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.

Understanding local governance: an international perspective

Enormous change and innovation in governmental practices are occurring throughout the world. Local governance, in particular, has become a concern in many countries. Processes such as redemocratization and decentralization and imperatives of international lending agencies have focused attention on developing good governance practices. Improvement in local government remains a high priority in most countries, but unless the relationship between citizens and government is more fully developed the actions of local government will not necessarily lead to improvement in the conditions of people's lives. This paper will explore the concept of governance and propose an analytical framework for the study of local governance in an international context. The article concludes with recommendations on strategies to improve governance systems and government performance.

STRATEGIES FOR SUPERIOR PERFORMANCE IN RECESSIONS: PRO OR COUNTER-CYCLICAL?

Recessions are recurring events in which most firms suffer severe impacts while others are less affected or may even prosper. Strategic management has made little progress in understanding such performance differences. In a scenario of decreased demand, intensified competition, and higher uncertainty, most firms try to survive by pro-cyclically cutting costs and investments. But firms could take advantage of undervalued resources in the market to counter-cyclically invest in new business opportunities to overtake competitors. We survey Brazilian firms in various industries about the 2008-2009 recession and analyze data using PLS-SEM. We find that while most firms pro-cyclically reduce costs and investments in recessions, a counter-cyclical strategy of investing in opportunities created by changes in the market enables superior performance. Most successful are firms with a propensity to recognize opportunities, an entrepreneurial orientation to invest, and the flexibility to efficiently implement investments.

MICROFINANCE AND CLIMATE CHANGE IMPACTS: THE CASE OF AGROAMIGO IN BRAZIL

ABSTRACTThis paper reports an empirical case study on the interface between microfinance and climate change actions. Climate change, which until recently seemed a luxury for the microfinance sector, now appears to be crucial for its future. For their low adaptive capacity, the millions of microfinance clients worldwide happen to be the most vulnerable to a changing climate. However, such an arena is still blurred from an academic viewpoint, and inexistent among Brazilian academia. Therefore, by investigating Brazil’s largest rural MFI, Agroamigo, we aim at providing an empirical contribution to green microfinance. The main conclusion is that, albeit Agroamigo offers important links to climate change initiatives, it will need to take better account of specific vulnerabilities and risks to protect its portfolio and clients better from climate change impacts.

Recensao de: I. K. Healy, Social Work Practices: Contemporary Perspectives on Change, London, Sage, 2000.

Revista Lusófona de Ciências Sociais

Evaluation of collaborative strategies for ecotourism and recreational activities in natural parks of Rio de Janeiro

In the city of Rio de Janeiro, the management agencies of environmental conservation units of the park type have been attempting to meet five primary objectives set by the National System for Conservation Units (NSCU), using participatory management guidelines for these units. Two of these objectives relate to the development of recreation activities that involve contact with nature and ecological tourism. This article presents the analyses and conclusions regarding the implementation of collaborative strategies with businesses to achieve such objectives; it is part of a series of research studies having a broader scope. Case studies were conducted in eight parks by means of dozens of interviews with managers and other interested social actors, as well as by documentary research and direct observation. The results suggest that the ecotourism objective is still far from being reached, and that the collaborative strategies used are not sufficient to compensate for the organizational, material and human limitations that encumber these agencies. It was also concluded for the sample that there lacks a strategic vision on the part of the three branches of government involved in the management of these parks in the sense of viewing ecotourism in the city's conservation units as a powerful means to foster local sustainable development.

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.

