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.

Knowledge and policy action in urban development: if we know so much, why is the urban condition not improving?

In spite of the wealth generation potential of the world's large metropolitan cities, poor living conditions for much of the world's urban population persist. Although the city has been widely studied, urban policy often remains ineffective. The paper adopts a policy process approach to analyze the relationship between knowledge and governmental action. Impediments to improving urban policy are found in the inadequate capacity of government to act and in the politics of democratic decision-making. The paper recommends that a pragmatic view of knowledge generation be adopted.

O Momento Imperial

Após os atentados terroristas de 11 de Setembro de 2001, a política externa norte-americana sofreu uma revisão significativa na definição de prioridades, gerando-se, ao mesmo tempo, uma forte controvérsia quanto ao papel dos EUA no mundo e à sua inserção no panorama geo-estratégico internacional. No cerne dessa controvérsia três grandes temas têm estado presentes: a questão da hegemonia; do unilateralismo vs . multilateralismo; e o da natureza imperial – ou não – da política externa norte-americana.

The institutional configuration of sport policy in Brazil: organization, evolution and dilemmas

Brazil has become the center of the spotlight of the whole world recently, amongst many other reasons, one of them was because it was chosen to host a series of mega sporting events - Pan American Games in 2007, Confederations Football Cup in 2013, Fifa Football World Cup 2014 Games and 2016 Olympic and Paralympic Games in 2016. However, little is known about the country's administrative governmental structure focused on sport policy. The available studies focus their analysis on the sport policies content, but not on the arrangement of its structural decision-making. The main aim of this article is indeed to describe, based on official documentation, the evolution and the current arrangements of the government responsible for the administrative structure for the planning and implementation of sports policies in Brazil. Thus, we tried to list the main problems arising from the organization of the Brazilian sports' management. These problems are: (1) inappropriate institutional structure in terms of human resources and obstacles to participation by other social actors beyond the officials (parliament and members of the Ministry of Sports) in the sports policy; (2) disarticulation between public institutions generating redundancies and conflicts of jurisdiction due to the poor division of labor between bureaucracy agencies; and (3) inadequate planning proved by the lack of organization of some institutions, and by the lack of assessment and continuity of public policies over time. Therefore, we must emphasize those problems from above, and due to these administrative arrangements, Brazilian sports' policy has big challenges in the sport development in this country, which includes the creation of a national "system" for sports and a priority investment in sport education.

UM ORIENTALISTA ALEMÃO NO BRASIL IMPERIAL. CHRISTIAN FRIEDRICH SEYBOLD, O TUTOR DE D. PEDRO II

Resumo Este artigo visa discutir a relação entre o segundo imperador do Brasil, Pedro d'Alcântara, e seu último mestre de línguas semíticas e orientais, o alemão Christian Friedrich Seybold (1859-1921). Uma leitura preliminar dos diários do monarca nos chamou a atenção para a enorme quantidade de menções e referências àquele orientalista alemão, o que revela, de certa forma, a importância que o professor ocupava na vida de d. Pedro II. No entanto, ao passo que Seybold está presente em numerosas páginas dos diários, nos causa certa estranheza que tal fato tenha merecido pouca ou nenhuma consideração por parte dos biógrafos do imperador, já que o contato frequente entre eles durante cinco anos se resume a algumas poucas linhas e alusões esparsas. Partindo de uma releitura crítica do material disponível na historiografia brasileira sobre Seybold, pretendemos aportar novos dados para o estudo bio-bibliográfico daquele que foi uma figura atuante na vida intelectual de d. Pedro II, presente até os últimos dias de vida do soberano.

The engine or the caboose: health policy in developing countries

A discussion of health policy in developing countries is presented. It argues that developing countries must adopt a progressive approach to health policy which rejects the two-tiered system of public and private health care. However, it also points out that ideology is not sufficient to maintain support. A progressive health system must utilize administrative and social and behavioral sciences to achieve effectiveness and efficiency in health care delivery. It cannot ignore these goals any more than a private health care system can.

The social adjustment of patients with schizophrenia: implications to the mental health policy in Brazil

A sample (n=124) of schizophrenic patients from a defined catchment area of the city os S.Paulo, Brazil, who had been consecutively admitted to hospital, was assessed for psychopathological status and social adjustment levels. Sociodemographic, socio-economic and occupational characteristics were recorded: almost 30% of the subjects had no occupation and received no social benefit, more than two-thirds had a monthly per capita income of US$ 100.00 or less. Sixty-five percent presented with Schneiderian firstrank symptoms. Nearly half the sample showed poor or very poor social adjustment in the month prior to admission. The most affected areas of social functioning were participation in the household activities, work and social withdrawal. The current mental health policy of promoting extra-mural care as an alternative to the previous hospital-based model will then mean the investment in a network of new community-based services, that give effective treatment and support to patients and their families. The need of further research into the current picture of mental disorders in the country is stressed.

