The traditional rationale of the arm's length approach to transfer pricing - should the separate accounting model be maintained for modern multinational entities?

This article examines the current transfer pricing regime to consider whether it is a sound model to be applied to modern multinational entities. The arm's length price methodology is examined to enable a discussion of the arguments in favour of such a regime. The article then refutes these arguments concluding that, contrary to the very reason multinational entities exist, applying arm's length rules involves a legal fiction of imagining transactions between unrelated parties. Multinational entities exist to operate in a way that independent entities would not, which the arm's length rules fail to take into account. As such, there is clearly an air of artificiality in applying the arm's length standard. To demonstrate this artificiality with respect to modern multinational entities, multinational banks are used as an example. The article concluded that the separate entity paradigm adopted by the traditional transfer pricing regime is incongruous with the economic theory of modern multinational enterprises.

Experience as a moderator of involvement and satisfaction on brand loyalty in a business-to-business setting 02-314R

This paper examines the relative influence of two key antecedents of brand loyalty-satisfaction and involvement and the moderating role of experience, using a sample of business buyers. The central argument of this paper is that the strength of the effect of these variables on attitudinal brand loyalty will vary with the level of customer experience with purchasing the service. Building on previous research which examined low-risk, customer product settings [Kim, J., Lim, J.S., & Bhargava, M. (1998). The role of affect in attitude formation: A classical conditioning approach. Journal of the Academy of Marketing Science 26 (2): pp. 143-152; Shiv, B., & Fedorikhin, A. (1999). Heart and mind in conflict: The interplay of affect and cognition in consumer decision-making. Journal of Consumer Research 26: 278], this study shows that for a high-risk setting, involvement with the service category will be more dominant in its influence on brand loyalty than satisfaction with the preferred brand. Furthermore, it was found that experience moderated the influence of involvement and satisfaction on attitudinal brand loyalty for a high-risk business-to-business service. This study provides new insights into the theory and practice of buyer behavior and business-to-business brands. Crown Copyright (C) 2004 Published by Elsevier Inc. All rights reserved.

Measuring market power in electricity generation: A long-term perspective using a programming model

This paper focuses on measuring the extent to which market power has been exercised in a recently deregulated electricity generation sector. Our study emphasises the need to consider the concept of market power in a long-run dynamic context. A market power index is constructed focusing on differences between actual market returns and long-run competitive returns, estimated using a programming model devised by the authors. The market power implications of hedge contracts are briefly considered. The state of Queensland Australia is used as a context for the analysis. The results suggest that generators have exercised significant market power since deregulation.

An experimental and finite element poroelastic creep response analysis of an intervertebral hydrogel disc model in axial compression

A hydrogel intervertebral disc (lVD) model consisting of an inner nucleus core and an outer anulus ring was manufactured from 30 and 35% by weight Poly(vinyl alcohol) hydrogel (PVA-H) concentrations and subjected to axial compression in between saturated porous endplates at 200 N for 11 h, 30 min. Repeat experiments (n = 4) on different samples (N = 2) show good reproducibility of fluid loss and axial deformation. An axisymmetric nonlinear poroelastic finite element model with variable permeability was developed using commercial finite element software to compare axial deformation and predicted fluid loss with experimental data. The FE predictions indicate differential fluid loss similar to that of biological IVDs, with the nucleus losing more water than the anulus, and there is overall good agreement between experimental and finite element predicted fluid loss. The stress distribution pattern indicates important similarities with the biological lVD that includes stress transference from the nucleus to the anulus upon sustained loading and renders it suitable as a model that can be used in future studies to better understand the role of fluid and stress in biological IVDs. (C) 2005 Springer Science + Business Media, Inc.

Stability and cycles in a cobweb model with heterogeneous expectations

We investigate the dynamics of a cobweb model with heterogeneous beliefs, generalizing the example of Brock and Hommes (1997). We examine situations where the agents form expectations by using either rational expectations, or a type of adaptive expectations with limited memory defined from the last two prices. We specify conditions that generate cycles. These conditions depend on a set of factors that includes the intensity of switching between beliefs and the adaption parameter. We show that both Flip bifurcation and Neimark-Sacker bifurcation can occur as primary bifurcation when the steady state is unstable.

Understanding sociocognitive space of written discourse: Implications for teaching business writing to Chinese students

Confronted with various issues in teaching business writing to Chinese students in New Zealand, this paper sees the need for bridging the gap between genre-based research and teaching in an intercultural context. Specifically, it develops an intercultural reflective model in the light of Bhatia's sociocognitive genre study as well as cross-cultural persuasion. As an important part of the model, New Zealand and Chinese experts' intracultural and intercultural reflections on business writing are solicited and compared and the theoretical implications for teaching and learning business writing are discussed. It has been found, through a case study of analysing English and Chinese business faxes, this model can offer an in-depth understanding about discursive competence across cultures, and provide a link between genre-based theory, teaching practice and professional expertise.

Partial completion of activity in business process specification

We examine the current workflow modelling capability from a new angle and demonstrate a weakness of current workflow specification languages in relation to execution of activities. This shortcoming is mainly due to serious limitations of the corresponding computational/execution model behind the business process modelling language constructs. The main purpose of this paper is the introduction of new specification/modelling constructs allowing for more precise representation of complex activity states during its execution. This new concept enables visibility of a new activity state–partial completion of activity, which in turn allows for a more flexible and precise enforcement/monitoring of automated business processes.