Profit repatriation of a Polish subsidiary from tax planning point of view of an international corporation

The main purpose of this study was to examine and compare the possibilities of profit repatriation from the point of view of tax planning of an international corporation, in such a case that a Finnish parent company has a subsidiary in Poland. The main research problem was divided into two sub research problems: 1) to examine concepts and principles of international taxation and tax planning from the point of view of international corporations and 2) to discuss the main features of Polish Companies-, Accounting- and Tax Act from the point of view a Finnish parent company. The research method of this study is mainly decision making, comparative analysis. In this study have been discussed the possibilities of international profit repatriation for supporting the decision making of the management of a Finnish parent company. In addition different repatriation possibilities have been compared. In this study has been noticed that a Finnish parent company can repatriate profit of its Polish subsidiary either directly as dividends or by using indirect methods such as interests, royalties, management fees and transfer pricing of goods. The total tax burden of dividends is heavier than the tax burden of indirect methods. It was also concluded that during the last years the Polish legislation has been renewed in order to prevent hidden dividend distribution. This has been done by implementing new rules of transfer pricing and thin capitalization.

The adjustment from Russia to Finland for corporate repatriates: How the repatriation experience influences readjustment in the workplace

To manage foreign operations, companies must often send their employees on international assignments. Repatriating these expatriates can be difficult because they have been forgotten during their posting, and their new experiences are not utilised. In addition to the possible difficulties in organisational repatriation, the returnee can suffer from readjustment problems after a lengthy stay abroad has changed their habits and even identity. This thesis examines the repatriation experience of Finnish assignees returning from Russia. The purpose of the study is to understand how the repatriation experience influences their readjustment to work in Finland. This experience is influenced by many factors including personal and situational changes, the repatriation process, job and organisational factors, and individual’s motives. The theoretical background of the study is founded on two models of repatriation adjustment. A refined, holistic theoretical framework for the study is created. It describes the formation of the repatriation experience and its importance for readjustment to work and retention. The qualitative research approach is suitable for the thesis which examines the returnees’ personal experiences and feelings: a qualitative case study aims to explain the phenomenon in-depth and comprehensively. The data was collected in summer 2013 through semi-standardised interviews with eight Finnish repatriates. They had returned from Russia within the last two years. The data was analysed by structuring the interview transcripts using template analysis. The results supported earlier literature and suggest that the re-entry remains a challenging phase for both the individual and the company. For some, adjusting to a new job was difficult for various reasons. The repatriates underwent personal change and development and felt it was for the better. Many repatriates criticised the company’s repatriation process upon return. Finding a suitable return job was not clear. Instead, the returnees had to be active in finding a new position. Many assignees had only modest career-related motives regarding the assignment and they had realistic expectations about the return. Therefore they were not extremely surprised or dissatisfied when they were not actively offered positions or support by the company. The significance of motives stood out even more than the theory predicted. As predicted, they are linked to the expectations of employees. Moreover, if the employees are motivated to remain in the company, they can tolerate partly a negative repatriation experience. Despite the complexity of the return and readjustment, the assignment as a whole was seen as a rewarding experience by all participants.

The repatriation of 1973 and the re-making of modern south Asia

In the aftermath of the 1971 war, nearly 250,000 people found themselves stranded in various parts of the subcontinent. These 'trapped minorities' became hostages in a complex negotiation process that highlighted how questions of citizenship and belonging remained unresolved in post-Partition South Asia. By studying three groups - the non-Bengalis, the Bengalis and the prisoners of war in a comparative perspective, this paper re-visits the question of who was welcome within certain borders and on what terms. It argues that these decisions depended not just on the state's policies towards 'outsiders' but also upon its own relationship with its minority communities.

British Balance of Competence Reviews, Part III: More reform than renegotiation or repatriation. EPIN [Working] Paper No. 42/December 2014. [see Abstract for I and II]

This paper, the third in a series for a CEPS project on the ‘The British Question’, is pegged on an ambitious exercise by the British government to review all the competences of the European Union on the basis of evidence submitted by independent stakeholders. The reviews considered in this paper cover the following EU policies: the single market for services, financial markets, the free movement of people, cohesion, energy, agriculture, fisheries, competition, social and employment policies, and fundamental rights. The declared objective of Prime Minister Cameron is to secure a ‘new settlement’ between the UK and the EU. From political speeches in the UK one can identify three different types of possible demand: reform of EU policies, renegotiation of the UK’s specific terms of membership, and repatriation of competences from the EU back to the member states. As most of the reviews are now complete, three points are becoming increasingly clear: i) The reform agenda – past, present or future - concerns virtually every branch of EU policy, including several cases reviewed here that are central to stated UK economic interests. The argument that the EU is ‘unreformable’ is shown to be a myth. ii) The highly sensitive cases of immigration from the EU and social policies may translate into requests for renegotiation of specific conditions for the UK, but further large-scale opt-outs, as in the case of the euro and justice and home affairs, are implausible. iii) While demands for repatriation of EU competences are voiced in general terms in public debate in the UK, no specific proposals emerge from the evidence as regards competences at the level at which they are identified in the treaties, and there is no chance of achieving consensus for such ideas among member states. Michael Emerson and Steven Blockmans, “British Balance of Competence Reviews, Part I: ‘Competences about right, so far’”, CEPS/EPIN Working Paper No. 35, October 2013 (www.ceps.eu/book/british-balance-competence-reviews-part-i-%E2%80%98competences-about-right-so-far%E2%80%99)(http://aei.pitt.edu/45599/); Michael Emerson, Steven Blockmans, Steve Peers and Michael Wriglesworth, “British Balance of Competence Reviews, Part II: Again, a huge contradiction between the evidence and Eurosceptic populism”, CEPS/EPIN Working Paper No. 40, June 2014 (www.ceps.eu/book/british-balance-competence-reviews-part-ii-again-huge-contradiction-between-evidence-and-eurosc)(http://aei.pitt.edu/52452/).

The programme of repatriation /

Mode of access: Internet.

Plan for repatriation of the dead of World War II and establishment of permanent United States military cemeteries at home and abroad

Cover title

Matching prescription claims with medication data for nursing home residents: Implications for prescriber feedback, drug utilisation studies and selection of prescription claims database

Medication data retrieved from Australian Repatriation Pharmaceutical Benefits Scheme (RPBS) claims for 44 veterans residing in nursing homes and Pharmaceutical Benefits Scheme (PBS) claims for 898 nursing home residents were compared with medication data from nursing home records to determine the optimal time interval for retrieving claims data and its validity. Optimal matching was achieved using 12 weeks of RPBS claims data, with 60% of medications in the RPBS claims located in nursing home administration records, and 78% of medications administered to nursing home residents identified in RPBS claims. In comparison, 48% of medications administered to nursing home residents could be found in 12 weeks of PBS data, and 56% of medications present in PBS claims could be matched with nursing home administration records. RPBS claims data was superior to PBS, due to the larger number of scheduled items available to veterans and the veteran's file number, which acts as a unique identifier. These findings should be taken into account when using prescription claims data for medication histories, prescriber feedback, drug utilisation, intervention or epidemiological studies. (C) 2001 Elsevier Science Inc. All rights reserved.