Monetary channels of social inclusion: a case study of basic income and the Caixa Econômica Federal in Brazil

This article reports evidence of new monetary channels for social inclusion involving basic income policies and the Caixa Econômica Federal, a Brazilian government savings bank. Since the Plano Real (Brazilian currency) and the liberalization of banking in the 1990s, the realization of competitive advantages by the Caixa as social policy agent and the importance of citizenship cards differ from existing theories of bank change, financial inclusion and monetary policy. Multi-method research reveals the importance of 1) political theories of basic income, 2) conceptions of citizenship and social justice, and 3) a back to the future modernization of government banking. This provides alternatives to contemporary market-based banking theory, neo-liberal policies, private and non-governmental microfinance strategies, and theories in political economy about fiscal constraints to social policies. New monetary channels of change also suggest that zero sum theories about politics, monetary authority and social inclusion are amiss.

Green microfinance: the case of the Cresol System in Southern Brazil

Climate change which until recently seemed a luxury for the microfinance sector, now appears to be crucial for the future of the sector. Due to their low adaptive capacity, the millions of MF clients worldwide happen to be the most vulnerable to a changing climate. Adapting previous analysis conducted in Nepal and Bangladesh by Agrawala and Maëlis (2010) to the Brazilian context, in this inductive qualitative study we aim to assess potential synergies between MF and CC actions and what strategies can be harnessed to better respond to CC vulnerabilities at client/MF level. To do so, we investigated the case of the second largest rural microcredit programme in Brazil, Sistema Cresol de Cooperativas de Crédito Rural com Interação Solidária. Albeit important overlaps between Cresol's product envelope and CC strategies exist, there is still room to realise synergies to both mitigate a new potential source of risk to Cresol's portfolio and to increase clients' adaptive capacity.

Investigation on the development of bidding strategies for a wind farm owner

In this paper, the development of bidding strategies is investigated for a wind farm owner. The optimization model is characterized by making the analysis of scenarios. The proposed approach allows evaluating alternative production strategies in order to submit bids to the electricity market with the goal of maximizing profits. The problem is formulated as a linear programming problem. An application to a case study is presented

Learning in higher education: strategies to overcome challenges faced by adult students - lessons drawn from two studies in portugal

Int’l J. of Information and Communication Technology Education, 3(2), 1-14, April-June 2007

How to teach mathematics with MOODLE

The aim of this article is to present a Project in the Oporto’s Institute of Accounting and Administration, which pretends to contribute for a change in the way of teaching and learning Mathematics. One of the main objectives of this project is to innovate the teaching and learning processes, exploring technologies as a pedagogical resource and to induce higher motivation to students, improve the rate of success and make available to students a set of materials adapted to their needs. This concern is justified due to the fact that students have a weak preparation, without consolidated basis. Since the year 2007/2008 the courses were adjusted to the Bologna process, which requires several changes in teacher’s and student’s roles, methodologies and assessment. The number of weekly classes has been reduced, so it was necessary to develop new strategies and methodologies to support the student. With the implementation of the Bologna Process in the Accounting degree, we felt a great need to provide other types of activities to students. To complement our theoretical and practical classes we have developed a project called MatActiva based on the Moodle platform offered by PAOL - Projecto de Apoio On-Line (Online Support Project). Moodle allows us to use the language TEX to create materials that use mathematical symbols. Using this functionality, we created a set of easy to use interactive resources. In MatActiva project, the students have access to a variety of different materials. We have followed a strategy that makes the project compatible with the theoretical and practical subjects/classes, complementing them. To do so, we created some resources, for instance multiple-choice tests, which are the most accessed by the students. These tests can be realized and corrected on-line and for each wrong answer there is a feedback with the resolution. We can find other types of resources: diagnostic tests, theoretical notes. There are not only the pre-requirements for subjects mathematics, but also materials to help students follow up the programs. We also developed several lessons. This activity consists of a number of pages, where each page has contents and leads to other pages, based on the student's progress. The teacher creates the choices and determines the next page that the student will see, based upon their knowledge. There is also an area of doubts, where the students can place all the mathematical doubts they have, and a teacher gives the answers or clues to help them in their work. MatActiva also offers an area where we can find some humour, curiosities, contests and games including mathematical contents to test the math skills, as well as links to pages about mathematical contents that could be useful for the study. Since ISCAP receives ERASMUS students and some of them attend mathematics, we developed some materials in English, so they can also use MatActiva. The main objectives of our project are not only to bring success in the subjects of mathematics, but also to motivate the students, encourage them to overcome theirs difficulties through an auto-study giving them more confidence and improve their relationship with the mathematics as well as the communication between students and teachers and among students.