The 27th British liquid crystal society annual meeting 2013, Cambridge

Attending the British Liquid Crystal Society’s (BLCS) Annual Meeting was a formative experience in my days as a PhD student, starting way back in the 1990s. At that time, this involved travelling to (to me) exotic parts of the United Kingdom, such as Reading, Oxford or Manchester, away from Southampton where I was based. Some postdoctoral years in a different country followed, and three BLCS Meetings were missed, until in 1997 and 1998, I was able to attend again, in Southampton and Leeds, respectively. Not much had changed from my student days, the size and the format were still about the same, many of the leading characters were still around, and the closing talk would still be given by John Lydon. Well, at some point, I got myself a proper academic job on the Continent and stopped attending BLCS Annual Meetings altogether. The fond memories of my youth started to fade. Were the Meetings still on? It seemed so, as old friends and acquaintances would occasionally recount attending them, and even winning prizes at them. But, it all seemed rather remote now. Until, that is, it came to pass that the 27th BLCS Meeting would be held in Selwyn College, Cambridge, just down (or up, depending on how you look at it) the road from the Isaac Newton Institute, where I was spending part of my sabbatical leave. The opportunity to resume attendance could not be missed. A brief e-mail exchange with the organisers, and a cheque to cover the fee, duly secured this. And thus, it was with trepidation that I approached my first BLCS Annual Meeting in more than a decade.

Cultural organizations and communication in portuguese decentralization policy

This paper intends to show the Portuguese municipalities’ commitment, since the first decade of this century, in cultural facilities of municipal management and how it provided 12 of the 18 district capitals of mainland Portugal with cultural equipment, but after all we want to know if this effort resulted in a regular, diverse, and innovative schedule. Investing in urban regeneration, local governments have tried to convert cities’ demographic changes (strengthening of the most educated and professionally qualified groups) in effective cultural demands that consolidate the three axes of development competitiveness-innovation-creativity. What the empirical study to the programming and communication proposals of those equipment shows is that it is not enough to provide cities with facilities; to escape to a utilitarian conception of culture, there is a whole work to be done so that such equipment be experienced and felt as new public sphere. Equipment in which proposals go through a fluid bind, constructed through space and discourse with local community, devoted a diversified and innovative bet full filling development axis. This paper presents in a systematic way what contributes to this binding on the analyzed equipment.

Cultural organizations and communication in portuguese decentralization policy

This presentation intends to show to what extent the Portuguese municipalities’ commitment, from the first decade of this century, in cultural facilities of municipal management and which has provided 12 of the 18 district capitals of mainland Portugal with equipment, resulted in a regular, diverse and innovative schedule. Investing in urban regeneration, local government has tried to convert cities’ demographic changes (strengthening of the most educated and professionally qualified groups) in effective cultural demands that consolidate the three axes of development competitiveness-innovation-creativity. What the empirical study to the programming and communication proposals of those equipment shows is that it is not enough to provide cities with facilities; to escape to a utilitarian conception of culture, there is a whole work to be done so that such equipment be experienced and felt as new public sphere. Equipment in which proposals go through a fluid bind, constructed through space and discourse with local community, devotes a diversified and innovative bet full filling development axis. This paper presents in a systematic way what contributes to this binding on the analyzed equipment.

East of Suez and the imaginary tangles of space and self

Drawing on postcolonial studies and the theorization on imperial gothic, this paper centres on three texts: The Hosts of the Lord (1900) by Flora Annie Steel; East of Suez (1901) by Alice Perrin, and The Way of an Eagle (1912)by Ethel Dell. These three texts highlight in different ways the discursive mediation of the Other and its destabilizing effects on the identity of the European-minded colonizer, thus foregrounding the multifarious nature of the British imaginative engagement with India. In this context, it is particularly relevant to examine the political and ideological implications of representing anywhere East of Suez as a locus of primitivism and chaos vis-à-vis the colonizer’s ambivalent reactions. Thus we seek to demonstrate the power of two distinct practices or modes of representation – namely, the power of a metaphorical discourse versus metonymic discourse- within the proces of constructing the East for a vast Western readership.

