scholarly journals Group subsidiaries, tax minimization and offshore financial centres: Mapping organizational structures to establish the ‘in-betweener’ advantage

Author(s):  
Richard Phillips ◽  
Hannah Petersen ◽  
Ronen Palan

Abstract International business and public policy research have examined the techniques that multinational enterprises (MNEs) use to shift revenues to subsidiaries in offshore financial centres (OFCs) in order to minimize tax liability and arbitrage for their advantage. While study of such tax arbitrage strategies has looked to geographical locations and legal dimensions to better understand these strategies, it has ignored the structural and organizational relationship between MNEs and their subsidiaries. We define two distinct types of OFC-based corporate entities based on their location among and apparent control over other MNE affiliates: ‘stand-alone’ OFCs at the end of a chain of MNE subsidiaries; and ‘in-betweener’ OFCs with equity control over further entities and hence apparent flexibility to redirect profits to other MNE subsidiaries further down the chain. We hypothesize that when MNEs have in-betweener OFCs controlling a substantial share of overall MNE profits, this indicates greater MNE interest in aggressive tax planning (ATP). We then evaluate empirical support for our claims based on an ‘equity mapping’ approach identifying stand-alone and in-betweener OFCs in 100 of the largest MNEs operating globally. This study demonstrates that a key factor determining tax arbitrage is not the amount of value registered on OFC subsidiaries’ balance sheets, but rather the portion of the group’s operating revenues and net income controlled by OFC subsidiaries. National taxing authorities could benefit from tracking in-betweener OFC locations and behaviour to counter ATP strategies, decrease sovereign arbitrage, and increase MNE tax revenue.

2020 ◽  
Vol 14 (4) ◽  
pp. 871-894
Author(s):  
Yishuai Yin

Purpose This paper aims to explore how institutional factors determine the adoption of employee empowerment practices by multinational enterprises (MNEs) subsidiaries in China. Design/methodology/approach This paper examines the effects of MNE subsidiaries’ external and internal institutional factors on the degree of employee empowerment practices adopted by these subsidiaries. Using hierarchical regression analysis, hypotheses were tested with a sample of 99 MNE subsidiaries operating in China. Findings The results show that both the informal institutions of the host country and the subsidiary’s characteristics play an important role in shaping the degree of empowerment practices adopted by MNE subsidiaries in China. Originality/value Employee empowerment practices have been increasingly used by MNEs to leverage human resources for organizational competitive advantage. Although a large body of work has studied a bundle of HRM practices as a whole adopted in MNE subsidiaries, there is a paucity of research on the specific empowerment practices in MNE subsidiaries. This research fills this important gap in the literature by investigating the institutional forces that influence the empowerment practices in MNE subsidiaries in China.


2018 ◽  
Vol 29 (78) ◽  
pp. 355-374
Author(s):  
Wellington Rodrigues Silva Souza ◽  
Marcos Peters ◽  
Aldy Fernandes da Silva ◽  
Maria Thereza Pompa Antunes

Abstract The purpose of this study was to empirically verify the existence or not of a distortion in the comparability of information when inflationary effects are omitted from financial statements. Although inflation has been under control in Brazil since the Plano Real, with indices well below those recorded in the 1980s and 1990s, discussing the need for accounting recognition of the effects of inflation remains an extremely relevant and pertinent issue in light of the proposal of accounting to produce faithful information that closely reflects the economic reality in which organizations operate. The results of the research show that financial accounting has been directly affected by the omission of inflationary effects in financial statements, drawing attention to the negative effects this has caused on the quality of the information produced. In order to operationalize the research, the Balance Sheet Monetary Correction (BSMC) was applied to the balance sheets of Brazilian companies from the siderurgical and metallurgical sector listed on the BM&FBOVESPA in the period from 1996 to 2016. Based on the variables net income, return on equity (ROE), and return on assets (ROA), and two conceptual axes of comparability (between entities and between periods), the statistical parameters were developed and the hypotheses were defined, which were tested using the Student t parametric test. This article shows the damage caused to the decision-making process of the external users for whom financial statements are intended when these are prepared neglecting the effects of inflation. This is verifiable through the analyses of the results obtained, including the observation of significant distortions between the means of the corrected indicators and the means of the historical indicators, such as in the case of net income in 2001, 2002, 2012, 2013, 2014, and 2016 (33.98%, 91.92%, -65.54%, -30.01%, -53.59%, and 26.30% variation, respectively), of ROE (-67.16%, -61.43%, -53.06%, -63.46%, -133.81%, and 65.00% variations in 2008, 2009, 2010, 2011, 2014, and 2015, respectively), and of ROA (-26,70%, -41.14%, -33,34%, -43,49%, 98,83%, and -413,68% in 2005, 2009, 2010, 2011, 2012, and 2014, respectively).


