Using global formulary apportionment for international profit allocation: The case of Indonesia's mining industry

My thesis examined an alternative approach, referred to as the unitary taxation approach to the allocation of profit, which arises from the notion that as a multinational group exists as a single economic entity, it should be taxed as one taxable unit. The plausibility of a unitary taxation regime achieving international acceptance and agreement is highly contestable due to its implementation issues, and economic and political feasibility. Using a case-study approach focusing on Freeport-McMoRan and Rio Tinto's mining operations in Indonesia, this thesis compares both tax regimes against the criteria for a good tax system - equity, efficiency, neutrality and simplicity. This thesis evaluates key issues that arise when implementing a unitary taxation approach with formulary apportionment based on the context of mining multinational firms in Indonesia.

Dos prejuízos no regime de participation exemption: a relação entre estabelecimento estável e filial

Mestrado em Fiscalidade

Cooperative Profit Sharing in Coalition-Based Resource Allocation in Wireless Networks

We consider a network in which several service providers offer wireless access to their respective subscribed customers through potentially multihop routes. If providers cooperate by jointly deploying and pooling their resources, such as spectrum and infrastructure (e.g., base stations) and agree to serve each others' customers, their aggregate payoffs, and individual shares, may substantially increase through opportunistic utilization of resources. The potential of such cooperation can, however, be realized only if each provider intelligently determines with whom it would cooperate, when it would cooperate, and how it would deploy and share its resources during such cooperation. Also, developing a rational basis for sharing the aggregate payoffs is imperative for the stability of the coalitions. We model such cooperation using the theory of transferable payoff coalitional games. We show that the optimum cooperation strategy, which involves the acquisition, deployment, and allocation of the channels and base stations (to customers), can be computed as the solution of a concave or an integer optimization. We next show that the grand coalition is stable in many different settings, i.e., if all providers cooperate, there is always an operating point that maximizes the providers' aggregate payoff, while offering each a share that removes any incentive to split from the coalition. The optimal cooperation strategy and the stabilizing payoff shares can be obtained in polynomial time by respectively solving the primals and the duals of the above optimizations, using distributed computations and limited exchange of confidential information among the providers. Numerical evaluations reveal that cooperation substantially enhances individual providers' payoffs under the optimal cooperation strategy and several different payoff sharing rules.

A nation’s role in addressing base erosion and profit shifting : balancing sovereignty with international collaboration and coordination

The notion of sovereignty is central to any international tax issue. While a nation is free to design its tax laws as it sees fit and raise revenue in accordance with the needs of its citizens, it is not possible to undertake such a task in isolation. In a world of cross-border investments and business transactions, all tax regimes impact on one another. Tax interactions between sovereign states cannot be avoided. Ultimately, the interactions mean that a nation must decide whether to engage in both collaboration and coordination with other nations and supranational bodies alike or maintain an individualised stance in relation to its tax policy. Whatever the decision, there is arguably an exercise in national sovereignty in some form. In the context of an international tax regime, whether that regime is interpreted broadly as meaning international norms generally adopted by nations around the world or domestic regimes legislating for cross-border transactions, rhetoric around national fiscal sovereignty takes on many different forms. At one end of the spectrum it is relied upon by financial secrecy jurisdictions (tax havens) as a defence to their position on the basis that ‘other’ nations cannot interfere with the fiscal sovereignty of a jurisdiction. At the other end of the spectrum, it is argued that profit shifting and international tax avoidance if not stopped is, in and of itself, a threat to a nation’s fiscal sovereignty on the basis that it threatens the ability to tax and raise the revenue needed. This paper considers a modern conceptualisation of sovereignty along with its role within international tax coordination and collaboration to argue that a move towards a more unified approach to addressing international base erosion and profit shifting may be the ultimate exercise of national fiscal sovereignty. By using the current transfer pricing regime as a case study, this paper posits that it is not merely enough to have international agreement on allocation rules to be applied, but that the ultimate exercise of national sovereignty is political agreement with other states to ensure that it is governments which determine the allocational basis of worldwide profits to be taxed. In doing so, it is demonstrated that the arm’s length pricing requirement of the current transfer pricing regime, rather than providing governments with the ability to determine the location of profits, is providing multinational entities with the ultimate power to determine that location. If left unchecked, this will eventually erode a nation’s ability to capture the required tax revenue and, as a consequence, may be deemed a failure by nation states to exercise their fiscal sovereignty.

