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Le but de cette étude est de servir comme un véhicule exploratoire présentant l'une des questions épineuses en matière de planification fiscale globale et de sa mise en œuvre par des États individuels, celle des prix de transfert et de l'utilisation de ces juridictions d'hébergement. L'étude vise à démontrer la complexité des mécanismes fiscaux qui entourent le sujet, principalement en utilisant de la jurisprudence et des analyses juridiques, ainsi que des rapports de comptabilité, des rapports financiers et des enquêtes journalistiques. Ce faisant, l'ouvrage présente de prouver que malgré la volonté politique manifeste de changer le cadre actuel, le statu quo est susceptible de rester, bénéficiant ainsi aux entreprises multinationales au détriment des économies des États individuels. Le travail est divisé en trois chapitres essentiels et distincts, dont chacun joue un rôle essentiel dans la reconstruction de la grande image de stratégies d'évasion fiscale globale. Le premier chapitre définit les paradis fiscaux et leur utilisation, illustre leurs origines, ainsi que leur évolution jusqu'aux temps modernes et étudie les questions problématiques qui entourent leurs opérations, particulièrement dans le contexte des activités des entreprises. Ce faisant, cette étude tente de démontrer les deux côtés du débat sur les techniques de minimisation des impôts et de leur impact à la fois sur les économies 'onshore' et 'offshore'. Le deuxième chapitre présente une analyse plus technique des prix de transfert, une méthode particulière utilisée par les entreprises pour réduire leur fardeau fiscal. Sous cette rubrique, une analyse approfondie des méthodes et fonctions de prix de transfert est proposé, en mettant l'accent sur le contexte nord-américain. Dans le dernier chapitre, l'application pratique des techniques de prix de transfert est illustrée par une étude d'un cas particulier de la corporation Starbucks, qui a réussi d'utiliser la comptabilité complexe inter-entreprises à travers plusieurs juridictions afin d'éviter de payer des impôts sur ces profits à travers le monde. ______________________________________________________________________________ MOTS-CLÉS DE L’AUTEUR : Prix de transfert, paradis fiscaux, évasion fiscale, minimisation fiscale, compagnies multinationaux

This thesis is an investigation of the impacts of extreme weather on the livelihoods of households in the hillside communities of the Jesus de Otoro Valley, Honduras. Extreme weather events can have profound negative impacts on livelihoods that rely heavily on natural resources, such as agriculture. The reliance of hillside households on agriculture and related activities for survival makes this population critically vulnerable to the negative impacts of extreme weather. This study found that the livelihood resources of this group that are most affected by extreme weather events are cash income and human health. Strong rains, drought and extreme temperatures have several direct impacts on household income, not only for hillside farmers themselves, but also for the merchants whose businesses have been developed to serve them. Extreme weather events also have multiple direct impacts on human health. Increased incidence of bacterial infections and communicable diseases are serious effects of strong rains, drought and temperature extremes. This study found a clear positive feedback link between decreased income and deterioration of health. Climate change studies predict that extreme weather events will become more frequent and severe. If these predictions are correct, hillside households will suffer potentially devastating impacts on their livelihoods. The coping strategies currently employed by hillside households in the face of extreme weather events are unlikely to provide the resources needed for households to survive under more severe and unstable weather conditions. / SSHRC, CIDA, Students for Development

Agroforestry production methods present one option for addressing growing concerns about the long term sustainability of intensive coffee production techniques. A study was designed to compare the effects of fertilization and shading from two leguminous species, Erythrina poeppigiana and Chloroleucon eurycyclum, on coffee grown at a Costa Rican research site. Coffee below biannually pruned, conventionally fertilized Erythrina exhibited the highest photosynthetic performance under both low and high light levels as well as greater biomass and higher N concentration. Soil P did not affect coffee performance, although shade trees on sites with higher soil P fixed more N compared to trees grown on low P sites, most of which were not found to be fixing. Results suggest shade mechanisms are the most important drivers of coffee adaptation in coffee agroforestry systems, though proper soil nutrient management and legume species pairing also appear to augment coffee response to microclimate conditions.