2019 ◽  
Vol 50 (4) ◽  
pp. 672-697 ◽  
Author(s):  
Daniel G Colombo ◽  
Jorge Martinez-Vazquez

Abstract This article presents a first analysis of the potential link between the level of fiscal decentralization of a country and its public investment in innovation. We present a theoretical model where a “benevolent government” invests in research and development (R&D) aiming at maximizing net income, and R&D results are subject to interregional knowledge spillovers. The model predicts that decentralization leads to a lower level of public spending on innovation, and to a lower share of basic research in the government R&D budget. These hypotheses are empirically tested using country aggregate data. The results provide empirical support to the mentioned hypotheses, as we find evidence that higher levels of both expenditure and revenue decentralization are associated with a lower intensity of basic research in public R&D and with a lower level of R&D spending. The strength of the evidence, however, is weakened by the small sample size and shortcomings of the indicators used in the analysis.


2003 ◽  
Vol 31 (2) ◽  
pp. 533-546
Author(s):  
Stepan Davtian ◽  
Tatyana Chernigovskaya

Diagnostics of a mental disorder completely bases on an estimation of patient’s behaviour, verbal behaviour being the most important. The behaviour, in turn, is ruled by a situation expressed as a system of signs. Perception of a situation could be seen as a function, which depends on the context resulting from the previous situations, structuring personal world. So the world is not given — it is being formed while the person is in action. We argue that distinctive features of behaviour, including its abnormal variants, can be explained not in categories of characters and diseases but in terms of situations taking place in individual worlds. The situation in which a person perceives himself is not simply a site in a three-dimensional space at a certain moment, but a part of the world and an episode of his life. Like a text composed of words, individual world is composed of situations. Each of them needs certain context to cope with ambiguity. This context is induced by the world as a whole. And the world, in turn, is presented as a chain of situations. If the context cannot help to interpret a situation adequately, uncertainty can be eliminated by actions clarifying a situation, which is changed in a predictable way. Thus, purposeful activity, skills to make predictions and corrections of one’s own actions are crucial. Weakness of any of them inevitably leads to the distortion of the presentation of the world, to wrong evaluation of situations and, as a result, to inadequate actions that finally reduce the activity as being ineffective. Thus, the lack of activity becomes the key factor in the development of disorder, being simultaneously its cause and effect. In periods of insufficient activity conditions for violated (and violating) sign processing arise. Possible variants of sign malfunction are: oligosemia (reduction of the number of perceivable signs), hyposemia (decrease of significance of signs), hypersemia (increase of significance of some signs at the expense of others), ambisemia (uncertainty of sign, when situation remains unclear), cryptosemia (recognition of signs not obvious for other observers), and parasemia (perverted interpretation of signs influenced by a false context).


Author(s):  
Victor Araújo ◽  
Malu A.C. Gatto

Abstract Access to information about candidates' performance has long stood as a key factor shaping voter behaviour, but establishing how it impacts behaviour in real-world settings has remained challenging. In the 2018 Brazilian presidential elections, unpredictable technical glitches caused by the implementation of biometrics as a form of identification led some voters to cast ballots after official tallies started being announced. In addition to providing a source of exogenous variation of information exposure, run-off elections also enable us to distinguish between different mechanisms underlying the impact of information exposure. We find strong support for a vote-switching bandwagon effect: information exposure motivates voters to abandon losing candidates and switch support for the frontrunner – a finding that stands in the second round, when only two candidates compete against each other. These findings provide theoretical nuance and stronger empirical support for the mechanisms underpinning the impact of information exposure on voter behaviour.


2018 ◽  
Vol 15 (2) ◽  
pp. 303-326 ◽  
Author(s):  
DANIEL J. D'AMICO ◽  
CLAUDIA WILLIAMSON

AbstractWe develop a framework for understanding how legal structures relate to imprisonment. We hypothesize that relatively more hierarchy within criminal justice institutions, compared to commercial law, fosters higher rates of incarceration. Our framework predicts that incarceration reflects asymmetric opportunities for rent seeking across differently organized legal institutions. Instead of comparing criminal justice institutions across nations in absolute terms, we investigate the relative degrees of institutional centralization across legal spheres. To provide support, we document the separate historical experiences that shaped divergent organizations across England and France. Within each country, criminal legal institutions developed inverse organizational traits from commercial legal processes. As a result, the contrasting organizations created asymmetric opportunities for rent seeking. Divergent contemporary outcomes can be understood by recognizing these initial organizational choices, the relative opportunities they created, and their subsequent path dependencies. We document contemporary England, France, and the United States’ incarceration trends and penal outcomes to provide empirical support.


