INTERNATIONAL BUSINESS IN UKRAINE: TAX COMPONENT

In the system of regulation of international business, the tax component is of exceptional importance. The development of business is largely dependent on tax policy tools, the actual task of which is to create an optimal tax field in Ukraine, for the development of an open national economic system. The article is devoted to the study of theoretical and practical tax aspects in the international business of Ukraine. Effective level and taxation regime helps to attract foreign capital, develop international business, increase state revenues and increase gross domestic product of the country. The factors hindering the process of investing in our country are considered. The problems, as well as ways of their solution, concerning the tax component of Ukrainian business are analyzed. Detailed attention is focused on some tax aspects, which primarily include: transfer pricing rules, the rule of "thin capitalization", the rules of reporting of international groups of companies by country. Essential characteristics, features and rules of transfer pricing and "thin capitalization" are highlighted. The actions on the BEPS Action Plan are considered, which propose to eliminate the shortcomings of international tax regulation and differences in the national tax legislation of different countries, which promote "concealment" of corporate profits and its artificial transfer to low tax jurisdictions, where companies are no longer engaged in economic activity. The proposals on the improvement of bills that will recognize Ukraine as a cooperating country on taxation issues have been formed. These bills will make it possible to strengthen the economic link between Ukraine and the countries of the CIS and Eastern Europe. Recovering and strengthening these ties is the easiest to date, as each party feels that need. Right now Ukraine is taking measures for their restoration on the basis of an effective market mechanism of economic interaction.

Power of Bonus in Pricing for Crowdsourcing

We consider a simple form of pricing for a crowdsourcing system, where pricing policy is published a priori, and workers then decide their task acceptance. Such a pricing form is widely adopted in practice for its simplicity, e.g., Amazon Mechanical Turk, although additional sophistication to pricing rule can enhance budget efficiency. With the goal of designing efficient and simple pricing rules, we study the impact of the following two design features in pricing policies: (i) personalization tailoring policy worker-by-worker and (ii) bonus payment to qualified task completion. In the Bayesian setting, where the only prior distribution of workers' profiles is available, we first study the Price of Agnosticism (PoA) that quantifies the utility gap between personalized and common pricing policies. We show that PoA is bounded within a constant factor under some mild conditions, and the impact of bonus is essential in common pricing. These analytic results imply that complex personalized pricing can be replaced by simple common pricing once it is equipped with a proper bonus payment. To provide insights on efficient common pricing, we then study the efficient mechanisms of bonus payment for several profile distribution regimes which may exist in practice. We provide primitive experiments on Amazon Mechanical Turk, which support our analytical findings.

Impact of transfer pricing toward benefits and sustainable of multinational hotel industry

This article discusses the impact of transfer pricing on the benefits and sustainability of the hotel industry operating in many countries. The author believes that the hotel industry is just like any other industry where the impact of transfer pricing also impacts tax reporting and the company's actual financial condition. For this reason, we have made some databases of journal publications and websites as the primary data for us to study with a phenomenological approach so that these data become valid findings in completing the discussion of this business study. The descriptive qualitative study format became the design of this study by relying on data and evidence from field studies by digitally searching in journal publications such as Taylor and Francis, Elsevier, Google books, and many national scientific publications. Based on the study results and discussion of the data, we can summarize that transfer pricing impacts revenue on the sustainability of the hotel industry internationally. Therefore, transfer pricing rules, and policies for each hotel are allowed to be directly determined following the country's rules in which it is located the hotel operated.

The Harmonisation of Transfer Pricing: the Obstacles, the Arm's Length Principle and the OECD Guidelines

<p>This essay argues that the complete harmonisation of transfer pricing rules with the arm’s length principle is unattainable for three reasons. First, states are not under a legal obligation to apply the principle outside of treaty or domestic law. Second, the theoretical shortcomings of the principle are creating a divergence from the OECD guidelines on how the principle should be applied. Third, the perception held by states that multinational enterprises are not paying a fair share of tax is also creating a divergence from the OECD guidelines on the principle. The resultant divergence is a significant obstacle to transfer pricing harmonisation.</p>

The Harmonisation of Transfer Pricing: the Obstacles, the Arm's Length Principle and the OECD Guidelines

<p>This essay argues that the complete harmonisation of transfer pricing rules with the arm’s length principle is unattainable for three reasons. First, states are not under a legal obligation to apply the principle outside of treaty or domestic law. Second, the theoretical shortcomings of the principle are creating a divergence from the OECD guidelines on how the principle should be applied. Third, the perception held by states that multinational enterprises are not paying a fair share of tax is also creating a divergence from the OECD guidelines on the principle. The resultant divergence is a significant obstacle to transfer pricing harmonisation.</p>

Optimal Loan Pricing for Agricultural Supply Chains from a Green Credit Perspective