Eastwards / westwards: which direction for gender studies in the 21st century?

Eastwards / Westwards: Which Direction for Gender Studies in the XXIst Century? is a collection of essays which focus on themes and methods that characterize current research into gender in Asian countries in general. In this collection, ideas derived from Gender Studies elsewhere in the world have been subjected to scrutiny for their utility in helping to describe and understand regional phenomena. But the concepts of Local and Global – with their discoursive productions – have not functioned as a binary opposition: localism and globalism are mutually constitutive and researchers have interrogated those spaces of interaction between the ‘self’ and the ‘other’, bearing in mind their own embeddedness in social and cultural structures and their own historical memory. Contributors to this collection provided a critical transnational perspective on some of the complex effects of the dynamics of cultural globalization, by exploring the relation between gender and development, language, historiography, education and culture. We have also given attention to the ideological and rhetorical processes through which gender identity is constructed, by comparing textual grids and patterns of expectation. Likewise, we have discussed the role of ethnography, anthropology, historiography, sociology, fiction, popular culture and colonial and post-colonial sources in (re)inventing old/new male/female identities, their conversion into concepts and circulation through time and space. This multicultural and trans-disciplinary selection of essays is totally written in English, fully edited and revised, therefore, it has a good potential for an immediate international circulation. This project may trace new paths and issues for discussion on what concerns the life, practices and narratives by and about women in Asia, as well as elsewhere in the present day global experience. Academic readership: Researchers, scholars, educators, graduate and post-graduate students, doctoral students and general non-fiction readers, with a special interest in Gender Studies, Asia, Colonial and Post-Colonial Literature, Anthropology, Cultural Studies, History, Historiography, Politics, Race, Feminism, Language, Linguistics, Power, Political and Feminist Agendas, Popular Culture, Education, Women’s Writing, Religion, Multiculturalism, Globalisation, Migration. Chapter summary: 1. “Social Gender Stereotypes and their Implication in Hindi”, Anjali Pande, Jawaharlal Nehru University, New Delhi, India. This essay looks at the subtle ways in which gender identities are constructed and reinforced in India through social norms of language use. Language itself becomes a medium for perpetuating gender stereotypes, forcing its speakers to confirm to socially defined gender roles. Using examples from a classroom discussion about a film, this essay will highlight the underlying rigid male-female stereotypes in Indian society with their more obvious expressions in language. For the urban woman in India globalisation meant increased economic equality and exposure to changed lifestyles. On an individual level it also meant redefining gender relations and changing the hierarchy in man-­woman relationships. With the economic independence there is a heightened sense of liberation in all spheres of social life, a confidence to fuzz the rigid boundaries of gender roles. With the new films and media celebrating this liberated woman, who is ready to assert her sexual needs, who is ready to explode those long held notions of morality, one would expect that the changes are not just superficial. But as it soon became obvious in the course of a classroom discussion about relationships and stereotypes related to age, the surface changes can not become part of the common vocabulary, for the obvious reason that there is still a vast gap between the screen image of this new woman and the ground reality. Social considerations define the limits of this assertiveness of women, whereas men are happy to be liberal within the larger frame of social sanctions. The educated urban woman in India speaks in favour of change and the educated urban male supports her, but one just needs to scratch the surface to see the time tested formulae of gender roles firmly in place. The way the urban woman happily balances this emerging promise of independence with her gendered social identity, makes it necessary to rethink some aspects of looking at gender in a gradually changing, traditional society like India. 2. “The Linguistic Dimension of Gender Equality”, Alissa Tolstokorova, Kiev Centre for Gender Information and Education, Ukraine. The subject-matter of this essay is gender justice in language which, as I argue, may be achieved through the development of a gender-related approach to linguistic human rights. The last decades of the 20th century, globally marked by a “gender shift” in attitudes to language policy, gave impetus to the social movement for promoting linguistic gender equality. It was initiated in Western Europe and nowadays is moving eastwards, as ideas of gender democracy progress into developing countries. But, while in western societies gender discrimination through language, or linguistic sexism, was an issue of concern for over three decades, in developing countries efforts to promote gender justice in language are only in their infancy. My argument is that to promote gender justice in language internationally it is necessary to acknowledge the rights of women and men to equal representation of their gender in language and speech and, therefore, raise a question of linguistic rights of the sexes. My understanding is that the adoption of the Universal Declaration of Linguistic Rights in 1996 provided this opportunity to address the problem of gender justice in language as a human rights issue, specifically as a gender dimension of linguistic human rights. 