Profit repatriation of a Polish subsidiary from tax planning point of view of an international corporation

The main purpose of this study was to examine and compare the possibilities of profit repatriation from the point of view of tax planning of an international corporation, in such a case that a Finnish parent company has a subsidiary in Poland. The main research problem was divided into two sub research problems: 1) to examine concepts and principles of international taxation and tax planning from the point of view of international corporations and 2) to discuss the main features of Polish Companies-, Accounting- and Tax Act from the point of view a Finnish parent company. The research method of this study is mainly decision making, comparative analysis. In this study have been discussed the possibilities of international profit repatriation for supporting the decision making of the management of a Finnish parent company. In addition different repatriation possibilities have been compared. In this study has been noticed that a Finnish parent company can repatriate profit of its Polish subsidiary either directly as dividends or by using indirect methods such as interests, royalties, management fees and transfer pricing of goods. The total tax burden of dividends is heavier than the tax burden of indirect methods. It was also concluded that during the last years the Polish legislation has been renewed in order to prevent hidden dividend distribution. This has been done by implementing new rules of transfer pricing and thin capitalization.

Internationalization dynamics in the Swiss Corporate Tax Reform III

Over the last years, in a context of international tax competition, international and regional institutions such as the G20, the OECD, and the European Union are redefining what is acceptable in terms of corporate fiscal policy. Certain Swiss preferential tax treatments are considered by the above-mentioned institutions as harmful tax practices. As a consequence, the Swiss government has planned a third corporate tax reform (CTR III). The objective of this reform is to ensure international acceptability of the corporate tax system without prejudicing local public finances and Swiss corporate tax attractiveness. Therefore, we can posit that the CTR III is an internationalized object influenced by both regulation trends and tax competition framework. The main purpose of this paper is to provide elements of answer on how the currently discussed CTR III is influenced by the international environment, by focusing on its content as well as the reactions and positions of local stakeholders. With the help of internationalization literature, two distinct internationalization processes have been identified through the propositions of compliance measures with internationally-defined standards and competitiveness-enhancing measures. With regard to the configuration of local actors, the degree of conflict seems to be rather high. The current content of the reform is supported by the business community and right-wing parties and rejected by the unions and the Socialist Party.

Diagnosis of endocrine disease: High-yield thyroid fine-needle aspiration cytology: an update focused on ancillary techniques improving its accuracy.

Thyroid fine-needle aspiration (FNA) cytology is a fast growing field. One of the most developing areas is represented by molecular tests applied to cytological material. Patients that could benefit the most from these tests are those that have been diagnosed as 'indeterminate' on FNA. They could be better stratified in terms of malignancy risk and thus oriented with more confidence to the appropriate management. Taking in to consideration the need to improve and keep high the yield of thyroid FNA, professionals from various fields (i.e. molecular biologists, endocrinologists, nuclear medicine physicians and radiologists) are refining and fine-tuning their diagnostic instruments. In particular, all these developments aim at increasing the negative predictive value of FNA to improve the selection of patients for diagnostic surgery. These advances involve terminology, the application of next-generation sequencing to thyroid FNA, the use of immunocyto- and histo-chemistry, the development of new sampling techniques and the increasing use of nuclear medicine as well as molecular imaging in the management of patients with a thyroid nodule. Herein, we review the recent advances in thyroid FNA cytology that could be of interest to the 'thyroid-care' community, with particular focus on the indeterminate diagnostic category.

Disclosure of tax information -from tax reporting system to the financial statements, Case: Fortum Oyj

The main target of the study was to examine how Fortum’s tax reporting system could be developed in a way that it collects required information which is also easily transferable to the financial statements. This included examining disclosure requirements for income taxes under IFRS and US GAAP. By benchmarking some Finnish, European and US companies the purpose was to get perspective in what extend they present their tax information in their financial statements. Also material weakness, its existence, was under examination. The research method was qualitative, descriptive and normative. The research material included articles and literature of the tax reporting and standards relating to it. The interviews made had a notable significance. The study pointed out that Fortum’s tax reporting is in good shape and it does not require big changes. The biggest renewal of the tax reporting system is that there is only one model for all Fortum’s companies. It is also more automated, quicker, and more efficient and it reminds more the notes in its shape. In addition it has more internal controls to improve quality and efficiency of the reporting process.