In recent years, many countries have proposed various sustainable development strategies around environmental issues. The implementation of green supply chain management is an effective sustainable development approach that combines “environmental awareness” and “economic development.” Therefore, introducing the concept of “green” effectively is the main direction for the sustainable development of agriculture in the future. The impacts of green credit policies on agricultural supply chains have rarely been discussed before. Therefore, we focus on the incentive mechanism of green credit policies in the agricultural supply chain. We use the Stackelberg Leadership Model to construct a pricing model which adds the interest subsidy and required reserve ratio (RRR) cuts, and determines the pricing rules of bank loans and production decisions of the farmer in the agricultural supply chain under the incentive policy of green credit by quantifying the optimization problems of the bank and the farmer. The result shows that optimal decisions exist for both farmer and bank in the supply chain game framework. The implementation of the green credit policies contributes to both of their profits. Additionally, the green credit policies give the bank room to reduce interest rates so that the overall utility level of the supply chain could be improved.

Improved Revenue Bounds for Posted-Price and Second-Price Mechanisms

How to optimize posted price mechanisms? The sequential posted-price (SPP) mechanism is one of the widely used selling mechanisms in practice. In this mechanism, the seller presents each buyer with a price sequentially and the buyer can either accept or reject the mechanism's offer. Despite the widespread use of the SPP mechanism, the problem of optimizing prices in this mechanism has not been fully addressed. In a paper entitled, “Improved Revenue Bounds for Posted-Price and Second-Price Mechanisms,” H. Beyhaghi, N. Golrezaei, R. Paes Leme, M. Pal, and B. Sivan construct SPP mechanisms by considering the best of two simple pricing rules: one that imitates the optimal mechanism and the other that posts a uniform price (same price for every buyer). Their simple pricing rules can be easily generalized to the setting with multiple units and yield the first improvement over long-established approximation factors.

Pricing Strategies of Dual-channel Green Supply Chain Considering Big Data Information Inputs

In the Big Data environment, when green manufacturers invest in the green production technology, to satisfy consumer demand timely and accurately, they may begin to gain consumer performance information (hereafter, CBDI) to design and produce product. However, these will go up their extra costs. Meanwhile, for a green manufacturer who sells the green product through the online channel and the offline channel, the expression of its market demand needs to rethink in the new environment. In these conditions, for a dual-channel green supply chain (hereafter, DGSC), chain members pay more attention on the pricing problems considering the inputs of CBDI and greening R&D. Hence, to resolve this question, a DGSC a green manufacturer selling by the online channel and with one retailer selling by the offline channel was chosen. Afterwards, the demand function of the DGSC was revised, and we analyzed the profits models and its pricing rules in the proposed four common cost-sharing models. Results indicate that whether the retailer bears the CBDI costs or the greening R&D costs, the retailer will not change its retail price. If the retailer can bear some CBDI costs, the alteration tendencies of the best wholesale price are related to the cost-sharing parameter.

Task Price Prediction Based on Clustering and DNN in Crowdsensing

With the popularization of mobile devices and the development of wireless networks, crowdsensing is devoted to providing universal Internet of Things services. A reasonable task pricing mechanism can not only motivate more users to participate in the sensing task but also help the benign development of crowdsensing platform, so it has gradually become a research hotspot in the field of crowdsensing. Aiming at the common problems of insufficient analysis of task pricing rules and large deviations of pricing prediction models, a task price prediction method based on clustering and DNN is proposed. Using the real historical trade price set as the data source, natural grouping and taxonomic description of task price are realized by exploring sensing task pricing law with complex constraint relation using two-step clustering analysis. On the basis of the above, the price interval prediction model based on DNN is implemented. The experimental results show that the predicting accuracy of the pricing mechanism is higher than 82.7%.

Corporate Income Shifting in an Era of Tax Multilateralism: The Impact of Exchange-of-Information Agreements

Using data from the annual reports of over 100,000 subsidiaries of multinational enterprises (MNEs) from 55 countries between 2003 and 2012, the authors of this article investigate the impact of exchange-of-information agreements ("EOI agreements") on tax-motivated income shifting. Transparency created by the signing of EOI agreements is expected to reduce the tax-motivated shifting of income by multinational corporations. Whether such agreements affect the income-shifting behaviour of multinational corporations is an unanswered question. The authors find evidence that, on average, EOI agreements do have an impact on tax-motivated income shifting. Additionally, they find that more advanced, modern EOI agreements are associated with a larger decrease in tax-motivated income shifting compared to the impact of early EOI agreements. This evidence challenges the prevalent assumption in empirical studies that EOI agreements are homogeneous. Supplemental analyses suggest that factors that affect the information asymmetry between MNEs and tax authorities, such as corporations with high levels of intangibles and tax authorities with strong transfer-pricing rules and enforcement, can diminish or enhance the effectiveness of EOI agreements in moderating tax-motivated income shifting. The evidence provided by this study shows that consideration of the tax authorities' information environment and the substance of an EOI agreement is essential when assessing the impact of such an agreement on the tax behaviour of sophisticated taxpayers such as multinational corporations.