Legal and political regulation of higher education in Portugal: an evolutionary perspective on the current policy issues and the problem of order

The higher education system in Europe is currently under stress and the debates over its reform and future are gaining momentum. Now that, for most countries, we are in a time for change, in the overall society and the whole education system, the legal and political dimensions have gained prominence, which has not been followed by a more integrative approach of the problem of order, its reform and the issue of regulation, beyond the typical static and classical cost-benefit analyses. The two classical approaches for studying (and for designing the policy measures of) the problem of the reform of the higher education system - the cost-benefit analysis and the legal scholarship description - have to be integrated. This is the argument of our paper that the very integration of economic and legal approaches, what Warren Samuels called the legal-economic nexus, is meaningful and necessary, especially if we want to address the problem of order (as formulated by Joseph Spengler) and the overall regulation of the system. On the one hand, and without neglecting the interest and insights gained from the cost-benefit analysis, or other approaches of value for money assessment, we will focus our study on the legal, social and political aspects of the regulation of the higher education system and its reform in Portugal. On the other hand, the economic and financial problems have to be taken into account, but in a more inclusive way with regard to the indirect and other socio-economic costs not contemplated in traditional or standard assessments of policies for the tertiary education sector. In the first section of the paper, we will discuss the theoretical and conceptual underpinning of our analysis, focusing on the evolutionary approach, the role of critical institutions, the legal-economic nexus and the problem of order. All these elements are related to the institutional tradition, from Veblen and Commons to Spengler and Samuels. The second section states the problem of regulation in the higher education system and the issue of policy formulation for tackling the problem. The current situation is clearly one of crisis with the expansion of the cohorts of young students coming to an end and the recurrent scandals in private institutions. In the last decade, after a protracted period of extension or expansion of the system, i. e., the continuous growth of students, universities and other institutions are competing harder to gain students and have seen their financial situation at risk. It seems that we are entering a period of radical uncertainty, higher competition and a new configuration that is slowly building up is the growth in intensity, which means upgrading the quality of the higher learning and getting more involvement in vocational training and life-long learning. With this change, and along with other deep ones in the Portuguese society and economy, the current regulation has shown signs of maladjustment. The third section consists of our conclusions on the current issue of regulation and policy challenge. First, we underline the importance of an evolutionary approach to a process of change that is essentially dynamic. A special attention will be given to the issues related to an evolutionary construe of policy analysis and formulation. Second, the integration of law and economics, through the notion of legal economic nexus, allows us to better define the issues of regulation and the concrete problems that the universities are facing. One aspect is the instability of the political measures regarding the public administration and on which the higher education system depends financially, legally and institutionally, to say the least. A corollary is the lack of clear strategy in the policy reforms. Third, our research criticizes several studies, such as the one made by the OECD in late 2006 for the Ministry of Science, Technology and Higher Education, for being too static and neglecting fundamental aspects of regulation such as the logic of actors, groups and organizations who are major players in the system. Finally, simply changing the legal rules will not necessary per se change the behaviors that the authorities want to change. By this, we mean that it is not only remiss of the policy maker to ignore some of the critical issues of regulation, namely the continuous non-respect by academic management and administrative bodies of universities of the legal rules that were once promulgated. Changing the rules does not change the problem, especially without the necessary debates form the different relevant quarters that make up the higher education system. The issues of social interaction remain as intact. Our treatment of the matter will be organized in the following way. In the first section, the theoretical principles are developed in order to be able to study more adequately the higher education transformation with a modest evolutionary theory and a legal and economic nexus of the interactions of the system and the policy challenges. After describing, in the second section, the recent evolution and current working of the higher education in Portugal, we will analyze the legal framework and the current regulatory practices and problems in light of the theoretical framework adopted. We will end with some conclusions on the current problems of regulation and the policy measures that are discusses in recent years.

Main features of the labour policy in Portugal

In this working paper is presented information on the Portuguese labour market developed with the support of the European project WORKS-“Work organisation and restructuring in the knowledge society”. Is still a on the process article and thus commentaries are welcome. The structure is based on the following topics: a) The employment policy (Time regimes - time use, flexibility, part-time work, work-life balance -, and the work contracts regimes – wages, contract types, diversity); b) Education and training (skilling outcomes, rules on retraining and further training, employability schemes, transferability of skills); c) Equal opportunities (relevance of equal opportunity regulation for restructuring outcomes, the role of gender and age regulation); d) Restructuring effects (policy on transfer of personnel, policy on redundancies, and participation or voice in restructuring).