3. “The Rebirth of an Old Language: Issues of Gender Equality in Kazakhstan”, Maria Helena Guimarães, Polytechnic Institute of Porto, Portugal. The existing language situation in Kazakhstan, while peaceful, is not without some tension. We propose to analyze here some questions we consider relevant in the frame of cultural globalization and gender equality, such as: free from Russian imperialism, could Kazakhstan become an easy prey of Turkey’s “imperialist dream”? Could these traditionally Muslim people be soon facing the end of religious tolerance and gender equality, becoming this new old language an easy instrument for the infiltration in the country of fundamentalism (it has already crossed the boarders of Uzbekistan), leading to a gradual deterioration of its rich multicultural relations? The present structure of the language is still very fragile: there are three main dialects and many academics defend the re-introduction of the Latin alphabet, thus enlarging the possibility of cultural “contamination” by making the transmission of fundamentalist ideas still easier through neighbour countries like Azerbaijan, Uzbekistan and Turkmenistan (their languages belong to the same sub-group of Common Turkic), where the Latin alphabet is already in use, and where the ground for such ideas shown itself very fruitful. 4. “Construction of Womanhood in the Bengali Language of Bangladesh”, Raasheed Mahmood; University of New South Wales, Sydney. The present essay attempts to explore the role of gender-based language differences and of certain markers that reveal the status accorded to women in Bangladesh. Discrimination against women, in its various forms, is endemic in communities and countries around the world, cutting across class, race, age, and religious and national boundaries. One cannot understand the problems of gender discrimination solely by referring to the relationship of power or authority between men and women. Rather one needs to consider the problem by relating it to the specific social formation in which the image of masculinity and femininity is constructed and reconstructed. Following such line of reasoning this essay will examine the nature of gender bias in the Bengali language of Bangladesh, holding the conviction that as a product of social reality language reflects the socio-cultural behaviour of the community who speaks it. This essay will also attempt to shed some light on the processes through which gender based language differences produce actual consequences for women, who become exposed to low self-esteem, depression and systematic exclusion from public discourse. 5. “Marriage in China as an expression of a changing society”, Elisabetta Rosado David, University of Porto, Portugal, and Università Ca’Foscari, Venezia, Italy. In 29 April 2001, the new Marriage Law was promulgated in China. The first law on marriage was proclaimed in 1950 with the objective of freeing women from the feudal matrimonial system. With the second law, in 1981, values and conditions that had been distorted by the Cultural Revolution were recovered. Twenty years later, a new reform was started, intending to update marriage in the view of the social and cultural changes that occurred with Deng Xiaoping’s “open policy”. But the legal reform is only the starting point for this case-study. The rituals that are followed in the wedding ceremony are often hard to understand and very difficult to standardize, especially because China is a vast country, densely populated and characterized by several ethnic minorities. Two key words emerge from this issue: syncretism and continuity. On this basis, we can understand tradition in a better way, and analyse whether or not marriage, as every social manifestation, has evolved in harmony with Chinese culture. 6. “The Other Woman in the Portuguese Colonial Empire: The Case of Portuguese India”, Maria de Deus Manso, University of Évora, Portugal. This essay researches the social, cultural and symbolic history of local women in the Portuguese Indian colonial enclaves. The normative Portuguese overseas history has not paid any attention to the “indigenous” female populations in colonial Portuguese territories, albeit the large social importance of these social segments largely used in matrimonial and even catholic missionary strategies. The first attempt to open fresh windows in the history of this new field was the publication of Charles Boxer’s referential study about Women in lberian Overseas Expansion, edited in Portugal only after the Revolution of 1975. After this research we can only quote some other fragmentary efforts. In fact, research about the social, cultural, religious, political and symbolic situation of women in the Portuguese colonial territories, from the XVI to the XX century, is still a minor historiographic field. In this essay we discuss this problem and we study colonial representations of women in the Portuguese Indian enclaves, mainly in the territory of Goa, using case studies methodologies. 7. “Heading East this Time: Critical Readings on Gender in Southeast Asia”, Clara Sarmento, Polytechnic Institute of Porto, Portugal. This essay intends to discuss some critical readings of fictional and theoretical texts on gender condition in Southeast Asian countries. Nowadays, many texts about women in Southeast Asia apply concepts of power in unusual areas. Traditional forms of gender hegemony have been replaced by other powerful, if somewhat more covert, forms. We will discuss some universal values concerning conventional female roles as well as the strategies used to recognize women in political fields traditionally characterized by male dominance. Female empowerment will mean different things at different times in history, as a result of culture, local geography and individual circumstances. Empowerment needs to be perceived as an individual attitude, but it also has to be facilitated at the macro­level by society and the State. Gender is very much at the heart of all these dynamics, strongly related to specificities of historical, cultural, ethnic and class situatedness, requiring an interdisciplinary transnational approach.