Agroforestry production methods present one option for addressing growing concerns about the long term sustainability of intensive coffee production techniques. A study was designed to compare the effects of fertilization and shading from two leguminous species, Erythrina poeppigiana and Chloroleucon eurycyclum, on coffee grown at a Costa Rican research site. Coffee below biannually pruned, conventionally fertilized Erythrina exhibited the highest photosynthetic performance under both low and high light levels as well as greater biomass and higher N concentration. Soil P did not affect coffee performance, although shade trees on sites with higher soil P fixed more N compared to trees grown on low P sites, most of which were not found to be fixing. Results suggest shade mechanisms are the most important drivers of coffee adaptation in coffee agroforestry systems, though proper soil nutrient management and legume species pairing also appear to augment coffee response to microclimate conditions.

台灣休閒咖啡館商業計畫書 / In Taiwan, have a cup of coffee have become part of the life of people who lives in the city. We cannot only buy the coffee in coffee shop like Starbucks, Barista, or Mr. Brown but also in convenient stores like 7-11 and Family Mart. These places provide different kinds and levels of coffee. This causes a fierce competition in coffee shop market. But this also indicates that the needs of coffee keep growing. Although lots of places provide coffee, only few of them provide quality coffee in a special and tasteful space. Most coffee shops are for people to sit down and talk and consumers don’t care if the coffee is good or not as long as it’s cheap. Actually from a cup of coffee, there are lots of things to talk about. From the history of drinking coffee, places that coffee bean grows, and people who live in those places. It will be fantastic if people know this information when having coffee. Form a cup of coffee, we know how to care about the world, and we don’t have to learn these things in a classroom but in a warm, elegant coffee shop. Le Moulin de la Galette will be a shop that not only provides good coffee, but also knowledge of coffee and the way to develop the culture of coffee. It will also be a place that the customer will gain a series of delightful experiences instead of just some products that you can have anywhere.

Influence of micropropagation through somatic embryogenesis on somaclonal variation in coffee (Coffea arabica): assessment of variations at the phenotypical, cytological, genetic and epigenetic level Somaclonal variation (SV) is a major concern in all micropropagation systems. It is described as the phenotypic variation displayed in in vitro-derived regenerants and it is believed to be originated from a large array of genetic and epigenetic mechanisms. Highly productive Coffea arabica hybrids are clonally disseminated in Meso-American region through somatic embryogenesis (SE). The objective of the present work in coffee is to evaluate the trueness-to-type of SE and to understand the mechanisms involved in SV. We assessed the variations in the propagated plants at the phenotypic, cytogenetic, genetic (mutations/AFLP, genetic transposition/S-SAP) and epigenetic (methylation/MSAP) level by using two complementary approaches. First, with 2 hybrids we studied industrial culture conditions expected to be weakly mutagenic thanks to the combined use of short term proliferation period (6 months) and low auxin supply (0-1.4 µM 2,4-D). Two proliferation systems i.e. secondary embryogenesis and embryogenic suspensions were compared, the latter being more productive and economic. AFLP and MSAP molecular analyses on 145 somatic seedlings showed that genetic and epigenetic polymorphisms between mother plants and emblings were extremely low, i.e. ranges of 0-0.003% and 0.07-0.18% respectively, with no significant difference between the proliferation systems. For the two hybrids tested, massive phenotypic observations in nursery and field plots showed very low levels of SV (0.9% from 800,000 plants). Cytological analysis showed abnormal chromosome numbers (41-43, 45) in most of coffee somaclonal variants and normal numbers (44) in phenotypically normal plants. Stressful experimental conditions were also applied by using extended proliferation periods (4, 12 and 27 months) for three independent embryogenic lines established for the Caturra var. in presence of high growth regulator concentrations (4.5 μM 2,4-D, 17.8 μM 6-BA) to understand the mechanisms of culture ageing on SV. The proliferation time strongly affected the SV frequency among the 180 regenerated plants and in a highly similar way with the three embryogenic lines. No variant was found after 4 months proliferation although 30% and 94% phenotypic variants were observed in plants derived from 12 and 27 month-old cultures, respectively. Regardless the culture age and the embryogenic line, no polymorphisms were found in the 124 plants analyzed and very limited methylation changes with MSAP markers (0.049-0.087%). However, similarly to plants derived from industrial conditions, phenotypic variants systematically showed abnormal chromosome numbers and normal plants systematically showed normal numbers. This work showed that SE based on embryogenic suspensions is reliable for true-to-type propagation of selected C. arabica varieties. It also demonstrated the importance of culture age on SV and hence the non random nature of this phenomenon. The genetic and epigenetic alterations are particularly limited during SE. The main change in most of phenotypic variants was aneuploidy showing that mitotic aberrations play a major role in SV in coffee.

