scholarly journals Dilemmas of Transfer Pricing Comparability Analysis in Manufacturing Entities. Polish-Czech Case Study

2018 ◽  
Vol 26 (2) ◽  
pp. 76-82
Author(s):  
Aleksandra Sulik-Górecka
Keyword(s):  
Conflicts Of Interest ◽  
Transfer Pricing ◽  
Legal Regulation ◽  
Point Of View ◽  
Case Study Analysis ◽  
Arm’S Length Principle ◽  
Analysis Of Results ◽  
Functional Profiles ◽  
Selection Of

Abstract Modern manufacturing entities often operate in capital groups, and their role is sometimes limited to the function of cost centers. From the legal point of view, however, they are separate entities obliged to apply transfer pricing regulations. Meeting the requirements of the arm's length principle can be very difficult at this time, given the relationships and conflicts of interest in the capital group. Complexity increases in capital groups operating in different countries, due to differences in tax regulations. The main purpose of the paper is to demonstrate that the need to valuate the sale of finished goods to a manufacturing entity, which is a subject to a different tax jurisdiction, may lead to a problem of compliance with the arm's length principle. In addition, the paper proposes a methodology for comparability analysis that may be used by manufacturing entities to defend conditions of setting transfer pricing. The paper presents the different functional profiles of manufacturing entities and points out the difficulties that they may encounter when preparing the comparability analysis. It has also been noted that there are differences in transfer pricing regulations in different countries, for example by analyzing Polish and Czech regulations. The lack of uniform benchmarking legislation can cause inconsistencies in the selection of comparable data, resulting in differences in transfer pricing. The paper uses the method of legal regulation review and analysis of results of published studies concerning the scope of transfer pricing and comparability analysis. The paper also adopts a case study analysis.

scholarly journals Collecting Microplastics in Gardens: Case Study (i) of Soil

2021 ◽  
Vol 9 ◽  
Author(s):  
Zahra Sobhani ◽  
Yunlong Luo ◽  
Christopher T. Gibson ◽  
Youhong Tang ◽  
Ravi Naidu ◽  
...  
Keyword(s):  
Signal To Noise Ratio ◽  
Point Of View ◽  
Signal To Noise ◽  
Statistical Point ◽  
Image Mapping ◽  
Noise Ratio ◽  
In The Beginning ◽  
Raman Image ◽  
Selection Of

As an emerging contaminant, microplastic is receiving increasing attention. However, the contamination source is not fully known, and new sources are still being identified. Herewith, we report that microplastics can be found in our gardens, either due to the wrongdoing of leaving plastic bubble wraps to be mixed with mulches or due to the use of plastic landscape fabrics in the mulch bed. In the beginning, they were of large sizes, such as > 5 mm. However, after 7 years in the garden, owing to natural degradation, weathering, or abrasion, microplastics are released. We categorize the plastic fragments into different groups, 5 mm–0.75 mm, 0.75 mm–100 μm, and 100–0.8 μm, using filters such as kitchenware, meaning we can collect microplastics in our gardens by ourselves. We then characterized the plastics using Raman image mapping and a logic-based algorithm to increase the signal-to-noise ratio and the image certainty. This is because the signal-to-noise ratio from a single Raman spectrum, or even from an individual peak, is significantly less than that from a spectrum matrix of Raman mapping (such as 1 vs. 50 × 50) that contains 2,500 spectra, from the statistical point of view. From the 10 g soil we sampled, we could detect the microplastics, including large (5 mm–100 μm) fragments and small (<100 μm) ones, suggesting the degradation fate of plastics in the gardens. Overall, these results warn us that we must be careful when we do gardening, including selection of plastic items for gardens.

