Financial strategies for minimizing corporate income taxes under Brazil's new global tax system

In 1996, Brazil adopted a worldwide income tax system for corporations. This system represents a fundamental change in how the Brazílian government treats multinational transactions and the tax minimizing strategies relevant to businesses. In this article, we describe the conceptual basis for worldwide tax systems and the problem of double taxation that they create. Responses to double taxation by both the governments and the priva te sector are considered. Namely, the imperfect mechanisms developed by Brazil and other countries for mitigating double taxation are analyzed. We ultimately focus on the strategies that companies utilize in order not only to avoid double texetion, but also to take advantage of tax havens.

Book-tax differences e gerenciamento de resultados no mercado de ações do Brasil

Este estudo verifica a relação entre book-tax differences (BTD) e gerenciamento de resultado em companhias listadas na BM&FBovespa no período de 2005 a 2009. Metodologicamente, foram empregadas duas abordagens: (i) distribuição de frequências e (ii) accruals discricionários - Modelo Jones Modificado. Os achados indicam uma relação diretamente proporcional entre a BTD e os accruals discricionários. Foram identificadas evidências de que as entidades preponderantemente gerenciam seus resultados na mesma direção do sinal observado da BTD, além de buscarem apresentar o montante de BTD em nível e em variação em torno do ponto zero e desta forma evitar sinalizar baixa qualidade do lucro. Adicionalmente, foram encontradas evidências de que o tamanho da firma e a adoção do regime tributário de transição estão relacionados de forma inversamente proporcional ao nível dos accruals discricionários.

EVALUATING THE EFFICIENCY PROGRESS WITH TECHNOLOGY IN A SPANISH HOTEL CHAIN

ABSTRACTThis paper analyzes the changes in the total factor productivity index of a Spanish hotel chain in the period from 2007 to 2010 with the purpose of identifying efficiency patterns for the chain in a period of financial crisis. The data envelopment analysis (DEA) Malmquist productivity index was used to estimate productivity change in 38 hotels of the AC chain. Results reveal AC hotels' efficiency trends and, therefore, their competitiveness in the recession period; they also show the changes experienced in these hotels' total productivity and its components: technological and efficiency changes. Positive efficiency changes were due to positive technical efficiency rather than technological efficiency. The recession period certainly influenced the performance of AC Hotels, which focused on organizational changes rather than investing in technology.

Compression Efficiency Analysis of Wyner-Ziv Video Coding with Motion Compensated Side Information Interpolation

The Wyner-Ziv video coding (WZVC) rate distortion performance is highly dependent on the quality of the side information, an estimation of the original frame, created at the decoder. This paper, characterizes the WZVC efficiency when motion compensated frame interpolation (MCFI) techniques are used to generate the side information, a difficult problem in WZVC especially because the decoder only has available some reference decoded frames. The proposed WZVC compression efficiency rate model relates the power spectral of the estimation error to the accuracy of the MCFI motion field. Then, some interesting conclusions may be derived related to the impact of the motion field smoothness and the correlation to the true motion trajectories on the compression performance.

Reward-risk efficiency in proportional reinsurance with different risk measures

We have studied, in particular under normality of the implied random variables, the connections between different measures of risk such as the standard deviation, the W-ruin probability and the p-V@R. We discuss conditions granting the equivalence of these measures with respect to risk preference relations and the equivalence of dominance and efficiency of risk-reward criteria involving these measures. Then more specifically we applied these concepts to rigorously face the problem of finding the efficient set of de Finetti’s variable quota share proportional reinsurance.

From efficiency to optimality in proportional reinsurance under group correlation

Based on our recent discovery of closed form formulae of efficient Mean Variance retentions in variable quota-share proportional reinsurance under group correlation, we analyzed the influence of different combination of correlation and safety loading levels on the efficient frontier, both in a single period stylized problem and in a multiperiod one.

Light pollution and energy efficiency: a case study of the village of Vialonga

Since industrialization and the formation of larger urban centers in the nineteenth century, pollution of the environment was always present in daily life in various ways, namely in the form of light. Light pollution can cause various consequences, both for humans and for their ecosystem, producing effects on environmental, social, economic and scientific level. In Portugal, the lighting is responsible for 3% of total electricity consumption, energy costs are in some cases more than 50% towards the costs incurred by municipalities with energy, checking-in recent years a trend similar to that improvement of illumination levels in the region (about 4 to 5% per year). Proper use of lighting brings many benefits both to the citizen and environment, since greater energy efficiency can contribute to reducing CO2 emissions, energy costs, as well as to decrease the use of resources not-renewable and/or contamination of renewable resources, which can occurs in the process of obtaining electricity. The present study has a main goal to analyze the illuminance levels associated to the public lighting of the village of Vialonga, Vila Franca de Xira (Portugal), to verify if it is efficient. The aim is also to relate the efficiency of street lighting with the existence of light pollution.

Energy efficiency analysis considering the use of an intelligent systems management in a smart home

In this abstract is presented an energy management system included in a SCADA system existent in a intelligent home. The system control the home energy resources according to the players definitions (electricity consumption and comfort levels), the electricity prices variation in real time mode and the DR events proposed by the aggregators.

Effect of the compact Ti layer on the efficiency of dye-sensitized solar cells assembled using stainless steel sheets

Titanium films have been deposited on stainless steel metal sheets using dc magnetron sputtering technique at different substrate temperatures. The structure of the titanium films strongly depend on the substrate temperature. The titanium film deposited at the substrate temperature lower than 300 ◦C has a loose flat sheet grains structure and the titanium film prepared at the substrate temperature higher than 500 ◦C has a dense nubby grains structure. The DSSC assembled using stainless steel sheet coated with titanium film deposited at high substrate temperature has a low charge transfer resistance in the TiO2/Ti interface and results in a high conversion efficiency. The DSSC assembled using stainless steel sheet coated with titanium film deposited at temperature higher than 500 ◦C has higher conversion efficiency than that assembled using titanium metal sheet as the substrate. The maximum conversion efficiency, 2.26% is obtained for DSSC assembled using stainless steel sheet coated with titanium film deposited at 700 ◦C substrate temperature, which is about 70% of the conversion efficiency of the FTO reference cell used in this study.

Efficiency Measures in the Agricultural Sector: The Beginning

Copyright © 2013 Springer Netherlands.

Animal Grazing System Efficiency

Copyright © 2013 Springer Netherlands.

Azorean Agriculture Efficiency by PAR

Copyright © 2013 Springer Netherlands.

Efficiency Assessment: Final Remarks

Copyright © 2013 Springer Netherlands.

Efficiency Measures in the Agricultural Sector: With Applications

Copyright 2013 Springer Netherlands.

O Combate à fraude e evasão fiscais: a atuação da administração tributária e a avaliação dos resultados obtidos

Dissertação para obtenção do Grau de Mestre em Auditoria Orientação científica do Professor Coordenador Rodrigo Mário Oliveira Carvalho