O presente trabalho investiga empiricamente os determinantes de investimentos chineses e brasileiros no exterior e faz uma comparação entre a China e o Brasil no sentido de determinantes e características gerais de investimento no exterior, como o volume, a escolha de destinação. Em base de uma revisão teórica da área de investimento no exterior no primeiro artigo, testamos empiricamente, no secondo artigo, as hipóteses sugeridas pela teoria de Paradigma Eclético do Dunning e pelas outras literaturas nesta área pelo modelo de painel, utilizando os dados oficiais do Brasil e da China coletados no período entre 2006 e 2012. Encontramos os mesmos resultados de variáveis principais, os quais indicam que investimentos no exterior de ambos dois países tem motivação significativa de buscar mercado, eficiência e exportar capital intelectual, mas a busca de recurso natural é uma motivação insignificativa para os dois países. Encontramos também os diferentes resultados em variáveis controladas entre dois países. / This study investigates the determinants of Chinese and Brazilian outward foreign direct investment (OFDI) and conducts a comparison between China and Brazil in terms of FDI determinants and general FDI features like volume, location choice. Based on an extensive and in-depth theoretical review of main FDI theories in first article, we, in second article, test empirically our hypotheses suggested by Dunning\'s Eclectic Paradigm theory and others FDI literature through a panel data model, using Brazil and China official data collected between 2006 and 2012. We find same results of main variables that both Chinese and Brazilian OFDI have significant motivations of market-seeking, efficiency-seeking and asset-exporting (contrary to hypothesis), but resource-seeking OFDI is insignificant for both countries. We also find their difference in results of control variables.

<p>Foreign Direct investment (FDI) has been recognized as a vital source of development for African countries, which are mainly capital importing countries. This has led to a quest for effective regulation of the activities of foreign investors in a country while considering the profit making goals of the investors as well. As there is a need to strike a balance between the need to regulate entry and activities of investors and reaping the immense benefits of FDI such as growth and development. The regulation of FDI thus becomes important. However, there is no universal multilateral agreement on Investment (MAI) that binds most states oft the world. What we have is attempts at regional levels to regulate Investment uniformly. This quest has led to debates with many developing countries (Africa Inclusive) resisting attempts to formulate a MAI. This paper will start with an introduction of the importance of FDI as well as the various attempts that have been made to regulate FID on a multilateral level. Then the paper will go on to examine two Bilateral Investment Treaties (BITs) Botswana-China BIT on Promotion and Protection of Investments 2000,Czech-Tunisia BIT for the Promotion and Reciprocal Protection of Investment 1997, and two Free Trade Agreements (FTAs) - Chapter 11 of the North American Free Trade Agreement (NAFTA), 1990 and the investment provisions of the U.S &ndash / Morocco Free Trade Agreement 2004, to identify those trends that are common to these agreements that have been entered into by African countries. It will examine these provisions in line with the rights and obligations they create for the investors as well as the host countries.</p>

Society's concern over the negative impact of business activities on the natural environment has significantly increased and, as a result, environmental regulations have grown considerably both in number and scope. As these policies affect businesses and their competitive environment, firms are interested in shaping the nature of such legislation through corporate political activities (CPAs). This thesis investigates the CPAs of MNEs in the automotive industry that are directed towards environmental regulations in the EU. Using the resource-based view as its theoretical framework, it investigates six research questions that address the characteristics, determinants and consequences of these CPAs in relation to three regulatory areas (pollutant emissions, CO2 emissions and end-of-life vehicles). Case study analysis is based on 71 interviews with stakeholders from the automotive industry (the entire population of 11 MNEs from the Triad regions that are politically active in Brussels) and related industries, EU institutions and civil society organisations, representing the societal triangle (market, state, civil society). The thesis finds that the 11 automotive firms engage in CPAs to inform policymakers, and because of the impact that regulations have on their businesses. Whilst the firms attempt a cooperative approach, in reality this is not always the case: whereas individual company and association activities should lead to a united voice, this does not occur when it comes to important company-specific technologies and particular environmental policies. These regulations are viewed by companies as both a costly burden and as opportunities, though non-corporate respondents perceive that MNEs see them only as costs. The main (political) resources and competences used in CPAs are found to be human resources (including the related resources of expertise, contacts, trust and reputation, i.e. social capital), and technological resources. Regulations and the technological resources influencing CPAs are directly and uniquely linked to the product portfolios of MNEs. These differences in technological resources and product ranges account for most of the variance in MNEs‟ CPAs rather than the respective countries of origin within the Triad.