Healthcare ◽  
2019 ◽  
Vol 7 (2) ◽  
pp. 59
Author(s):  
Martyne Horton-Jones ◽  
Emma Marsh ◽  
Sian Fumarola ◽  
Helen Wright-White ◽  
Wilfred McSherry ◽  
...  

Background: Between October 2017 and March 2018, the Trust experienced significant winter pressures and an increase in category 2 and 3 hospital-acquired avoidable pressure ulcers. This review aimed to investigate the causal factors of this increase. Methods: A ‘Deep Dive’ review of 37 cases was undertaken in three stages: (i) assurance; ensure the increase was not due to insufficient equipment; (ii) collation of relevant data, including age, length of time in A&E, bed surface, number of internal moves; (iii) analysis identifying factors that might account for the observed increase. Findings: Age combined with prolonged length of time in A&E, being nursed on a trolley followed by three or four internal moves were observed in patients who developed pressure ulcers. Patient age was observed as a key factor, with those over 80 years experiencing pressure ulcers more frequently. Conclusion: The small size of this data suggests a need for the greater awareness of frailty issues in older people, timely assessment and intervention to prevent a chain of detrimental factors might be key to reduce and prevent hospital-acquired avoidable pressure ulcers. Recommendations for immediate action, education and future research have been made to the Trust Quality and Safety Committee.


Author(s):  
Mats Alvesson

As we have seen, an excessive interest in change—or at least the initiation of more or less well-considered projects—is closely linked to a high degree of sensitivity for what people think others are doing. As there are frequent mass media reports about the strong need for change and organizations are often engaged in various change activities, it is vital to keep up—both with the general norm and with the signalled moves of others. The risk of deviating and, in particular, falling behind is a major motive force. A key factor here is the surface—what seems to be visible from a distance and without much deeper knowledge—in an organizational and management context. This chapter focuses on the links between these aspects, in which imitations and fashions have a particularly high impact at the shop-window level (i.e., the illusion level), and where an increasing emphasis on the shop-window factor encourages imitations and fashion-following behaviour. This chapter then takes the phenomenon of imitation seriously. But even if the desire to keep up with norms and fashions and the fear of lagging behind other organizations—in general or in one’s sector—play a role, how significant is it? It may only have a moderate impact, compared with efficiency concerns, for example. And surely responsible executives, politicians, and other policymakers are strong, independent, reasonably thoughtful, and rational actors, who generally have good reasons for their decisions and the organizational structures they are responsible for? Or is the almost caricature-like view of organizations as almost slavishly following fashions ‘true’? No precise answers are possible, but research and insightful observations by respected commentators may give important material for informed reasoning. In this chapter, I start with the phenomenon of imitation and convergence between organizations by exploring the impact of adapting new formal structures in organizations within a certain sector. There are reasons to believe that imitation of ‘leaders’ and following fashion are far from insignificant. Then this is related to the issue of the ‘depth’ of such imitation tendencies, where the window-dressing aspects are emphasized.


2016 ◽  
Vol 19 (04) ◽  
pp. 1650021 ◽  
Author(s):  
Denis Davydov ◽  
Steve Swidler

Benford’s Law, a rule concerning first digits of an array of numbers, has frequently been used to test for the reporting quality of financial statements. When applied to the recent experience for Russian banks, one conclusion is that the 2004 regime shift in accounting standards produced higher quality financial statements. Prior to 2004, the Benford evidence suggests that Russian banks tended to round revenues up, expenses down and thus overstate net income. It also appears that banks may have presented stronger balance sheets than warranted. In the second part of the analysis, the practical use of Benford’s Law to discern a looming bank failure appears limited. While there is, perhaps, some beneficial information to be drawn from testing for Benford distribution conformity, in isolation the tests for financial statement manipulation are inconclusive. Instead, Benford might be used with other early warning detection algorithms to recognize impending bank failures.


Author(s):  
Fawzy Soliman

Many innovative companies pass through a number of transformation stages. The transformation is considered a chain of activities that begins with information that leads to knowledge, then into learning before it can finally be used for innovation. The chapter shows that transformational leadership is a key factor for moving the organisation from being information-based into knowledge-based and then into a learning organisation and an innovative company. The six important characteristics of the transformational leaders for the transformation are shown to be courage to switch off or terminate projects, rewarding performing staff, ability to appropriately time release of products to the market, ability to release products to the market within budget, and ability to inspire and be a role model for other staff. The chapter also shows that there are fourteen transformational leadership attributes that may be considered less critical than the above-mentioned six characteristics. Those non-critical characteristics include: degree of passion for the job, attracting talent, ability to build teams, coaching subordinates, communicating at all levels, driving projects successfully, enabling project-supporting environments, advising others managers, advocating for improvement, encouraging self-goal setting, ability of self rehearsal, ability of self reinforcement, ability of self-observation, and ability of self-expectation.


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