Juridisen kaksinkertaisen verotuksen problematiikka kansainvälisessä yritystoiminnassa

Tässä tutkielmassa tarkastellaan kansainvälisessä yritystoiminnassa esiintyviä juridisen kaksinkertaisen verotuksen ongelmatilanteita suomalaisten yritysten näkökulmasta. Tutkielmassa pohditaan lisäksi yritysten omaa roolia osana kaksinkertaisen verotuksen tilanteita. Juridista kaksinkertaista verotusta muodostuu, kun sama yhtiö maksaa samasta tulosta veroa kahteen valtioon. Teoriaosio etenee verotusoikeuden määrittämisestä kaksinkertaisen verotuksen muodostumiseen. Kaksinkertainen verotus pyritään poistamaan poistomenetelmällä, joka on Suomessa tavallisesti hyvitysmenetelmä. Ongelmatilanne muodostuu, kun kaksinkertaista verotusta ei saada tehokkaasti poistettua tulon lähdevaltion ja yhtiön asuinvaltion välillä. Tämä tutkielma on laadullinen tutkimus ja tutkimusmenetelmänä on käytetty teemahaastattelua. Tutkimustulokset osoittavat, että kvalifikaatiokonflikteissa juridisen kaksinkertaisen verotuksen ongelmatilanne esiintyy pääsääntöisesti rojalti-liiketulo -luokitteluristiriidan seurauksena. Kiinteän toimipaikan kvalifikaatio on harvinaisempi ongelmatilanne. Hyvitysmenetelmän suurimmat ongelmat esiintyvät puolestaan pääliikkeen tappiollisen liiketoiminnan johdosta. Toinen hyvitysmenetelmän ongelmakohta esiintyy, kun lähdeveron alainen tulo huomioidaan bruttotulosta, mutta ulkomaisen tulon hyvitys suoritetaan nettotulosta. Haastatteluiden perusteella on selvää, että yritysten oma rooli kaksinkertaisen verotuksen ehkäisyssä on merkittävä. Yrityksen omia vaikutusmahdollisuuksia ovat muun muassa riittävä ennakointikyky, dokumentointi, selkeät sopimukset ja asiantuntijuus.

Haar wavelets-based approach for quantifying credit portfolio losses

This paper proposes a new methodology to compute Value at Risk (VaR) for quantifying losses in credit portfolios. We approximate the cumulative distribution of the loss function by a finite combination of Haar wavelet basis functions and calculate the coefficients of the approximation by inverting its Laplace transform. The Wavelet Approximation (WA) method is specially suitable for non-smooth distributions, often arising in small or concentrated portfolios, when the hypothesis of the Basel II formulas are violated. To test the methodology we consider the Vasicek one-factor portfolio credit loss model as our model framework. WA is an accurate, robust and fast method, allowing to estimate VaR much more quickly than with a Monte Carlo (MC) method at the same level of accuracy and reliability.

Credit risk contributions under the Vasicek one-factor model: a fast wavelet expansion approximation

To measure the contribution of individual transactions inside the total risk of a credit portfolio is a major issue in financial institutions. VaR Contributions (VaRC) and Expected Shortfall Contributions (ESC) have become two popular ways of quantifying the risks. However, the usual Monte Carlo (MC) approach is known to be a very time consuming method for computing these risk contributions. In this paper we consider the Wavelet Approximation (WA) method for Value at Risk (VaR) computation presented in [Mas10] in order to calculate the Expected Shortfall (ES) and the risk contributions under the Vasicek one-factor model framework. We decompose the VaR and the ES as a sum of sensitivities representing the marginal impact on the total portfolio risk. Moreover, we present technical improvements in the Wavelet Approximation (WA) that considerably reduce the computational effort in the approximation while, at the same time, the accuracy increases.

“Documentary Credit Law : An Indian Perspective"

This is a study in international trade law. Documentary credits are the most common method of payment for goods in international trade. In India also these instruments are used both in national and international trade. The law governing these transactions remains haphazard. This study identifies the deficiencies in the regulatory framework for documentary credits in India. It primarily focuses on those areas which exhibits a lack of equality and justice in its operation. An attempt has also been made to identify the rights and duties of parties involved in the transaction. The reasons for the increase of fraudulent activities associated with the documents executed in the documentary credit transactions are also examined. How far the law in India is sufficient to ensure fair business practice in international trade financing is also examined. Methodology adopted for the study is analytical. The statutory provisions, rules and case laws under these provisions have been examined. An empirical study by personal interview with the bankers is also made to ascertain the practice of bankers in India.

