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Interjurisdictional allocation of multinational banking income: aligning taxation principles with economic activity.Sadiq, Kerrie, mikewood@deakin.edu.au January 2003 (has links)
This thesis argues that one type of multinational entity the multinational bank
poses particularly significant challenges to the international tax regime in terms of its
current profit allocation rules. Multinational banks are a unique subset of
multinational entities, and as a consequence of their unique traits, the traditional
international tax regime foes not yield an optimal interjurisdictional allocation of
taxing rights. The opportunity for tax minimisation, achievable because of the unique
traits, and realised through exploitation of the traditional source and transfer pricing
regime, results in a jurisdictional distribution of taxing rights which does not reflect economic reality.
There are two distinct ways in which the traditional international tax regime fails to
reflect economic activity. The first way that economic activity may not be reflected
in the distribution of the taxing rights to income from multinational banking is
through the application of traditional source rules. The traditional sources rules
allocate income where transactions are completed rather than where the
intermediation services are arranged. As a result of their unique commercial role as
financial intermediaries, by separating intermediary economic activity from legal
transactions with third parties, multinational banks may distort the true location of the
activity giving rise to income.
The second way in which the traditional tax regime may fail to reflect economic
activity is through the traditional transfer pricing regime requiring related or internal
transaction to be undertaken at an arms length price. The arms length pricing
requirement is theoretically deficient in its failure to recognise the highly integrated
nature of multinational banking. In practice, the arms length pricing requirement is
also difficult, if not impossible, to apply to multinational banks because of the
requirement of comparability. The difficulties associated with the current model have
resulted in a subtle move by multinational banks towards global formulary
apportionment.
This thesis concludes that, for the international taxation of multinational banks, the current source regime should be replaced with a system that allocates profits for tax
purposes on the basis of income source, with source determined using a unitary
taxation or global formulary apportionment system. It is argued that global formulary
apportionment is a theoretically superior model that provides both jurisdiction to tax
and allocated profits on the basis of the economic activity that generates the income.
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Ekonominės veiklos samprata: teisinis reguliavimas Lietuvos ir ES teisės aktuose (bei Europos Teisingumo teismo praktikoje) bei praktinės problemos / Conception of economic activity: regulation under lithuanian, eu legislation (and in the european court of justice case-law) and practical issuesSmaliukas, Andrius 08 September 2009 (has links)
Lietuvos Respublikos Seimas 2002 metų kovo 5 dieną priėmė naujos redakcijos Pridėtinės vertės mokesčio įstatymą, kuris įsigaliojo tų pačių metų liepos 1 dieną. Naujos redakcijos PVM įstatymo 3 straipsnyje nurodyta, kad PVM objektas yra prekių tiekimas ir paslaugų teikimas, tenkinantis visas šias sąlygas: 1) prekės tiekiamos ir (arba) paslaugos teikiamos už atlygį; 2) prekių tiekimas ir (arba) paslaugų teikimas pagal šio Įstatymo nuostatas vyksta šalies teritorijoje; 3) prekes tiekia ir (arba) paslaugas teikia apmokestinamasis asmuo vykdydamas savo ekonominę veiklą, t.y., veikdamas kaip toks. Viena iš sąlygų – kad apmokestinamasis asmuo prekes tiektų ar paslaugas teiktų vykdydamas savo ekonominę veiklą. Ekonominės veiklos vykdymas yra būtina sąlyga, kad asmens sudaromi sandoriai galėtų būti apmokestinami PVM. Taigi, ekonominės veiklos vykdymas atskiria PVM apmokestinamus asmenis nuo asmenų, kurie nėra apmokestinami šiuo mokesčiu. Nuo tinkamo ekonominės veiklos sąvokos taikymo priklauso ne tik valstybės surenkamų pajamų dydis, bet ir atskirų asmenų mokestinės prievolės. Šiame darbe lyginamas ekonominės veiklos reglamentavimas Lietuvos bei Europos Sąjungos teisės aktuose, nagrinėjami Europos Teisingumo teismo sprendimai ir tokiu būdu yra išskiriami ekonominės veiklos požymiai. Išskyrus ir aprašius ekonominės veiklos požymius, nagrinėjama prekyba vertybiniais popieriais kaip ekonominė veikla, išskiriami atvejai, kokiais atvejais tokia veikla gali būti laikoma ekonomine veikla, o... [toliau žr. visą tekstą] / The Parliament of the Republic of Lithuanian adopted on 5 March 2002 the act of value added tax (hereinafter – VAT act), which came into force on 1 of July. Under Article 3 of VAT act, the supply of goods or services shall be subject to VAT, if: 1) the supply of goods or services effected for consideration; 2) the supply of goods or services effected within the territory of the country; 3) The supply of goods or services effected by a taxable person which carries out his economic activity. One of the conditions – the taxable person must carry out any economic activity. It is compulsory condition if the supply of goods or services could be subject to VAT. The exercise of economic activity separate taxable persons and persons which do not have to pay VAT. Proper application of definition of economic activity not only necessary for country revenue but also can affect person’s burden of taxation. In this study the definition and features of economic activity are analyzed in the way of comparing Lithuanian legislation with European Union legislation. Also the European Court of Justice case-law is analyzed. After the features of economic activity are separated and described, there is trading of securities as economic activity analyzed. There are described cases when such activity can be regarded as economic activity and when it cannot. As example there are situation from European Court of Justice case-law presented. Also burden of taxation is in the case if such activity can or... [to full text]