A influência do membro superior no ciclo da marcha

Objectivo: Pretendeu-se avaliar as modificações no comportamento neuro-motor a nível da funcionalidade do membro superior predominantemente afectado e a sua influência no ciclo da marcha de dois indivíduos com Acidente Vascular Cerebral, face a um programa de intervenção em fisioterapia, segundo uma abordagem baseada no Conceito de Bobath. Foi também objectivo averiguar o impacto qualitativo nos componentes e estados de saúde. Metodologia: A avaliação foi realizada em dois indivíduos com sequelas de Acidente Vascular Cerebral, antes e após o plano de intervenção segundo o Conceito de Bobath, através do registo observacional, da Classificação Internacional de Funcionalidade, Incapacidade e Saúde, da Performance-Oriented Mobility Assessment POMA I, da Time Up and Go Test, da Motor Assessement Scale e da Motor Evaluation Scale for Upper Extremity in Patients. Resultados: Obteve-se um incremento da funcionalidade do membro superior predominantemente afectado, com uma atribuição na Classificação Internacional de Funcionalidade, Incapacidade e Saúde de qualificadores correspondentes a dificuldade ligeira a moderada ao nível da mobilidade e dos auto cuidado após o plano de intervenção, repercutindo-se assim numa diminuição da restrição na participação e limitação da actividade. Houve um aumento de score total em todos os instrumentos e escalas de medidas de avaliação utilizadas, tendo os indivíduos alcançado uma maior funcionalidade do membro superior e um padrão de marcha mais eficiente, com uma menor necessidade de recorrer a estratégias compensatórias de movimento. Conclusão: O plano de intervenção, baseado numa abordagem segundo o Conceito de Bobath, essencialmente dirigido para a obtenção de ganhos funcionais ao nível do membro superior predominantemente afectado nos indivíduos em estudo, parece ter contribuído para induzir mudanças no comportamento neuro-motor, verificando-se uma influência no ciclo de marcha ao nível da qualidade e eficiência do movimento.