Student Number : 0420292V - MA research report - School of International Relations - Faculty of Humanities / The transformation of the political economy after the Cold War, and particularly the introduction of the knowledge economy and the successful liberation of a group of developing countries, has made a considerable impact on the trading patterns in the global economy. It has also revolutionised the processes of manufacturing, production and consumption. These economic changes have had significant consequences for the countries of the developing world, making the possibility of coalition-building between the countries of the Southern core more feasible, and in this way bringing about fundamental alterations in the political economy of the international system. However, the economic co-operation that takes place in the South is uneven and advances the interests of semi-peripheral states such as India, South Africa and Brazil, giving rise to new patterns of collaboration.

A research report submitted to the Faculty of Commerce, Law and Management, University of the Witwatersrand, Johannesburg, in partial fulfilment of the requirements for the degree of Master of Commerce (specialising in Taxation) Johannesburg, 2014 / Base erosion and profit shifting (BEPS) is a key concern in international tax. In 2010 the Organization for Economic Co-operation and Development (OECD) was tasked with the study of BEPS. In 2013 the OECD released the study report “Addressing base erosion and profit shifting” emphasising BEPS and the risk for the world’s economies and tax bases. The OECD has been focused on BEPS due to several reasons, namely; increase in globalisation, an ever-changing digital economic environment, mismatches of different countries’ tax legislation and the ease with which intellectual property can be transferred. They has released several documents detailing the risk of BEPS as well as an action plan outlining their aim for the transformation of local and international tax. According to the OECD corporate income taxes, as a percentage of gross domestic product (GDP) is a possible indication of base erosion. In South Africa, the corporate income tax rate as a percentage of GDP has decreased from 7.2 % in 20081 to 5% in 20132. Is this a possible indication of base erosion or profit shifting taking place? Protecting South Africa’s tax base is paramount for future growth of the country and the economy. It is therefore important to identify whether BEPS is a real risk and to determine whether South Africa has adequate legislation in place to protect its tax base. Keywords: Base erosion and profit shifting, BEPS, Organisation for Economic Co-operation and Development, OECD, international tax, transfer pricing, thin capitalisation, treaty abuse, treaty shopping

With the development of economic globalization, the threat of international financial crisis is rising. In order to address the challenge of financial crisis, the regional financial cooperation is becoming important mechanism for political elite in East Asia. Although Taiwan has important status of international economics and trade in East Asia and close economic and trade relations with China, but it is still difficult for Taiwan to join East Asia financial cooperation due to Cross-Strait political factor. This thesis analyses the political consensus of political elite in East Asia through the perspective of ¡§Neo-functionalism¡¨ on the impact of two stages of East Asia financial cooperation after international financial crisis in 1997 and 2008, and on the difficulty for Taiwan to take part in regional financial cooperation of ASEAN+3 with China¡¦s increasing political and economic influence in East Asia. Therefore this thesis analyses above issues for providing advices to Taiwan government regarding policymaking on participation in East Asia financial cooperation.

Thesis (M.A.)--Carleton University, 2001. / Includes bibliographical references (p. 99-105). Also available in electronic format on the Internet.

Thesis (Ph. D.)--Fletcher School of Law and Diplomacy, 2005. / Vita. Includes bibliographical references (leaves 417-443).

The thesis deals with the issues of economic cooperation between China and the Euroepan Union. Particular emphasis is given to the economic relations which are presented in the results of economic cooperation from 1975 until present. Whereas the mutual relations cannot be almost purely considered as a resultant economic variables, the issue is supplemented by international political questions which are closely related to the issue as well. The observed economic data are used to analyze the strengths and weaknesses of economic relations of China and the European Union and threats and opportunities arising from them.

This paper discusses the importance of Czechoslovak foreign trade with the EEC countries for the period of normalization. In the theoretical part, the author defines the issues of foreign trade. It deals with the variety of business concepts, tools of trade policy and the overall importance of international trade for the economy. In the analytical part describes the main organizations affecting foreign trade relations of Czechoslovakia after World War II, relations between the two organizations, bipolar division of the world and the position of Czechoslovakia in world trade. In the second part, the author analyzes the overall Czechoslovak foreign trade, territorial distribution and commodity structure of exports and imports. The last part focuses on the evaluation of the importance of trade with the EEC Member States, its development and shortcomings.