Credit union correspondents and financial inclusion in Brazil: an exploratory study

A rede de correspondentes bancários do Brasil tem sido estudada há mais de uma década, em particular por causa da sua importância no aumento do alcance de serviços financeiros para regiões distantes dos maiores centros urbanos. O uso de correspondentes por cooperativas de crédito não tem recebido destaque, apesar do papel importante das cooperativas na inclusão financeira. Esta dissertação adota uma abordagem “multimétodo” para efetuar uma pesquisa exploratória dos correspondentes de cooperativas de crédito no Brasil. A pesquisa visa, por um lado, alargar a compreensão dos incentivos que levam cooperativas a usarem correspondentes, e por outro, avaliar se esses correspondentes merlhoram a inclusão financeira. A pesquisa é formada por um estudo de caso assim como por análise de dados relativos ao registro de correspondentes bancários e de dados financeiros das cooperativas. Os resultados apontam que o uso de correspondentes bancários por cooperativas está relacionado à busca de maior eficiência e redução de filas nas agências. A melhoria da inclusão financeira por esses correspondentes limita-se a um serviço único – o recebimento de pagamentos. Não obstante, em 2014, cooperativas de correspondentes de crédito tinham um papel importante no fornecimento de serviços de recebimento de contas em 690 municípios brasileiros, dos quais 200 tinham baixos níveis de inclusão financeira. Apesar da escassa disponibilidade de serviços dos correspondentes das cooperativas, os resultados sugerem que esses atores poderiam adquirir uma importância maior na promoção de inclusão financeira no futuro.

Do agricultural subsidies crowd out or stimulate rural credit institutions? The Case of CAP Payments. Factor Markets Working Paper No. 4, September 2011

In this paper we estimate the impact of subsidies from the EU’s common agricultural policy on farm bank loans. According to the theoretical results, if subsidies are paid at the beginning of the growing season they may reduce bank loans, whereas if they are paid at the end of the season they increase bank loans, but these results are conditional on whether farms are credit constrained and on the relative cost of internal and external financing. In the empirical analysis, we use farm-level panel data from the Farm Accountancy Data Network to test the theoretical predictions for the period 1995–2007. We employ fixed-effects and generalised method of moment models to estimate the impact of subsidies on farm loans. The results suggest that subsidies influence farm loans and the effects tend to be non-linear and indirect. The results also indicate that both coupled and decoupled subsidies stimulate long-term loans, but the long-term loans of large farms increase more than those of small farms, owing to decoupled subsidies. Furthermore, the results imply that short-term loans are affected only by decoupled subsidies, and they are altered by decoupled subsidies more for small farms than for large farms; however, when controlling for endogeneity, only the decoupled payments affect loans and the relationship is non-linear.

The federal farm loan system, new method of farm mortgage finance, under national supervision; a practial manual upon organizing and conducting national farm loan associations, also joint stock land banks. Showing how farmers, investors, bankers and the public may obtain the fullest benefit of the system.

Mode of access: Internet.

Method of Linear Programming as an Idea for High School Curriculum

2010 Mathematics Subject Classification: 97D40, 97M10, 97M40, 97N60, 97N80, 97R80

A Highly Improved Method For Sensitive Determination Of Amitriptyline In Pharmaceutical Formulations Using An Unmodified Carbon Nanotube Electrode In The Presence Of Sulfuric Acid.

The present paper describes a novel, simple and reliable differential pulse voltammetric method for determining amitriptyline (AMT) in pharmaceutical formulations. It has been described for many authors that this antidepressant is electrochemically inactive at carbon electrodes. However, the procedure proposed herein consisted in electrochemically oxidizing AMT at an unmodified carbon nanotube paste electrode in the presence of 0.1 mol L(-1) sulfuric acid used as electrolyte. At such concentration, the acid facilitated the AMT electroxidation through one-electron transfer at 1.33 V vs. Ag/AgCl, as observed by the augmentation of peak current. Concerning optimized conditions (modulation time 5 ms, scan rate 90 mV s(-1), and pulse amplitude 120 mV) a linear calibration curve was constructed in the range of 0.0-30.0 μmol L(-1), with a correlation coefficient of 0.9991 and a limit of detection of 1.61 μmol L(-1). The procedure was successfully validated for intra- and inter-day precision and accuracy. Moreover, its feasibility was assessed through analysis of commercial pharmaceutical formulations and it has been compared to the UV-vis spectrophotometric method used as standard analytical technique recommended by the Brazilian Pharmacopoeia.

Influence Of Delivery Method On Neuroprotection By Bone Marrow Mononuclear Cell Therapy Following Ventral Root Reimplantation With Fibrin Sealant.

The present work compared the local injection of mononuclear cells to the spinal cord lateral funiculus with the alternative approach of local delivery with fibrin sealant after ventral root avulsion (VRA) and reimplantation. For that, female adult Lewis rats were divided into the following groups: avulsion only, reimplantation with fibrin sealant; root repair with fibrin sealant associated with mononuclear cells; and repair with fibrin sealant and injected mononuclear cells. Cell therapy resulted in greater survival of spinal motoneurons up to four weeks post-surgery, especially when mononuclear cells were added to the fibrin glue. Injection of mononuclear cells to the lateral funiculus yield similar results to the reimplantation alone. Additionally, mononuclear cells added to the fibrin glue increased neurotrophic factor gene transcript levels in the spinal cord ventral horn. Regarding the motor recovery, evaluated by the functional peroneal index, as well as the paw print pressure, cell treated rats performed equally well as compared to reimplanted only animals, and significantly better than the avulsion only subjects. The results herein demonstrate that mononuclear cells therapy is neuroprotective by increasing levels of brain derived neurotrophic factor (BDNF) and glial derived neurotrophic factor (GDNF). Moreover, the use of fibrin sealant mononuclear cells delivery approach gave the best and more long lasting results.

