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.

E-Cigarettes: A Review of New Trends in Cannabis Use.

The emergence of electronic cigarettes (e-cigs) has given cannabis smokers a new method of inhaling cannabinoids. E-cigs differ from traditional marijuana cigarettes in several respects. First, it is assumed that vaporizing cannabinoids at lower temperatures is safer because it produces smaller amounts of toxic substances than the hot combustion of a marijuana cigarette. Recreational cannabis users can discretely "vape" deodorized cannabis extracts with minimal annoyance to the people around them and less chance of detection. There are nevertheless several drawbacks worth mentioning: although manufacturing commercial (or homemade) cannabinoid-enriched electronic liquids (e-liquids) requires lengthy, complex processing, some are readily on the Internet despite their lack of quality control, expiry date, and conditions of preservation and, above all, any toxicological and clinical assessment. Besides these safety problems, the regulatory situation surrounding e-liquids is often unclear. More simply ground cannabis flowering heads or concentrated, oily THC extracts (such as butane honey oil or BHO) can be vaped in specially designed, pen-sized marijuana vaporizers. Analysis of a commercial e-liquid rich in cannabidiol showed that it contained a smaller dose of active ingredient than advertised; testing our laboratory-made, purified BHO, however, confirmed that it could be vaped in an e-cig to deliver a psychoactive dose of THC. The health consequences specific to vaping these cannabis preparations remain largely unknown and speculative due to the absence of comprehensive, robust scientific studies. The most significant health concerns involve the vaping of cannabinoids by children and teenagers. E-cigs could provide an alternative gateway to cannabis use for young people. Furthermore, vaping cannabinoids could lead to environmental and passive contamination.

Tumour biology, metastatic sites and taxanes sensitivity as determinants of eribulin mesylate efficacy in breast cancer: results from the ERIBEX retrospective, international, multicenter study.

BACKGROUND: Our retrospective, international study aimed at evaluating the activity and safety of eribulin mesylate (EM) in pretreated metastatic breast cancer (MBC) in a routine clinical setting. METHODS: Patients treated with EM for a locally advanced or MBC between March 2011 and January 2014 were included in the study. Clinical and biological assessment of toxicity was performed at each visit. Tumour response was assessed every 3 cycles of treatment. A database was created to collect clinical, pathological and treatment data. RESULTS: Two hundred and fifty-eight patients were included in the study. Median age was 59 years old. Tumours were Hormone Receptor (HR)-positive (73.3 %) HER2-positive (10.2 %), and triple negative (TN, 22.5 %). 86.4 % of the patients presented with visceral metastases, mainly in the liver (67.4 %). Median previous metastatic chemotherapies number was 4 [1-9]. Previous treatments included anthracyclines and/or taxanes (100 %) and capecitabine (90.7 %). Median number of EM cycles was 5 [1-19]. The relative dose intensity was 0.917. At the time of analysis (median follow-up of 13.9 months), 42.3 % of the patients were still alive. The objective response rate was 25.2 % (95 %CI: 20-31) with a 36.1 % clinical benefit rate (CBR). Median time to progression (TTP) and overall survival were 3.97 (95 %CI: 3.25-4.3) and 11.2 (95 %CI: 9.3-12.1) months, respectively. One- and 2-year survival rates were 45.5 and 8.5 %, respectively. In multivariate analysis, HER2 positivity (HR = 0.29), the presence of lung metastases (HR = 2.49) and primary taxanes resistance (HR = 2.36) were the only three independent CBR predictive factors, while HR positivity (HR = 0.67), the presence of lung metastases (HR = 1.52) and primary taxanes resistance (HR = 1.50) were the only three TTP independent prognostic factors. Treatment was globally well tolerated. Most common grade 3-4 toxicities were neutropenia (20.9 %), peripheral neuropathy (3.9 %), anaemia (1.6 %), liver dysfunction (0.8 %) and thrombocytopenia (0.4 %). Thirteen patients (5 %) developed febrile neutropenia. CONCLUSION: EM is an effective new option in heavily pretreated MBC, with a favourable efficacy/safety ratio in a clinical practice setting. Our results comfort the use of this new molecule and pledge for the evaluation of EM-trastuzumab combination in this setting. Tumour biology, primary taxanes sensitivity and metastatic sites could represent useful predictive and prognostic factors.

