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.

Applications of artificial intelligence to condition-based maintenance

In this paper we discuss interesting developments of expert systems for machine diagnosis and condition-based maintenance. We review some elements of condition-based maintenance and its applications, expert systems for machine diagnosis, and an example of machine diagnosis. In the last section we note some problems to be resolved so that expert systems for machine diagnosis may gain wider acceptance in the future.

A JOINT EXPERIMENTAL ANALYSIS OF INVESTOR BEHAVIOR IN IPO PRICING METHODS

This article jointly examines the differences of laboratory versions of the Dutch clock open auction, a sealed-bid auction to represent book building, and a two-stage sealed bid auction to proxy for the “competitive IPO”, a recent innovation used in a few European equity initial public offerings. We investigate pricing, seller allocation, and buyer welfare allocation efficiency and conclude that the book building emulation seems to be as price efficient as the Dutch auction, even after investor learning, whereas the competitive IPO is not price efficient, regardless of learning. The competitive IPO is the most seller allocative efficient method because it maximizes offer proceeds. The Dutch auction emerges as the most buyer welfare allocative efficient method. Underwriters are probably seeking pricing efficiency rather than seller or buyer welfare allocative efficiency and their discretionary pricing and allocation must be important since book building is prominent worldwide.

Robosonic: Randomness-Based Manipulation of Sounds Assisted by Robots

In this text, we intend to explore the possibilities of sound manipulation in a context of augmented reality (AR) through the use of robots. We use the random behaviour of robots in a limited space for the real-time modulation of two sound characteristics: amplitude and frequency. We add the possibility of interaction with these robots, providing the user the opportunity to manipulate the physical interface by placing markers in the action space, which alter the behaviour of the robots and, consequently, the audible result produced. We intend to demonstrate through the agents, programming of random processes and direct manipulation of this application, that it is possible to generate empathy in interaction and obtain specific audible results, which would be difficult to otherwise reproduce due to the infinite loops that the interaction promotes.

A System Dynamics-Based Simulation Experiment for Testing Mental Model and Performance Effects of Using the Balanced Scorecard

This study develops a theoretical model that explains the effectiveness of the balanced scorecard approach by means of a system dynamics and feedback learning perspective. Presumably, the balanced scorecard leads to a better understanding of context, allowing managers to externalize and improve their mental models. We present a set of hypotheses about the influence of the balanced scorecard approach on mental models and performance. A test based on a simulation experiment that uses a system dynamics model is performed. The experiment included three types of parameters: financial indicators; balanced scorecard indicators; and balanced scorecard indicators with the aid of a strategy map review. Two out of the three hypotheses were confirmed. It was concluded that a strategy map review positively influences mental model similarity, and mental model similarity positively influences performance.

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.

A system dynamics-based simulation

This study develops a theoretical model that explains the effectiveness of the balanced scorecard approach by means of a system dynamics and feedback learning perspective. Presumably, the balanced scorecard leads to a better understanding of context, allowing managers to externalize and improve their mental models. We present a set of hypotheses about the influence of the balanced scorecard approach on mental models and performance. A test based on a simulation experiment that uses a system dynamics model is performed. The experiment included three types of parameters: financial indicators; balanced scorecard indicators; and balanced scorecard indicators with the aid of a strategy map review. Two out of the three hypotheses were confirmed. It was concluded that a strategy map review positively influences mental model similarity, and mental model similarity positively influences performance.

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.

