considered distinct for each consumer type. The proposed methodology is applied to the Portuguese power system, in the context of the Iberian electricity market (MIBEL). The renewable-based producers are considered as special producers, with special tariffs, and so it is important to use the energy available as it will be paid anyway. In this context, consumers are entities actively participating in the operation of the market.

Peer Instruction method in introductory math courses

Learning is not a spectator’s sport. Students do not learn much by just sitting in class listening their teachers, memorizing pre-packaged assignments and spitting out answers. The teaching-learning process has been a constant target of studies, particularly in Higher Education, in consequence of the annual increase of new students. The concern with maintaining a desired quality level in the training of these students, conjugated with the will to widen the access to all of those who finish Secondary School Education, has triggered a greater intervention from the education specialists, in partnership with the teachers of all Higher Education areas, in the analysis of this problem. Considering the particular case of Engineering, it has been witnessed a rising concern with the active learning strategies and forms of assessment. Research has demonstrated that students learn more if they are actively engaged with the material they are studying. In this presentation we describe, present and discuss the techniques and the results of Peer Instruction method in an introductory Calculus courses of an Engineering Bach

Matrix Converter-Based Unified Power-Flow Controllers: Advanced Direct Power Control Method

This paper presents a direct power control (DPC) for three-phase matrix converters operating as unified power flow controllers (UPFCs). Matrix converters (MCs) allow the direct ac/ac power conversion without dc energy storage links; therefore, the MC-based UPFC (MC-UPFC) has reduced volume and cost, reduced capacitor power losses, together with higher reliability. Theoretical principles of direct power control (DPC) based on sliding mode control techniques are established for an MC-UPFC dynamic model including the input filter. As a result, line active and reactive power, together with ac supply reactive power, can be directly controlled by selecting an appropriate matrix converter switching state guaranteeing good steady-state and dynamic responses. Experimental results of DPC controllers for MC-UPFC show decoupled active and reactive power control, zero steady-state tracking error, and fast response times. Compared to an MC-UPFC using active and reactive power linear controllers based on a modified Venturini high-frequency PWM modulator, the experimental results of the advanced DPC-MC guarantee faster responses without overshoot and no steady-state error, presenting no cross-coupling in dynamic and steady-state responses.