A reappraisal of 'International Stratigraphic Lexicon' and the need for the creation named units critical catalogues

Analysis of stratigraphic terminology and classification, shows that time-related stratigraphic units, which by definition have a global extent, are the concern of international cornrnissions and committees of the intemational Union of Geological Sciences (IUGS) . In contrast, lithostratigraphic, and other closely related units, are regional in extent and are catalogued in the International Stratigraphic Lexicon (ISL), the last volume of which, was published in 1987. Tlie intemational Commission on Stratigraphy (ICS) is currently attempting to revitalize the publication of ISL, given that the information contained in published volumes has never been updated, and that there has been a significant increase in stratigraphic research in recent decades. The proliferation of named units in the South Pyrenean and Ebro Basin Paleogene is evaluated to illustrate the extent of the problem. Moreover, new approaches to stratigraphic analysis have led to the naming of genetic units according to similar guidelines followed in the naming of descnptive or lithostratigraphic units. This has led to considerable confusion. The proposal to revitalize the ISL is accepted as part of the solution, that should also include the publication of critica1 catalogues, and the creation of norms for genetic unit terminology.

Clustering and International Competitiveness of Information Technology Industry in the Saint Petersburg Area

The main objective of this study is to assess the potential of the information technology industry in the Saint Petersburg area to become one of the new key industries in the Russian economy. To achieve this objective, the study analyzes especially the international competitiveness of the industry and the conditions for clustering. Russia is currently heavily dependent on its natural resources, which are the main source of its recent economic growth. In order to achieve good long-term economic performance, Russia needs diversification in its well-performing industries in addition to the ones operating in the field of natural resources. The Russian government has acknowledged this and started special initiatives to promote such other industries as information technology and nanotechnology. An interesting industry that is basically less than 20 years old and fast growing in Russia, is information technology. Information technology activities and markets are mainly concentrated in Russia’s two biggest cities, Moscow and Saint Petersburg, and areas around them. The information technology industry in the Saint Petersburg area, although smaller than Moscow, is especially dynamic and is gaining increasing foreign company presence. However, the industry is not yet internationally competitive as it lacks substantial and sustainable competitive advantages. The industry is also merely a potential global information technology cluster, as it lacks the competitive edge and a wide supplier and manufacturing base and other related parts of the whole information technology value system. Alone, the industry will not become a key industry in Russia, but it will, on the other hand, have an important supporting role for the development of other industries. The information technology market in the Saint Petersburg area is already large and if more tightly integrated to Moscow, they will together form a huge and still growing market sufficient for most companies operating in Russia currently and in the future. Therefore, the potential of information technology inside Russia is immense.

International STakeholder NETwork (ISTNET): creating a developmental neurotoxicity (DNT) testing road map for regulatory purposes.

A major problem in developmental neurotoxicity (DNT) risk assessment is the lack of toxicological hazard information for most compounds. Therefore, new approaches are being considered to provide adequate experimental data that allow regulatory decisions. This process requires a matching of regulatory needs on the one hand and the opportunities provided by new test systems and methods on the other hand. Alignment of academically and industrially driven assay development with regulatory needs in the field of DNT is a core mission of the International STakeholder NETwork (ISTNET) in DNT testing. The first meeting of ISTNET was held in Zurich on 23-24 January 2014 in order to explore the concept of adverse outcome pathway (AOP) to practical DNT testing. AOPs were considered promising tools to promote test systems development according to regulatory needs. Moreover, the AOP concept was identified as an important guiding principle to assemble predictive integrated testing strategies (ITSs) for DNT. The recommendations on a road map towards AOP-based DNT testing is considered a stepwise approach, operating initially with incomplete AOPs for compound grouping, and focussing on key events of neurodevelopment. Next steps to be considered in follow-up activities are the use of case studies to further apply the AOP concept in regulatory DNT testing, making use of AOP intersections (common key events) for economic development of screening assays, and addressing the transition from qualitative descriptions to quantitative network modelling.

Clustering and international competitiveness of information technology industry in the Saint Petersburg area