O trabalho em equipas docentes e o desenvolvimento da Educação Física

RESUMO: O sucesso das respostas aos novos desafios, exigências e expectativas que, nos dias de hoje, recaem sobre a escola, parece depender da concepção das estratégias organizacionais que globalmente a escola define, tendo em conta as características do contexto e das populações que serve. Depende por isso do modo como os actores chave se organizam e trabalham. Os modos de entender o trabalho docente em equipa prenunciam formas de entender a acção educativa e de conduzir a aprendizagem dos alunos. Tomando como ponto de partida as nossas experiências profissionais, este trabalho constitui uma reflexão sobre as possibilidades de desenvolvimento da Educação Física, baseada na escola e sustentada na organização do trabalho dos seus professores. Elaborando uma síntese dos principais problemas do seu desenvolvimento discutem-se as possibilidades e as vantagens da organização do trabalho dos professores em equipas, num contexto organizacional marcado por avanços e retrocessos nos processos de descentralização e atribuição de autonomia às escolas. Enquadra-se a organização do trabalho docente no âmbito das culturas de escola. Revisita-se o conceito de trabalho em equipa, distinguindo-o da simples participação nas estruturas da escola, realçando a sua importância na construção e gestão de conhecimento profissional através do estabelecimento de parcerias sinérgicas, onde o desempenho de papéis de liderança tem uma enorme importância. ABSTRACT: Successful responses to the new challenges, demands and expectations that currently are ascribed to schools seem to depend on the design of organizational strategies that broadly define the school, taking into account the characteristics of its context and the population it serves. Therefore, their success depends on how the key players are organized and work. The ways of perceiving the teaching team work forecast the ways of understanding the educational activity and how to lead learning. Starting from our own professional experience, this study is a reflection on the school based development of physical education, sustained by the organization of their teachers’ work. On organizing a summary of the major problems found in the development of this subject, we discuss the feasibilities and the gains got from the organization of teachers' teamwork, in an organizational context marked by promises and setbacks in the processes of decentralization and schools autonomy. The organization of teaching is to be seen as part of the school culture. We review the concept of teamwork as distinct from mere participation in the structures of the school, and its importance in the construction and management of professional knowledge will be highlighted by the establishment of synergistic partnerships, in which the performance of leadership roles is of the greatest importance. RÉSUMÉ: Le succès des réponses aux nouveaux défis, les exigences et les attentes que dans ces jours, s’accomplissent sur l'école, semble dépendre de la conception des stratégies d'organisation qui définit de façon générale l'école, en tenant compte des caractéristiques du contexte et des populations qu'elle dessert. Tout cela dépend donc de la façon dont les acteurs principaux sont organisés et travaillent. Les façons de comprendre l'équipe pédagogique démontrent des formes de comprendre l'activité éducative et de conduire à l'apprentissage des élèves. En prenant comme point de départ nos expériences professionnelles, ce travail est une réflexion sur le potentiel de développement de l'Éducation Physique, dépendante de l'école et soutenue dans l'organisation du travail de leurs enseignants. En préparant une synthèse des principaux problèmes de leur développement, on discute les possibilités et les avantages de l'organisation du travail des enseignants dans les équipes, dans un contexte organisationnel marqué par des avancées et des reculs dans le processus de décentralisation et l'accomplissement de l'autonomie aux écoles. On encadre l'organisation du travail des enseignants dans le champ des cultures de l’école. On revoit le concept du travail en équipe, en le distinguant de la simple participation dans les structures de l'école, en soulignant son importance dans la construction et gestion des connaissances professionnelles à travers l'établissement de partenariats synergiques, où les rôles de leadership joue un rôle d'une grande importance.

An approach to absorptive capacity based on the Portuguese textile industry

The main purpose of this research is to identify the hidden knowledge and learning mechanisms in the organization in order to disclosure the tacit knowledge and transform it into explicit knowledge. Most firms usually tend to duplicate their efforts acquiring extra knowledge and new learning skills while forgetting to exploit the existing ones thus wasting one life time resources that could be applied to increase added value within the firm overall competitive advantage. This unique value in the shape of creation, acquisition, transformation and application of learning and knowledge is not disseminated throughout the individual, group and, ultimately, the company itself. This work is based on three variables that explain the behaviour of learning as the process of construction and acquisition of knowledge, namely internal social capital, technology and external social capital, which include the main attributes of learning and knowledge that help us to capture the essence of this symbiosis. Absorptive Capacity provides the right tool to explore this uncertainty within the firm it is possible to achieve the perfect match between learning skills and knowledge needed to support the overall strategy of the firm. This study has taken in to account a sample of the Portuguese textile industry and it is based on a multisectorial analysis that makes it possible a crossfunctional analysis to check on the validity of results in order to better understand and capture the dynamics of organizational behavior.

An approach to absorptive capacity based on the Portuguese textile industry(Final version)

The main purpose of this research is to identify the hidden knowledge and learning mechanisms in the organization in order to disclosure the tacit knowledge and transform it into explicit knowledge. Most firms usually tend to duplicate their efforts acquiring extra knowledge and new learning skills while forgetting to exploit the existing ones thus wasting one life time resources that could be applied to increase added value within the firm overall competitive advantage. This unique value in the shape of creation, acquisition, transformation and application of learning and knowledge is not disseminated throughout the individual, group and, ultimately, the company itself. This work is based on three variables that explain the behaviour of learning as the process of construction and acquisition of knowledge, namely internal social capital, technology and external social capital, which include the main attributes of learning and knowledge that help us to capture the essence of this symbiosis. Absorptive Capacity provides the right tool to explore this uncertainty within the firm it is possible to achieve the perfect match between learning skills and knowledge needed to support the overall strategy of the firm. This study has taken in to account a sample of the Portuguese textile industry and it is based on a multisectorial analysis that makes it possible a crossfunctional analysis to check on the validity of results in order to better understand and capture the dynamics of organizational behavior.

A supervised versus home-based program effects on liver transplanted familial amyloidotic polyneuropathy patients: walking, fatigue and quality of life

Purpose: To evaluate the effects of a six months exercise training program on walking capacity, fatigue and health related quality of life (HRQL). Relevance: Familial amyloidotic polyneuropathy disease (FAP) is an autossomic neurodegenerative disease, related with systemic deposition of amyloidal fibre mainly on peripheral nervous system and mainly produced in the liver. FAP often results in severe functional limitations. Liver transplantation is used as the only therapy so far, that stop the progression of some aspects of this disease. Transplantation requires aggressive medication which impairs muscle metabolism and associated to surgery process and previous possible functional impairments, could lead to serious deconditioning. Reports of fatigue are common feature in transplanted patients. The effect of supervised or home-based exercise training programs in FAP patients after a liver transplant (FAPTX) is currently unknown.