Challenges of Monitoring Tax Compliance by Multinational Firms: Evidence from Chile

2019 ◽  
Vol 109 ◽  
pp. 500-505
Author(s):  
Sebastián Bustos ◽  
Dina Pomeranz ◽  
José Vila-Belda ◽  
Gabriel Zucman
Keyword(s):  
Multinational Firms ◽  
Transfer Pricing ◽  
Tax Avoidance ◽  
Tax Compliance ◽  
Tax Rates ◽  
Profit Shifting ◽  
Effective Tax Rates ◽  
Arm’S Length Principle ◽  
Debt Shifting

This paper reviews common challenges of taxing multinational firms, using Chile as a case study. We briefly describe key international tax avoidance methods: profit shifting to low-tax jurisdictions through transfer pricing and debt shifting. We discuss the prevalent policy to tax multinationals--the arm's length principle--and alternative proposals using apportionment formulas. Novel data from Chile show that multinationals make up a large share of GDP but report lower profit and effective tax rates than local firms. In 2011, Chile implemented a reform following OECD guidelines to enforce the arm's length principle. We discuss potential effects on tax collection and welfare.

scholarly journals Life Cycle Assessment of LNG Fueled Vessel in Domestic Services

2019 ◽  
Vol 7 (10) ◽  
pp. 359 ◽  
Author(s):  
Hwang ◽  
Jeong ◽  
Jung ◽  
Kim ◽  
Zhou
Keyword(s):  
Life Cycle Assessment ◽  
Life Cycle ◽  
Environmental Impact ◽  
South Korea ◽  
Point Of View ◽  
Marine Fuel ◽  
Pm 2.5 ◽  
Fuel Supply ◽  
Selection Of

This research was focused on a comparative analysis of using LNG as a marine fuel with a conventional marine gas oil (MGO) from an environmental point of view. A case study was performed using a 50K bulk carrier engaged in domestic services in South Korea. Considering the energy exporting market for South Korea, the fuel supply chain was designed with the two largest suppliers: Middle East (LNG-Qatar/MGO-Saudi Arabia) and U.S. The life cycle of each fuel type was categorized into three stages: Well-to-Tank (WtT), Tank-to-Wake (TtW), and Well-to-Wake (WtW). With the process modelling, the environmental impact of each stage was analyzed based on the five environmental impact categorizes: Global Warming Potential (GWP), Acidification Potential (AP), Photochemical Potential (POCP), Eutrophication Potential (EP) and Particulate Matter (PM). Analysis results reveal that emission levels for the LNG cases are significantly lower than the MGO cases in all potential impact categories. Particularly, Case 1 (LNG import to Korea from Qatar) is identified as the best option as producing the lowest emission levels per 1.0 × 107 MJ of fuel consumption: 977 tonnages of CO2 equivalent (for GWP), 1.76 tonnages of SO2 equivalent (for AP), 1.18 tonnages of N equivalent (for EP), 4.28 tonnages of NMVOC equivalent (for POCP) and 26 kg of PM 2.5 equivalent (for PM). On the other hand, the results also point out that the selection of the fuel supply routes could be an important factor contributing to emission levels since longer distances for freight transportation result in more emissions. It is worth noting that the life cycle assessment can offer us better understanding of holistic emission levels contributed by marine fuels from the cradle to the grave, which are highly believed to remedy the shortcomings of current marine emission indicators.

DETERMINANTS OF DIFFERENTIATION FOR SELECTED COUNTY LABOUR MARKETS IN PODLASKIE VOIVODSHIP – THE APPLICATION OF THE SCENARIO METHOD

2018 ◽  
Vol 6 ◽  
pp. 271-282
Author(s):  
Anna Kononiuk ◽  
Alicja Ewa Gudanowska
Keyword(s):  
Qualitative Method ◽  
Labour Markets ◽  
Study Analysis ◽  
Market Institutions ◽  
Factors Affecting ◽  
Case Study Analysis ◽  
Expert Team ◽  
Scenario Method ◽  
Selection Of

The main aim of the paper is to present the possibilities of scenario method use for the identification of the factors determining a different situation in selected county labour markets in Podlaskie Voivodship, Poland. The novelty posited by the authors of the paper consisted in the application of the qualitative method based on the intuitive logic school of scenario construction for the county labour markets analysis. The following pairs of poviats were subjected to the case study: Hajnowski and Bielski, Grajewski and Wysokomazowiecki, Suwalski and Sejneński. The selection of the experts of the presented case study followed the rules of researcher triangulation. The expert team consisted of representatives of labour market institutions, local government units and enterprises, which allowed for a multifaceted view on the analysed issues. The scenario method was preceded by the STEEPVL analysis. The main problem issue undertaken during the case study analysis was the identification of factors affecting the development of selected poviats and the assessment of these factors in terms of validity and uncertainty. The STEEPVL analysis and the scenario method were implemented for poviats, which in pairs of poviats occupy lower positions in the ranking of poviats in the region. The research methods applied by the authors of the paper were literature review, a case study, STEEPVL analysis and the scenario method.