The aim of this study is to understand the Fair Trade Coffee Business Model by determining how the Fair Trade Coffee Business Model affects the livelihoods of the small scale producers in developing countries. The Fair Trade Coffee Business Model is driven by the mission to improve the well-being of the small scale producers located in developing countries through the lens of the Triple Bottom Line (economic, social and environment). What is the significance of fair trade coffee to the economies of developing countries that produce coffee? The economies are considerably impacted by coffee production as coffee ranks as the second foremost exported commodity from developing countries (European Coffee Federation, 2006). Ensuring the small scale producers receive a fair price for the coffee they grow is only one of the initiatives of the model. Other key initiatives include pre-harvest financing, increased healthcare services, working together for a higher quality coffee, fairer business conduct, improvements in education, and technical assistance. The findings of this study provide some insights into the Fair Trade Coffee Business Model’s effect on the livelihoods of the small scale producers in developing countries through the lens of the Triple Bottom Line. The Fair Trade Coffee Business Model has increased the quality of the coffee bean produced by the small scale producers along with developing long term business relationships throughout the Fair Trade Coffee Business Model supply chain. In sum, the small scale producers reported that the Fair Trade Coffee Business Model has a positive effect on their livelihood and well-being. More specifically, they also indicated that the motivations for them to participate in the Fair Trade Coffee Business Model are receiving a better price for coffee, democratic decision making and farm training. An additional finding affirms that the Fair Trade Coffee Business Model is a sound contributor to the socio-economic stability of the small scale producers, offering a sustainable income-generating alternative market strategy.

One of the objectives of my thesis is to argue that regulatory capitalism and international law are problematic forms of power implicated both directly and ideologically in the standardizing practices and regulation of certified fair trade. My work begins by explaining variations in the way fair trade coffee is conceptualized and offered in the market, then moves on to explain how fair trade certification standards link up with other international standards and certification bodies, and finally, describes how standards and certification are used to textually construct social facts. I examine first those places where regulatory capitalism and international law remain embedded and active in fair trade certification practices, then the way standardizing practices work to organize (or disorganize) the relationships of people who work with fair trade coffee. The ethnography consists of interviews with three informally regulated fair trade roasters in the Victoria region. My aim is to identify precisely the points where the standardizing practices of certified fair trade reduce concrete relations of exchange to conceptual notions of fair trade. Identifying these points allows me to examine areas where dominant forms of power remain embedded and active in the concept and realization of certified fair trade coffee, and also how standardizing practices limit the potential of fair trade to transform unjust relations of trade. The question this thesis raises is not whether or how we can make fair trade coffee but rather, how can we focus solutions to unjust trade relations to be politically effective for all involved?

It is important, for companies operating on a homogeneous product market, to understand and adapt to customer needs. Since coffee is a homogeneous product in food retail it is vital for coffee companies to work extensively with differentiation and the fierce competition. The prevailing homogenity makes it difficult for companies to develop the product itself and must therefore work to create added value to the product. The purpose of this thesis is to carry out a study on consumer decision-making when purchasing homogeneous products, and to examine how companies work to strengthen their brand and gain market share in a homogeneous product market. The market that this thesis highlights is the coffee market. To answer the purpose of this thesis the writers have conducted a questionnaire survey regarding consumers’ decision-making process and interviewed two marketing managers for two major actors on the coffee market. The results of the survey show that the availability and the price are key factors for consumers when choosing coffee, and the generated responses from the interviews emphasize the importance of working with strengthening a brand and finding an identity for the product.