In 2001 the Gas Exporting Countries Forum (GECF) was created by some of the world’s leading natural gas producing and exporting countries in order to promote their mutual interests through cooperation, in particular with regard to extracting the maximum value from their natural gas exports. My core research question is: Does cooperation among GECF member countries explain those exporters’ market power in highly import-dependent natural gas consuming countries? To determine the influence of the GECF’s cooperative actions and policies, I study the GECF’s cooperative behaviour and measure the role of (collusive) producer conduct in terms of its contribution to achieving the main GECF objective: attaining gas prices that are measurably above the cost of production and hence help producers earn significant economic rents. I employ a variety of methods from the international relations literature on cooperation and cartelisation, collective action theory and an economic measurement model in three case studies. I find that cooperation among GECF members partly explains their market power in a number of import-dependent gas markets. This is so despite the GECF’s weak degree of institutionalisation. The reasons for the GECF’s influence on effective cooperative results are: first, conducive structural conditions in many gas importing markets favouring cartelisation; second, GECF members use methods such as artificial market entry barriers (e.g. long-term term contracts negotiated in a non-transparent way) to secure their market power and third, the GECF faces less severe internal procedural challenges that plague other cartels such as collective action problems, especially cheating. Cooperation among GECF exporters hence contributes to high(er) prices of natural gas. This causes economic inefficiencies and a transfer of wealth—and political power—from gas consumers to producers. It also hinders climate change mitigation as cleanerburning gas remains too expensive to replace ‘dirty’ coal in power generation.

Notre recherche propose d’appréhender la « mise en dispositif », au sens de Foucault (1977), de projets de polarisation territoriale dans le champ de l’économie sociale et solidaire (ESS). Nous nous appuyons sur une analyse multi-niveaux qui se décline sous la forme d’une enquête qualitative nationale sur l’élaboration du dispositif Pôle Territorial de Coopération Economique (PTCE) et de deux études de cas. Nous mobilisons la grille d’analyse du travail institutionnel pour cerner les pratiques mises en œuvre par les pôles pour s’approprier le dispositif dans un contexte de pluralisme institutionnel. Deux niveaux de résultats sont proposés. Le premier revient à éclairer le phénomène de banalisation du dispositif PTCE, qui est d’abord caractérisé par une logique civique de développement territorial alternatif, qui se voit ensuite remplacée par une logique gestionnaire de normalisation de l’ESS. Le second consiste à caractériser les modalités d’appropriation de ce dispositif à l’échelle méso. Il en ressort que le PTCE qui parvient à survivre et à se développer est celui qui hybride les logiques civique et gestionnaire. Le second PTCE, très façonné par la logique civique, ne parvient pas à pérenniser son activité et suscite un rejet du dispositif, dont il ne partage aucunement l’intention stratégique. Conjuguer une posture critique à une analyse néo-institutionnaliste nous permet de dégager plusieurs apports théoriques. (1) La montée en généralité nous amène à dessiner les contours conceptuels d’un nouveau type de dispositif que nous qualifions de normalisateur. (2) Nous mettons en évidence un nouveau type de pratiques : celles qui ont trait à la résistance institutionnelle. / Our research focuses on the adoption of a dispositive (Foucault, 1977) destinated to territorial polarization projects in the field of social and solidarity economy. We build on a multi-scalar approach which consists in a qualitative national survey of the construction of the Territorial Cluster for Economic Cooperation policy and two case studies of two of these clusters. We build on the institutional work theory to characterize the practices deployed by the two TCECs in order to appropriate the dispositive in a context of institutional pluralism. Two levels of results are proposed. The first one sheds light on the banalisation process of the TCEC dispositive at the national level, which is first dominated by a civic logic of alternative territorial development that is then effaced by a a managerial logic of normalization of SSE. The second level of results consists in characterizing the modalities of appropriation of this dispositive at the meso scale of the two clusters analysed. It appears that the TCEC which manages to survive and develop is the one that hybridizes the civic and managerial logics. The other one, particularly shaped by the civic logic, doesn’t manage to perpetuate its activities and implies a reject of the dispositive, since it doesn’t share its strategic intention. Combining a critical approach and a neo-institutionalist analysis leads to several theoretical contributions. (1) We draw the outlines of a new type of dispositive that we conceptualize as a normalizing dispostive. (2) The analysis of institutional work in a context of institutional pluralism highlights a new type of practices : the ones which deal with institutional resistance.

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