Incumbent audit firm-provided tax services and the clients with low financial reporting quality

This study investigates whether incumbent audit firm-provided tax services enhance or impair the likelihood of acknowledging client companies’ low financial reporting quality. In particular, we examine the association between tax-related fees and the likelihood of timely restatements, and internal control weakness disclosures among a sample of US companies that all have misstatements in financial information. The empirical findings indicate that companies paying higher tax-related fees are less likely to disclose SOX 404 internal control weakness disclosures, implying that underlying control problems are unacknowledged when incumbent audit firm provided tax-related fees are higher. However, the findings suggest that just providing both audit and tax-related services does not have an impact on audit quality per se, but rather it is the magnitude of the tax-related fees in particular that counts. We also find some evidence suggesting that companies paying higher tax-related fees have higher likelihood of restatement lags, whereas companies paying smaller tax-related fees to their audit firm restate financial statements in a timelier manner. Overall, the findings suggest that audit scrutiny of client companies with low quality financial reporting is weaker when the magnitude of tax-related fees is higher.

Ancillary services market and potential profit for generators in Russia

Reformation of electricity markets has initiated creation of ancillary services markets all over the world. The Russian electricity market reform is in transition period, that is why the problem of ancillary services market has just arisen. Since the model of market rules was created, ancillary services market became a topical question for generating companies. This master’s thesis is focused on the describing the possible ancillary services around the world and in Russia specifically. Moreover, the physical interpretation of ancillary services is defined. In addition, possibility of generation company to participate in the ancillary services market was considered. Calculations were made for primary frequency regulation service, where necessary level of price bids and payback period were evaluated.

Effects of a Financial Transaction Tax - Do Transaction Costs Lower Volatility?: A Literature Review

In this literature review the theorethical framework of Financial transaction taxes and their assumed effect on market volatility is assessed. The empirical evidence from various studies is compared against the theory and a simple empirical review of the Finnish stock market is conducted. The findings implicate that financial transaction taxes can not reduce volatility and their actual effect on markets is dependend by many other factors as well. Some evidence even suggests that transactions taxes may actually raise volatility.

Pursuing substantive participation in Russia : a perspective from international legal obligations and comparative law

Så som är fallet för många andra stater, kan vissa delar av den ryska förvaltningen ännu utvecklas för att till fullo uppfylla internationella standarder. Internationella fördragsorgan som övervakar förverkligandet i Ryssland av fördrag om mänskliga rättigheter framför ibland kritiska anmärkningar om den demokratiska utvecklingen i Ryssland. Enskilda fall där politiska rättigheter möjligen kränkts av ryska myndigheter har utan tvivel placerat Ryssland i fokus för internationell media. Exempel på sådana fall är mordet på journalisten Anna Politkovskaya, Sergei Magnitskys död i fängelse och fängslandet av medlemmarna i "Pussy Riot”. Likväl anser författaren av denna studie att politiska rättigheter i Ryssland förverkligas inom rimliga gränser och i enlighet med internationell människorättslagstiftning. Denna studie fokuserar på förverkligandet av den individuella rättigheten att delta i det politiska beslutsfattandet i Ryssland genom andra mekanismer för deltagande än val och folkomröstningar. Studien utgörs av en sammanställning av forskningsartiklar som har publicerats i olika internationella tidskrifter. Sammanställningen föregås av ett fristående inledande kapitel. Författaren koncentrerar sig på frågan om Rysslands invånare ges effektiva möjligheter att delta i handhavandet av allmänna angelägenheter och om det finns användbara rättsmedel till hands för skydd av de politiska rättigheterna. Författaren tar sig an en juridisk analys av rysk lagstiftning gällande olika sätt för direkt deltagande i beslutsfattande samt analyserar rättsfall angående direkt deltagande från domstolarna i Moskva, Perm Krai och Sverdlovsk Oblast. Denna studie använder sig även av en rättshistorisk infallsvinkel för att visa på den positiva dynamiken hos den historiska utvecklingen beträffande d e väsentligaste plattformarna för offentligt deltagande. Det bevisas att rysk lagstiftning som garanterar rätten att delta i beslutsfattande är väl utvecklad i enlighet med internationella människorättsfördrag, och att åtminstone domstolarna i de utvalda ryska områdena fattar beslut som stöder deltaganderättigheter som eventuellt kränkts av myndigheter inom den verkställande makten. Författaren kommer till den slutsatsen att de i denna studie inkluderade enskilda dokumenterade händelserna gällande administrativ felbehandling inte nödvändigtvis tillåter den direkta slutsatsen att det begås systematiska och grova kränkningar av medborgares deltaganderättigheter i Ryssland.

