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.

Taking the "cross" out of cross-cultural transfer of management practice

Multi-national enterprises often attempt to replicate successful management practices in "foreign" environments. However, such practices may be ethnocentric because they fit the assumptions, behaviors, expectations, and values of the home cultural environment. Unless the underlying assumptions are shared, transfer to a differing environment may fail. Even if the focus is shifted from cultural differences to implementation, implementation approaches may also be criticized as ethnocentric for the same reasons. In this article, a non-ethnocentric model is expanded and used to test the portability of one management practice, performance appraisal, from the USA to Brazil. This "Test of Portability" may help managers understand which management practices are portable, and, perhaps even more valuable, provide a rationale for adaptation or rejection.

The Metaphysics of Information The Power and the Glory of Machinehood

Não há disciplina em qualquer ramo da ciência, seja esta natural, social, humana, descritiva, experimental ou teórica, qualitativa ou quantitativa, que não tenha sido afectada a vários níveis da instrumentalidade, conceptualização, construção de modelos, escolha de metáforas heurísticas ou ontológicas, e sentidO da investigação, em alguns casos muito profunda e decisivamente, pela influência crescente da constelação informacional computacional. A investigação baseada em simulações por computador é uma “terceira espécie de ciência”, que se soma aos tipos teórico e físico-experimental de trabalho científico. A ciber-ciência é um lugar natural para simular ciência, ou meta-ciberciência, mas todo o conhecimento científico cai no domínio da meta-ciberciência ou da filosofia da ciência computacional. A meta-ciência simula a ciência(o estudo computacional da produção do conhecimento científico); a ciber-ciência é por definição simulatória; a ciber-ciência simula a Natureza; a Natureza, segundo alguns físicos, é ela mesma uma simulação. Receber a categoria da informação nas ciências da vida e nas ciências humanas e sociais, da maneira específica como tem vindo a ocorrer, traz um considerável lastro metafísico: os humanos como máquinas, ultrapassáveis por máquinas inteligentes ou “espirituais”. A informação emerge como a alavanca de Arquimedes para as nossas intervenções n o domínio da vida e do espírito, de máquinas informacionais naturais, com evidentes implicações para a ciência política.

In the Shadow of Power

Pedro Feytor Pinto headed the Department of Information Services (SEIT) in the government of Marcello Caetano who replaced Antonio Oliveira Salazar in 1968 as the head of the Portuguese government. Feytor Pinto has just released a book entitled Na Sombra do Poder (In the Shadow of Power)[Lisboa, D. Quixote, 2011, pp. 402]. Not wishing to classify it as history or memoirs, yet hoping that historians may find it useful, the author chooses to narrate events as he experienced them from his vantage point in the shadow of Power, during the years ending with the Carnation Revolt of 25 April 1974, which put an end to half a century of dictatorship, known as Estado Novo.

Metaphors of opulence and power in the life of Thomas Wolsey, the King’s Cardinal

This essay approaches the display of power and rulership both through the art of writing and the art of painting by focusing on George Cavendish's biographical account of Thomas Wolsey.

A hybrid PSO-ANFIS approach for short-term wind power prediction in Portugal

The increased integration of wind power into the electric grid, as nowadays occurs in Portugal, poses new challenges due to its intermittency and volatility. Wind power prediction plays a key role in tackling these challenges. The contribution of this paper is to propose a new hybrid approach, combining particle swarm optimization and adaptive-network-based fuzzy inference system, for short-term wind power prediction in Portugal. Significant improvements regarding forecasting accuracy are attainable using the proposed approach, in comparison with the results obtained with five other approaches.

Electromagnetic transients analysis of lightning overvoltages on wind power plants

As wind power generation undergoes rapid growth, lightning and overvoltage incidents involving wind power plants have come to be regarded as a serious problem. Firstly, lightning location systems are discussed, as well as important parameters regarding lightning protection. Also, this paper presents a case study, based on a wind turbine with an interconnecting transformer, for the study of adequate lightning and overvoltage protection measures. The electromagnetic transients circuit under study is described, and computational results are presented.

Direct Power Control of Matrix Converter Based Unified Power Flow Controllers

This paper presents the Direct Power Control of Three-Phase Matrix Converters (DPC-MC) operating as Unified Power Flow Controllers (UPFC). Since matrix converters allow direct AC/AC power conversion without intermediate energy storage link, the resulting UPFC has reduced volume and cost, together with higher reliability. Theoretical principles of DPC-MC method are established based on an UPFC model, together with a new direct power control approach based on sliding mode control techniques. As a result, active and reactive power can be directly controlled by selection of an appropriate switching state of matrix converter. This new direct power control approach associated to matrix converters technology guarantees decoupled active and reactive power control, zero error tracking, fast response times and timely control actions. Simulation results show good performance of the proposed system.

Risk Aversion in a Mixed-Integer Nonlinear Approach to Support Decision-Making for a Hydro Power Producer

In this paper, a mixed-integer nonlinear approach is proposed to support decision-making for a hydro power producer, considering a head-dependent hydro chain. The aim is to maximize the profit of the hydro power producer from selling energy into the electric market. As a new contribution to earlier studies, a risk aversion criterion is taken into account, as well as head-dependency. The volatility of the expected profit is limited through the conditional value-at-risk (CVaR). The proposed approach has been applied successfully to solve a case study based on one of the main Portuguese cascaded hydro systems.

Stability Condition Based Sliding Mode Modulators for Multilevel Power Converters

Sliding mode controllers for power converters usually employ hysteresis comparators to directly generate the power semiconductors switching states. This paper presents a new sliding mode modulator based on the direct implementation of the sliding mode stability condition, which for multilevel power converters shows advantages, as branch equalized switching frequencies and less distortion on the ac currents when operating near the rated converter power. The new sliding mode multilevel modulator is used to control a three-phase multilevel converter, operated as a reactive power compensator (STATCOM), implementing the stability condition in a digital signal processing system. The performance of this new sliding mode modulator is compared with a multilevel modulator based on hysteresis comparators. Simulation and experimental results are presented in order to highlight the system operation and control robustness.