scholarly journals The Problem of Alternative Financing Source Management – The Equity Crowdfunding Case

e-Finanse ◽  
2019 ◽  
Vol 15 (4) ◽  
pp. 12-24
Author(s):  
Anna Motylska-Kuźma
Keyword(s):  
Comparative Analysis ◽  
Point Of View ◽  
Study Analysis ◽  
Legal Requirements ◽  
Good Communication ◽  
Case Study Analysis ◽  
Equity Crowdfunding ◽  
Alternative Sources ◽  
Source Management

AbstractThe main objective of this paper is to analyze one of the alternative sources of financing - equity crowdfunding - from the point of view of managerial processes. Based on the case study analysis and the comparative analysis the problems and challenges of raising funds using equity crowdfunding are discussed, comparing the findings with the issuing of shares. The analysis show that although many of the activities undertaken in raising funds through issuing shares and equity crowdfunding are similar, the managerial processes in the case of equity crowdfunding require from the company first of all building and caring about relationships with investors, rather than showing and proving effectiveness. In exchange for the low legal requirements, the equity crowdfunding investors expect good communication even if the promises are not fulfilled.

scholarly journals Adoption of Integrated Reporting: Reasons and Benefits—A Case Study Analysis

2018 ◽  
Vol 13 (12) ◽  
pp. 244 ◽  
Author(s):  
Filippo Vitolla ◽  
Nicola Raimo
Keyword(s):  
Positive Impact ◽  
Point Of View ◽  
Integrated Reporting ◽  
Case Study Analysis ◽  
Corporate Reporting ◽  
External Point ◽  
Potential Benefits ◽  
Reporting Tool ◽  
Limited Diffusion

Integrated reporting is the new corporate reporting tool that includes financial and non-financial information in a single document. Although some studies describe the potential benefits of integrated reporting, this practice is still not widespread. One of the reasons for the limited diffusion is linked to the absence of empirical evidence that demonstrates the actual concreteness of these benefits for organizations that decide to adopt integrated reporting. This study analyses the process of adopting integrated reporting and the benefits associated with it through a case study. In particular, the case of Generali Group is analysed in the aim of highlighting the adoption path and the effects deriving from the implementation of integrated reporting in a context like the Italian one, still not very attentive to these issues. The findings show how the implementation of integrated reporting has been the result of a clear desire of top management and that the adoption of this practice has had a decidedly positive impact both from an internal and external point of view.

scholarly journals The Optimal Location of Ground-Based GNSS Augmentation Transceivers

Geosciences ◽  
2019 ◽  
Vol 9 (3) ◽  
pp. 107 ◽  
Author(s):  
Jacek Rapinski ◽  
Artur Janowski
Keyword(s):  
Wide Band ◽  
Optimal Location ◽  
Point Of View ◽  
Global Navigation Satellite Systems ◽  
Design Stage ◽  
Shift Measurement ◽  
Satellite Systems ◽  
Global Navigation Satellite ◽  
Selection Of

Modern Global Navigation Satellite Systems (GNSS) allow for positioning with accuracies ranging from tens of meters to single millimeters depending on user requirements and available equipment. A major disadvantage of these systems is their unavailability or limited availability when the sky is obstructed. One solution is to use additional range measurements from ground-based nodes located in the vicinity of the receiver. The highest accuracy of distance measurement can be achieved using ultra wide band (UWB) or ZigBee phase shift measurement. The position of the additional transmitter must be carefully selected in order to obtain the optimal improvement in the dilution of precision (DOP), which reflects the improvement in the geometry of solution. The presented case study depicts a method for selecting the optimal location of a ground-based ranging source. It is based on a search of a minimum DOP value as a transmitter location function. The parameters of objective function are the elevation and azimuth of the transceiver. The solution was based on a limited-memory Broyden–Fletcher–Goldfarb–Shanno with Box constraints (L-BFGS-B) method and a numerical optimization algorithm for parameter value estimation. The presented approach allows for the selection of the optimal location of a ground-based source of ranging signals in GNSS processing from a geometry of solution point of view. This can be useful at the design stage of an augmentation network of ground-based transceivers. This article presents a theoretical basis and a case study presenting the selection of the optimal location of a ground-based ranging source.