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Demografické okno a regionální analýza ekonomické aktivity v ČR / Demographic window and regional analysis of economic activity in the Czech RepublicŠtech, Zbyněk January 2014 (has links)
Subject of this degree work is economic activity. This degree work shows progress of demographic characteristic and demographic behaviour, which affects economic activity citizens. In another part of degree work, issue of demographic behaviour is extended by new phenomenon demographic window. This degree work tries to prove or disprove existence of this phenomenno on region of Czech Republic. Existence of demographic window is proves or disproved by historical development of individual economic generations in region of Czech Republic and in her individual areas.Existence of demographic window is proved during historical development of Czech Republic. Demographic window is expressively opened since 1990. Its existence is proved in individual areas of Czech Republic too. Duration of its existence is affected by development of first and third economic generations in individual areas. In season of demographic window is performed analyze of rate of economic activity in Czech Republic and individual areas which is depended on demographic charakteristics. This charakteristics are age, gender and education. In the Czech Republic, we can find areas, where is distinctively higher or less rate of economic activity than in whole Czech Republic and remaining areas.
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Företagsbot som sanktion vid arbetsmiljöbrottMörsin, Madeleine January 2016 (has links)
Corporate fine is today the most common sanction for work environment crime. Corporate fine is an economic sanction suffered by the trader when the crime was committed in his economic activity. This thesis aims to provide a better understanding for the application of the corporate fine in work environment crime. Furthermore, the thesis also aims to give a picture of how the use of corporate fine in work environment crime is experienced both from a Prosecutor's perspective and an employers' perspective. In order to fulfil this legal science study it is complemented with an empirical study. A legal and social science method has been used to answer the formulated research questions. The Swedish law has a special prosecution rule that says that the Prosecutor of the less serious crime in the economic activity in the first place has to take action against corporate fine and not take action against individuals. This rule together with requirement that the crime must have been committed in an economic activity means that the fine not equally can be tried out to public activities, which is a sector were most women works. Work environment crimes are usually committed in activities in the construction and manufacturing industries, where more men than women are employed. This means that the corporate fines at work environment crime, to a greater extent is sentenced to maledominated industries rather than female-dominated industries. A conclusion that can be drawn from the empirical study is that the two employers' representatives have not experience that the incentive to create a good working environment has changed from when the corporate fine replaced the individual criminal responsibility. On the other hand, they see a risk where the incentives can be weakened. Because they believe that an individual criminal responsibility in general sharpens the focus of individuals.
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INTERNATIONAL TRADE AND INDUSTRIAL GEOGRAPHYTondel, Fabien 01 January 2009 (has links)
This dissertation explores the impact of international trade on the geographic location of manufacturing activities and on regional productivity growth patterns within countries. This study develops models of trade with monopolistic competition in the context of a two-region country. It also provides empirical estimates of the e ect of tari policy on the distribution of industrial activities and on productivity growth di erentials across Colombia's regions.
The rst essay investigates the consequences of trade liberalization for the distribution of manufacturing activities between large and small cities. It presents an extension of the Melitz (2003) model of trade with monopolistic competition and heterogeneous rms where producers' location and export market participation decisions depend on their productivity. As a country's exposure to trade shifts, rms and output are reallocated between large and small urban areas. Data from Colombia's manufacturing sector lend support to theoretical predictions concerning tari reduction's impact on the repartition of industrial activities between metro- and nonmetropolitan areas in this country.