Long-Term Economic Model for Allocation of FACTS Devices in Restructured Power System Integrated Wind Generation

This study proposes an approach to optimally allocate multiple types of flexible AC transmission system (FACTS) devices in market-based power systems with wind generation. The main objective is to maximise profit by minimising device investment cost, and the system's operating cost considering both normal conditions and possible contingencies. The proposed method accurately evaluates the long-term costs and benefits gained by FACTS devices (FDs) installation to solve a large-scale optimisation problem. The objective implies maximising social welfare as well as minimising compensations paid for generation re-scheduling and load shedding. Many technical operation constraints and uncertainties are included in problem formulation. The overall problem is solved using both particle swarm optimisations for attaining optimal FDs allocation as main problem and optimal power flow as sub-optimisation problem. The effectiveness of the proposed approach is demonstrated on modified IEEE 14-bus test system and IEEE 118-bus test system.

Impact of clinical practice guidelines on priorisation for intensive care beds allocation in high-risk acute coronary syndrome patients: does age play a role?

QUESTION UNDER STUDY: To assess which high-risk acute coronary syndrome (ACS) patient characteristics played a role in prioritising access to intensive care unit (ICU), and whether introducing clinical practice guidelines (CPG) explicitly stating ICU admission criteria altered this practice. PATIENTS AND METHODS: All consecutive patients with ACS admitted to our medical emergency centre over 3 months before and after CPG implementation were prospectively assessed. The impact of demographic and clinical characteristics (age, gender, cardiovascular risk factors, and clinical parameters upon admission) on ICU hospitalisation of high-risk patients (defined as retrosternal pain of prolonged duration with ECG changes and/or positive troponin blood level) was studied by logistic regression. RESULTS: Before and after CPG implementation, 328 and 364 patients, respectively, were assessed for suspicion of ACS. Before CPG implementation, 36 of the 81 high-risk patients (44.4%) were admitted to ICU. After CPG implementation, 35 of the 90 high-risk patients (38.9%) were admitted to ICU. Male patients were more frequently admitted to ICU before CPG implementation (OR=7.45, 95% CI 2.10-26.44), but not after (OR=0.73, 95% CI 0.20-2.66). Age played a significant role in both periods (OR=1.57, 95% CI 1.24-1.99), both young and advanced ages significantly reducing ICU admission, but to a lesser extent after CPG implementation. CONCLUSION: Prioritisation of access to ICU for high-risk ACS patients was age-dependent, but focused on the cardiovascular risk factor profile. CPG implementation explicitly stating ICU admission criteria decreased discrimination against women, but other factors are likely to play a role in bed allocation.

Budgeting and resource allocation in universities, a public choice approach

The calls urging colleges and universities to improve their productivity are coming thick and fast in Brazil. Many studies are suggesting evaluation systems and external criteria to control universities production in qualitative terms. Since universities and colleges are not profit-oriented organizations (considering just the fair and serious researching and teaching organizations, of course) the traditional microeconomics and administrative variables used to measure efficiency do not have any direct function. In this sense, It could be created a as if market control system to evaluate universities and colleges production. The budget and the allocation resources mechanism inside it can be used as an incentive instrument to improve quality and productivity. It will be the main issue of this paper.