Place of transfer pricing in the tax system

2021 ◽  
Author(s):  
Artem Kotenko ◽  
Mykola Mishyn
Keyword(s):  
System Analysis ◽  
Transfer Pricing ◽  
Legal Regulation ◽  
Main Body ◽  
Tax System ◽  
Local Taxes ◽  
Arm’S Length Principle ◽  
Definition Of ◽  
Problem Setting ◽  
Broad Approach

Problem setting. The approach proposed by the legislator to the definition of the tax system as a set of national and local taxes and fees in the procedure established by the TC of Ukraine, constitutes the tax system of Ukraine (para. 6.3 of Article 6 of the TC of Ukraine), raises the question of the place of transfer pricing in the tax system. If you approach the tax system as a set of taxes and fees, the transfer pricing is actually excluded from the tax system. Analysis of recent researches and publications. Among the scientists involved in the research of the tax system, it is possible to distinguish M. Kucheryavenko, D. Getmantsev, N. Pryshva, O. Barin and others. Some problems of legal regulation of transfer pricing were dealt with by M. Mishin, M. Bondarenko, K. Broyakov and others. The target of the research is to analyze and determine the place of transfer pricing in the tax system. Article’s main body. The article is devoted to determining the place of transfer pricing in the tax system. We propose our own view on the tax system. It is stated that a broad approach to understanding the tax system excludes contradictions laid down in para. 6.3 of Article 6 of the TC of Ukraine. Conclusions and prospects for the development. Transfer pricing involves the application of special methods for determining the compliance of the conditions of the controlled transaction with a certain criterion – the “arm’s length” principle, drawing up and submitting reports, exercising control and bringing to responsibility for violation of transfer pricing requirements. The legislative approach to the content of the tax system as an aggregate of taxes and fees actually excludes transfer pricing from the tax system. Instead, our proposed broad approach eliminates such contradiction.

scholarly journals Towards a Smart and Sustainable City with the Involvement of Public Participation—The Case of Wroclaw

2019 ◽  
Vol 11 (2) ◽  
pp. 332 ◽  
Author(s):  
Dorota Bednarska-Olejniczak ◽  
Jarosław Olejniczak ◽  
Libuše Svobodová
Keyword(s):  
Sustainable Development ◽  
Public Participation ◽  
Smart City ◽  
Full Range ◽  
Point Of View ◽  
City Development ◽  
Sustainable City ◽  
Case Study Analysis ◽  
Unexplored Area

The purpose of this article is to identify the directions and scope of inclusion of the residents’ participation into the concept of city’s sustainable development and the smart city concept, taking into account national and international conditions, on the basis of Wroclaw’s practices in 1998–2018. Many researchers have emphasized the necessity of including residents’ participation in both the smart city concept and the sustainable city development concept, but they do not focus on a coherent linking of these activities during evolution toward a sustainable smart city (SSC). The in-depth case study analysis considered, i.e., three subsequent Wroclaw development strategies (1998–2018) and implementation of the smart city concept in Wroclaw (2015–2018) with particular emphasis on the issue of public participation and sustainable development of the city. The results of study show that in the case of the developments in the activities of smart city and sustainable city development carried out by Wroclaw, it is possible to identify two different approaches to residents’ participation in city activities. In Wroclaw, ‘residents’ participation’ in the framework of the sustainable city development activities currently covers all theoretical levels of participation, while within the smart city activities it focuses mainly on the participatory budget and the limited use of ICT. The conducted research indicates that for the implementation of the SSC concept it would be important to integrate these approaches in order to ensure the full range of residents’ participation in accordance with theoretical postulates. The conducted analysis therefore covers mostly unexplored area of research, which is important from the point of view of a city’s evolution toward becoming a sustainable smart city. The conclusions from the research are also an empirical contribution to the analysis of the changes of cities towards SSC and indicate the need for further, extended research on the undertaken problem.

Sign in / Sign up

Export Citation Format

Share Document