The second essay extends the New Economic Geography, Footloose-Capital model to examine the e ect of commercial policy on the distribution of industrial activities between regions within a country. This study aims at distinguishing theoretical cases with regard to the nature of the trade policy change or to the source of asymmetry between regions. It shows that trade liberalization can have adverse consequences for the manufacturing sector of a small or isolated region under bilateral liberalization, but a positive impact under unilateral trade liberalization.
The third essay adapts the Melitz and Ottaviano (2008) model of trade with monopolistic competition, heterogeneous rms, and variable mark-ups to analyze the relationship between trade openness, regional market size, and regional aggregate industry performance. It demonstrates that the impact of trade liberalization on aggregate industry productivity growth varies across regions as a function of regional market size and proximity to foreign markets. A larger region experiences a greater increase in aggregate productivity through intra-industry reallocation of market shares. Similarly, a region with better access to international markets enjoys a higher productivity growth from tari reduction. Empirical evidence is obtained from the Colombian manufacturing sector.
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Tailors and Sewing Threads : A case study of public-owned firm evolving in the Swedish societyBeaufils, Pierre, Vrbanjac, Dennis January 2016 (has links)
Background Understanding the benefits from the environment of municipally-owned energy firms in Sweden, through the perspective of the network theory, the triple helix model and knowledge transfer. Aim To construct a model describing the resources flowing within the network of relationships within the specific context of operations. Methodology The study is centred on a case company where two specific departments are put in focus: the energy recovery department and the business development. The case study aims to be descriptive, according to the data collected from interviews of relevant respondents. Findings - The benefits derived from a collaboration with a knowledge centre is the legitimate creation of exploitable innovation for the firm, as well as the creation/improvement of hybrid platforms where mobility of personnel is seen as a central communication factor. - When it comes to the income generating activities the main benefits that arose within the collaboration was the creation of opportunities for growth and business networks as such.- Power on influencing the context generates policies and favourable network oriented circumstances.
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Příčiny a důsledky vývoje ekonomicky aktivního obyvatelstva / Causes and consequences of economic inactivity in the Czech RepublicPetkovová, Ludmila January 2010 (has links)
The aim of study is to analyze the causes of economic inactivity in the Czech population of working age. Attention is focused on its development, deeper understanding of the structure of the population and the consequences for him mean. The first section presents the concept of economic status, population and methods used by survey data in this area. Next chapters deals with the particular reasons for economic inactivity, such as education, retirement and disability pensions and other reasons that are asked in the Labour Force Survey conducted by the Czech Statistical Office. In the development there is particularly noticeable the prolonged duration of education of young population and the increasing age of retirement. The study continues with the analysis of the age and educational structure and development of the economically active population of working age. The last chapter analyses the issue of the average length of economic activities according to individual education based on the tables of economic activity.
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Stock Markets and Real Economic Activity : Zooming out to show a broader picture using 12 EU Membership CountriesTruedsson, Christian January 2019 (has links)
This thesis analyzes the long run relationship between stock markets and macroeconomic variables, such as the real industrial production index, consumer price index, money supply, and long-term government bonds. By the use of recent developments in cointegration methodologies a larger set of countries is analyzed due to mitigation of the issue where variables are integrated of different orders. Based on a present value model, this thesis applies an ARDL model and conducts the bounds testing procedure for analysis of cointegrating relationships among the variables. Complemented by the popular Johansen cointegration methodology, it is found that the variables are cointegrated for all of the twelve countries. Hence, the present value model provides a theoretical explanation of the long run connection between stock markets and macroeconomic variables. Finally, the long run relationship is estimated using both FMOLS and DOLS. Results show that real economic activity, proxied by the real industrial production index, enters a positive relationship with the stock market indices, and so does money supply. In contrast, the consumer price index and long-term government bonds enter a negative relationship with the stock market indices. Hence, this thesis adds to the literature by applying new methodologies to the topic, through which a larger set of countries can be analyzed, and by further analyzing the long run relationship between stock markets and real economic activity.