Uv-vis Spectra As An Alternative To The Lowry Method For Quantify Hair Damage Induced By Surfactants.

It is well known that long term use of shampoo causes damage to human hair. Although the Lowry method has been widely used to quantify hair damage, it is unsuitable to determine this in the presence of some surfactants and there is no other method proposed in literature. In this work, a different method is used to investigate and compare the hair damage induced by four types of surfactants (including three commercial-grade surfactants) and water. Hair samples were immersed in aqueous solution of surfactants under conditions that resemble a shower (38 °C, constant shaking). These solutions become colored with time of contact with hair and its UV-vis spectra were recorded. For comparison, the amount of extracted proteins from hair by sodium dodecyl sulfate (SDS) and by water were estimated by the Lowry method. Additionally, non-pigmented vs. pigmented hair and also sepia melanin were used to understand the washing solution color and their spectra. The results presented herein show that hair degradation is mostly caused by the extraction of proteins, cuticle fragments and melanin granules from hair fiber. It was found that the intensity of solution color varies with the charge density of the surfactants. Furthermore, the intensity of solution color can be correlated to the amount of proteins quantified by the Lowry method as well as to the degree of hair damage. UV-vis spectrum of hair washing solutions is a simple and straightforward method to quantify and compare hair damages induced by different commercial surfactants.

Graded Meshes In Bio-thermal Problems With Transmission-line Modeling Method.

In this study, the transmission-line modeling (TLM) applied to bio-thermal problems was improved by incorporating several novel computational techniques, which include application of graded meshes which resulted in 9 times faster in computational time and uses only a fraction (16%) of the computational resources used by regular meshes in analyzing heat flow through heterogeneous media. Graded meshes, unlike regular meshes, allow heat sources to be modeled in all segments of the mesh. A new boundary condition that considers thermal properties and thus resulting in a more realistic modeling of complex problems is introduced. Also, a new way of calculating an error parameter is introduced. The calculated temperatures between nodes were compared against the results obtained from the literature and agreed within less than 1% difference. It is reasonable, therefore, to conclude that the improved TLM model described herein has great potential in heat transfer of biological systems.

Trichomes Related To An Unusual Method Of Water Retention And Protection Of The Stem Apex In An Arid Zone Perennial Species.

It is well known that trichomes protect plant organs, and several studies have investigated their role in the adaptation of plants to harsh environments. Recent studies have shown that the production of hydrophilic substances by glandular trichomes and the deposition of this secretion on young organs may facilitate water retention, thus preventing desiccation and favouring organ growth until the plant develops other protective mechanisms. Lychnophora diamantinana is a species endemic to the Brazilian 'campos rupestres' (rocky fields), a region characterized by intense solar radiation and water deficits. This study sought to investigate trichomes and the origin of the substances observed on the stem apices of L. diamantinana. Samples of stem apices, young and expanded leaves were studied using standard techniques, including light microscopy and scanning and transmission electron microscopy. Histochemical tests were used to identify the major groups of metabolites present in the trichomes and the hyaline material deposited on the apices. Non-glandular trichomes and glandular trichomes were observed. The material deposited on the stem apices was hyaline, highly hydrophilic and viscous. This hyaline material primarily consists of carbohydrates that result from the partial degradation of the cell wall of uniseriate trichomes. This degradation occurs at the same time that glandular trichomes secrete terpenoids, phenolic compounds and proteins. These results suggest that the non-glandular trichomes on the leaves of L. diamantinana help protect the young organ, particularly against desiccation, by deposition of highly hydrated substances on the apices. Furthermore, the secretion of glandular trichomes probably repels herbivore and pathogen attacks.

Tissue Microarray Is A Reliable Method For Immunohistochemical Analysis Of Pleomorphic Adenoma.

To determine the most adequate number and size of tissue microarray (TMA) cores for pleomorphic adenoma immunohistochemical studies. Eighty-two pleomorphic adenoma cases were distributed in 3 TMA blocks assembled in triplicate containing 1.0-, 2.0-, and 3.0-mm cores. Immunohistochemical analysis against cytokeratin 7, Ki67, p63, and CD34 were performed and subsequently evaluated with PixelCount, nuclear, and microvessel software applications. The 1.0-mm TMA presented lower results than 2.0- and 3.0-mm TMAs versus conventional whole section slides. Possibly because of an increased amount of stromal tissue, 3.0-mm cores presented a higher microvessel density. Comparing the results obtained with one, two, and three 2.0-mm cores, there was no difference between triplicate or duplicate TMAs and a single-core TMA. Considering the possible loss of cylinders during immunohistochemical reactions, 2.0-mm TMAs in duplicate are a more reliable approach for pleomorphic adenoma immunohistochemical study.