Farmer land allocation for maize, groundnut and cotton production in Chipata District, Eastern Province, Zambia

Small-scale farmers in the Chipata District of Zambia rely on their farm fields to grow maize and groundnuts for food security. Cotton production and surplus food security crops are used to generate income to provide for their families. With increasing population pressure, available land has decreased and farmers struggle to provide the necessary food requirements and income to meet their family’s needs. The purpose of the study was to determine how a farmer can best allocate his land to produce maize, groundnuts and cotton when constrained by labor and capital resources to generate the highest potential for food security and financial gains. Data from the 2008-2009 growing season was compiled and analyzed using a linear programming model. The study determined that farmers make the most profit by allocating all additional land and resources to cotton after meeting their minimum food security requirements. The study suggests growing cotton is a beneficial practice for small-scale subsistence farmers to generate income when restricted by limited resources.

Resource allocation in multi-user telecommunication networks

This dissertation discussed resource allocation mechanisms in several network topologies including infrastructure wireless network, non-infrastructure wireless network and wire-cum-wireless network. Different networks may have different resource constrains. Based on actual technologies and implementation models, utility function, game theory and a modern control algorithm have been introduced to balance power, bandwidth and customers' satisfaction in the system. ^ In infrastructure wireless networks, utility function was used in the Third Generation (3G) cellular network and the network was trying to maximize the total utility. In this dissertation, revenue maximization was set as an objective. Compared with the previous work on utility maximization, it is more practical to implement revenue maximization by the cellular network operators. The pricing strategies were studied and the algorithms were given to find the optimal price combination of power and rate to maximize the profit without degrading the Quality of Service (QoS) performance. ^ In non-infrastructure wireless networks, power capacity is limited by the small size of the nodes. In such a network, nodes need to transmit traffic not only for themselves but also for their neighbors, so power management become the most important issue for the network overall performance. Our innovative routing algorithm based on utility function, sets up a flexible framework for different users with different concerns in the same network. This algorithm allows users to make trade offs between multiple resource parameters. Its flexibility makes it a suitable solution for the large scale non-infrastructure network. This dissertation also covers non-cooperation problems. Through combining game theory and utility function, equilibrium points could be found among rational users which can enhance the cooperation in the network. ^ Finally, a wire-cum-wireless network architecture was introduced. This network architecture can support multiple services over multiple networks with smart resource allocation methods. Although a SONET-to-WiMAX case was used for the analysis, the mathematic procedure and resource allocation scheme could be universal solutions for all infrastructure, non-infrastructure and combined networks. ^

Optimal allocation of a cross-connection and sectionalizers in distribution systems

In this paper, the placement of sectionalizers, as well as, a cross-connection is optimally determined so that the objective function is minimized. The objective function employed in this paper consists of two main parts, the switch cost and the reliability cost. The switch cost is composed of the cost of sectionalizers and cross-connection and the reliability cost is assumed to be proportional to a reliability index, SAIDI. To optimize the allocation of sectionalizers and cross-connection problem realistically, the cost related to each element is considered as discrete. In consequence of binary variables for the availability of sectionalizers, the problem is extremely discrete. Therefore, the probability of local minimum risk is high and a heuristic-based optimization method is needed. A Discrete Particle Swarm Optimization (DPSO) is employed in this paper to deal with this discrete problem. Finally, a testing distribution system is used to validate the proposed method.

Optimal allocation and sizing of capacitors to minimize the transmission line loss and to improve the voltage profile

To allocate and size capacitors in a distribution system, an optimization algorithm, called Discrete Particle Swarm Optimization (DPSO), is employed in this paper. The objective is to minimize the transmission line loss cost plus capacitors cost. During the optimization procedure, the bus voltage, the feeder current and the reactive power flowing back to the source side should be maintained within standard levels. To validate the proposed method, the semi-urban distribution system that is connected to bus 2 of the Roy Billinton Test System (RBTS) is used. This 37-bus distribution system has 22 loads being located in the secondary side of a distribution substation (33/11 kV). Reducing the transmission line loss in a standard system, in which the transmission line loss consists of only about 6.6 percent of total power, the capabilities of the proposed technique are seen to be validated.