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News shocks e expectativas do consumidor: evidências para o Brasil / News shocks and consumer expectations: evidence for BrazilMaion, Thales Augusto Jordão de Toledo Torricelli 02 February 2018 (has links)
Índices de confiança/expectativas são frequentemente utilizados pela mídia e pelo mercado com intuito de projetar o comportamento da economia. As expectativas dos agentes econômicos são peças relevantes, acredita-se, para explicar flutuações de produto e emprego, tanto moderadas como drásticas a exemplo das crises \".com\" e dos subprimes americanos. No Brasil, o tema passou a receber mais atenção devido à crise dos últimos anos.A estimação de um VAR com séries brasileiras de produto, consumo e expectativas sugere que de fato inovações nos índices de expectativas possuirão impactos de médio-longo prazo no consumo agregado e no PIB, além dos próprios índices. A partir dessa evidência, procura-se separar por meio de um modelo DSGE o quanto desses impactos se deve a fundamentos econômicos futuros antecipados pelos agentes e o quanto se deve a alterações momentâneas de humor, isto é, aos animal spirits. Os resultados sugerem que animal spirits e ruídos inerentes aos próprios índices são responsáveis por uma parte considerável da flutuação no período de 1-2 trimestres. Para horizontes iguais ou superiores a 2 trimestres, a antecipação de fundamentos econômicos passa a ser predominante. / Consumer confidence/expectation indexes are frequently used by the media and the market in order to forecast the behavior of the economy. Agents\' expectations are believed to explain output and employment fluctuations, either moderate or drastic as the \".com\" and the american subprime crisis. In Brazil, more attention has been drawn to this topic due to the recent economic crisis.The estimation of a VAR with brazilian data for consumption, output and expectations suggests that innovations to the expectation indexes do have impact on aggregate consumption and GDP in the medium/long-run, as well as the indexes themselves. Inspired by this evidence, a DSGE model is used in order to assess how much of these impacts are due to anticipation of future economic fundamentals and how much are due to animal spirits. The results indicate that animal spirits and index-specific noise are responsible for a non-negligible amount of fluctuations up to 2 quarters, whereas news of future economic conditions prevail on lower frequencies.
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Stres u matek na rodičovské dovolené v souvislosti s rizikem ztráty zaměstnání / Stress in mothers on parental leave in relation to the risk of job lossMELECKÁ, Renata January 2015 (has links)
This thesis Stress in mothers on parental leave in connection with the risk of job loss deals with the issues of stress and unemployment phenomenon, as well as on the topic of employment of women, pregnant women and mothers, also on equal opportunities for women and men in the labor market, the systems of social security and on topics related to the return of mothers after maternity leave to the labor market. This work consists of two main parts - the theoretical and the research (empirical). The theoretical part deals with the above-mentioned problems and issues. The empirical part is focused on the research and descriptions of its results, where quantitative methods of data collection were use. For the purpose of this work the main target is a group of mothers on maternity leave. The data from respondents were collected using a questionnaire method. Collected data was then quantified using descriptive statistics. Two research questions and three hypotheses in total were defined. Hypotheses were statistically tested using statistical methods - ANOVA. The total number of 320 questionnaires from the target group was collected. To achieve the validity of the collected data and homogeneity of the sample, data collection was aimed exclusively at women, i.e. mothers on maternity leave from only the South Region. Aim of the work was to determine which group of mothers on parental leave more is more stressed mothers with a strong economic background or mothers with less strong economic background. Using a Likert scale was measured the extent of stress in mothers, who are not assured of having their job after returning from maternity leave. Using the above mentioned scale also was measured the stress in mothers on parental leave regarding their return to job and related duties, or finding a completely new job. Related to the results and testing, in the first hypothesis testing we found that mothers who do not receive any social security benefits, are more stressed than those mothers who receive benefits. Second hypothesis testing showed that mothers living with partners are less stressed than mothers who do not live with a partner. The third hypothesis testing found out that mothers on maternity leave, who are not assured of having their jobs after the maternity leave, are more stressed than mothers who have such certainty. From the results of the collected data was found out that most respondents are women aged twenty-five to thirty years, and women from thirty-one to thirty-five years. Mostly with the secondary school education (with graduation) and with university education. A large number of women working full-time and women cohabiting with a partner. A large majority of those mothers receives social security benefits. Also, a large number of women planned a combined parental leave with three years of geting the social security benefits. A considerable part of the interviewed mothers but also answered that along with the parental leave they do not have any another job. The results also showed that almost 80 % of respondents were not working at a leader position. Over 60 % of respondents are currently on parental leave with a child, a smaller part of the respondents with a second or third child. An interesting result is the fact that almost a half of respondents is planning another motherhood and nearly 60 % of them plan the second motherhood following the first one. The results of this research may lead to a consideration on the facts determined. For example, why most of the women do not work in a leader position despite their education. Or if women do really have such strong economic background to be able to continue with another parental leave. This work may help the women themselves, whether those planning to be a mother, expecting a child or having it already. Work can be as a basis or a handbook with an overview of the benefits of social security systems.
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