The main objective of this study is to assess the potential of the information technology industry in the Saint Petersburg area to become one of the new key industries in the Russian economy. To achieve this objective, the study analyzes especially the international competitiveness of the industry and the conditions for clustering. Russia is currently heavily dependent on its natural resources, which are the main source of its recent economic growth. In order to achieve good long-term economic performance, Russia needs diversification in its well-performing industries in addition to the ones operating in the field of natural resources. The Russian government has acknowledged this and started special initiatives to promote such other industries as information technology and nanotechnology. An interesting industry that is basically less than 20 years old and fast growing in Russia, is information technology. Information technology activities and markets are mainly concentrated in Russia’s two biggest cities, Moscow and Saint Petersburg, and areas around them. The information technology industry in the Saint Petersburg area, although smaller than Moscow, is especially dynamic and is gaining increasing foreign company presence. However, the industry is not yet internationally competitive as it lacks substantial and sustainable competitive advantages. The industry is also merely a potential global information technology cluster, as it lacks the competitive edge and a wide supplier and manufacturing base and other related parts of the whole information technology value system. Alone, the industry will not become a key industry in Russia, but it will, on the other hand, have an important supporting role for the development of other industries. The information technology market in the Saint Petersburg area is already large and if more tightly integrated to Moscow, they will together form a huge and still growing market sufficient for most companies operating in Russia currently and in the future. Therefore, the potential of information technology inside Russia is immense.

CSR : a new governance approach for regulating professional sport ? : the case of french professionnal sports clubs

The purpose of this paper is to examine the CSR practices and their implementation in the context of French professional sports clubs. In doing so, it analyses the link between the governance of sports clubs and CSR, which is viewed as a component of governance expanded to stakeholders and contributing to the creation of shared value. Drawing on interview data with key stakeholders of four professional sport clubs (football and basketball) and secondary material, the study sheds light on the determinants, the implementation as well as the impact of CSR on the governance of the professional clubs under examination.

A new approach for the separation of spermatozoa from other cell types in forensically relevant samples.

Due to imbalance in genetic material contribution, gynecological samples collected following a sexual assault are challenging to process in order to resolve the male contributor's DNA profile. We set up a new and fast procedure for the recovery and separation of cells from cotton swabs, or other supports. Using spermatozoa specific CD52 antibody coupled to magnetic beads along with magnetic columns, this procedure was first developed and optimized by flow cytometry. It allows the recovery of two enriched cell fractions: a sperm fraction, mostly enriched with the alleged offender's spermatozoa, and a non-sperm fraction, mostly enriched with cells from the victim. Processing fresh as well as six months old mock samples, made of buccal swabs loaded with sperm dilutions, resulted in full single NGM SElect DNA profiles of the sperm donors, respectively the epithelial cells donors, for the sperm and the non-sperm fractions. Untreated duplicate samples processed in parallel only provided the autosomal DNA profiles of the epithelial cells donors. This new procedure can be rapidly tested and adopted by forensic laboratories worldwide as it uses material already commercially available. Moreover it can be easily automated with existing platform, and could therefore provide a mean to rapidly reduce existing backlogs.

Means and challenges in international operations for a Finnish mobile application provider

Master’s Thesis concentrates to means and challenges in international operations for a Finnish mobile application provider Small Planet Oy during its various company stages from founding till maturing and during macro economical phases between year 1998 and 2008. Small Planet has just celebrated its 10 year anniversary and is therefore quite an extraordinary company which has survived all the highs and lows during past ten years and which has operated in the market as long as the whole mobile application industry has existed. Master’s Thesis describes possibilities for a company’s internationalization with different entry modes like exporting, licensing, investment entry and co-operative operations which are suitable for a mobile application provider. Unsuitable entry modes like franchising or contract manufacturing are not explained. The goal has been to analyze Small Planet’s international operations and to make conclusions from the practical experiences. Analysis and conclusions shall help Small Planet in its international operations in the future and should give insight to other mobile application companies and their managers who are in the situation of planning their own international operations. Results show that the best ways for Small Planet to internationalize its operations has been the co-operation with a big domestic client and the co-operation with Finnish operator infrastructure providers which have complementary products with Small Planet. Through these co-operations Small Planet has got lot of new international clients. Same time financial risks and investment need for international operations have been low. Co-operative international sales can be the most efficient international entry mode for a mobile application provider.

Emotions in International Politics. Beyond Mainstream International Relations

In recent years, social scientists have increasingly recognized the interconnectedness of thought on emotions. Nowhere is the role of passions more evident than international politics, where pride, anger, guilt, fear, empathy, and other feelings are routinely on display. But in the absence of an overarching theory of emotions, how can we understand their role at the international level? Emotions in International Politics fills the need for theoretical tools in the new and rapidly growing subfield of international relations. Eminent scholars from a range of disciplines consider how emotions can be investigated from an international perspective involving collective players, drawing evidence from such emotionally fraught events as the Rwandan genocide, World War II, the 9/11 attacks, and the Iranian nuclear standoff. The path-breaking research collected in Emotions in International Politics will be a valuable theoretical guide to understanding conflict and cooperation in international relations.