In vivo fluctuation of Tax, Foxp3, CTLA-4, and GITR mRNA expression in CD4+CD25+ T cells of patients with human T-lymphotropic virus type 1-associated myelopathy

HTLV-1 Tax expression exerts an inhibitory effect on the Foxp3 transcription factor in CD4+CD25+ T-regulatory cells (Treg). For a better understanding of the role of Tax mRNA in the gene expression of cellular markers we measured Tax, Foxp3, CTLA-4, GITR, TGF-β, and IL-10 mRNA in Treg cells of 50 patients with human T-lymphotropic virus type 1 (HTLV-1)-associated myelopathy/tropical spastic paraparesis (HAM/TSP; 27 women and 23 men; mean age: 56.7 years). The control group consisted of 23 non-infected subjects (12 women and 11 men) with a mean age of 51.3 years. Real-time PCR was used to measure mRNA of Tax proteins and several cellular markers of Treg function. Determinations revealed a high level of Tax mRNA in HAM/TSP (124.35 copies/100 CD4+CD25+ T cells). Foxp3, GITR, and CTLA-4 mRNA levels were lower in HAM/TSP patients (mean ± SD, 22.07 ± 0.78, 9.63 ± 0.36, and 4.54 ± 0.39, respectively) than in non-infected controls (47.15 ± 12.94, 22.14 ± 1.91, and 21.07 ± 2.31). Both groups had similar levels of TGF-β and IL-10. An inverse relationship was found between Tax levels and Foxp3, CTLA-4, and GITR levels. Conversely, there was a direct correlation between levels of Foxp3, GITR, and CTLA-4. Disease severity and evolution time did not correlate with Tax or Foxp3 levels. The present results suggest that Tax and Foxp3 mRNA vary with the same degree of disease severity in HAM/TSP patients. Tax fluctuations may affect CTLA-4 and GITR expression via the Foxp3 pathway, causing virus-induced dysfunction of CD4+CD25+ T cells in HAM/TSP patients.

An evaluation of the 2003 tax reform effort in Brazil

This paper provides an assessment of the tax-reform effort launched by the newly elected Lula government in 2003. It analyzes how the envisaged reform had to be changed and scaled down, in the wake of strong political resistance, after a failed attempt to develop a consensual proposal, fully supported by state-governors. The main effective changes are then evaluated. Challenges ahead are discussed at the end.

A graphic explanation on how a tax on exports neutralizes the Dutch disease without costs to exporters

The adequate way of neutralizing the Dutch disease is the imposition of a variable tax on the export of the commodity that originates the disease. If such tax is equivalent to the "size" of the Dutch disease, it will shifts to the right its supply curve of the commodity in relation to the exchange rate, giving the existing domestic supply and the international demand, the exchange rate will depreciate at the value of the tax, and the equilibrium exchange rate will move from the "current" to the "industrial" equilibrium.