ISSUES OF TRANSFER PRICING Transfer pricing is a very discussed topic of recent years, both by tax subjects, tax advisors as well as by tax administrations. This is due to activities of OECD and the European Union in this area, as well as due to increase in number of tax audits focusing on transfer pricing. The key documents are rules issued by OECD in the form of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, which is being constantly revised and supplemented, the latest revision being issued in 2017. In the narrower terms, transfer pricing may be defined as prices for transactions between connected (related) parties. In broad terms, transfer pricing may be defined as any and all transactions between connected (related) parties including in particular transfer of goods, providing of services, transfer and other transactions concerning intangibles, cost contribution arrangements and business restructurings, as well as related tax administrations procedures when deciding on tax duty in connection with the transactions performed between the related parties and the transfer pricing documentation. In the first and second part of this thesis I am outlining the historical progress in activities of OECD in the area of transfer pricing since the first report issued...

A Teoria de Negócios Internacionais sugere que ao aumentar o seu grau de internacionalização, as Empresas Multinacionais dos Países Emergentes dependerão cada vez menos dos efeitos dos seus países de origem, escapando assim das mazelas e deficiências desses países e igualando-se às Empresas Multinacionais dos Países Desenvolvidos. Essa argumentação de escape do país de origem, ou argumentação de escape, enfrenta, no entanto, dois desafios. O primeiro refere-se à geração das vantagens competitivas das multinacionais. As firmas originárias dos países desenvolvidos utilizam-se principalmente de capacidades tecnológicas e marketing para construir suas vantagens com base em seus produtos e marcas diferenciados, enquanto as multinacionais dos países emergentes o fazem a partir do aproveitamento de condições específicas do seu país de origem, utilizando-se de capacidades de inovação em processos e operações e em funções administrativas. O segundo desafio refere-se a evidências empíricas de que efeitos de país de origem se fazem sentir mesmo nas empresas multinacionais maduras de países desenvolvidos. A presente pesquisa busca ampliar o conhecimento sobre as capacidades de inovação das empresas multinacionais de países emergentes através do estudo dos limites do argumento do escape. Uma análise longitudinal das capacidades de inovação das empresas multinacionais brasileiras é utilizada para este fim. Estuda-se um período de cinco anos em que o ambiente de negócios do Brasil mudou de estável e favorável a turbulento e desafiador. A análise utiliza dois \"surveys\" aplicados em 2010 e 2015, além de informação complementar de fontes primárias e secundárias. Os resultados sugerem que as capacidades de inovação dessas empresas multinacionais ainda podem sofrer influência do ambiente institucional político e econômico do seu país de origem, mesmo com incremento do seu grau de internacionalização. Observam-se ainda diferentes consequências conforme a estratégia de internacionalização utilizada pelas firmas. As implicações dos achados são discutidas. / The international Business theory suggests that as they increase their degree of internationalization, Multinationals from Emerging Markets reduce their dependency on their Country of Origin Effects, escaping from these countries\' instabilities and deficiencies, therefore leveling with Multinationals from developed countries. The escape from the country of origin, or escape argument, faces two challenges. The first is that firms from developed countries base their advantages on technology and marketing capabilities to build strong products and brands, whereas firms from emerging countries do so mainly by exploiting their country of origin effects using innovative capabilities related to process and operations and to administrative functions. The second challenge relates to empirical evidence of the persistence of country of origin effects on mature multinational firms from developed countries. This research attempts to improve the knowledge on the innovation capability of Emerging Markets Multinational Enterprises through studying the limits of the escape argument. A longitudinal analysis of the innovative capabilities of Brazilian Multinational firms is used for that purpose. The five-year period studied involves a shift in Brazil\'s conditions from a stable and positive institutional environment to one of turbulence and instability. The research uses data from two surveys executed in 2010 and 2015, as well as other primary and secondary sources. The results suggest that the innovative capabilities from Emerging Market Multinationals can still suffer influences from changes in their home country political and economic institutional environment, even with an increase in their degree of internationalization. The outcomes vary according to the internationalization strategy used by the firms. Implications of these findings are discussed.

The thesis investigates how FDI intra-industry spillovers are affected by MNE ownership modes and sub-national locations. A conceptual framework is developed which utilises IB theories to propose how MNE ownership modes and sub-national locations are likely to matter for FDI spillovers. The research propositions are explored quantitatively using an unbalanced firm-level panel dataset of 1624 Indian manufacturing firms (1991-2008) with 5203 firm-year observations. The model estimation is carried out in STATA 13.0 in two stages; firstly, by using semi-parametric (Levinsohn-Petrin) method to derive the dependent variable (TFP of domestic firms); and secondly, by using fixed effects model estimated in first-differences to relate TFP of domestic firms' with different measures of foreign presence. Results from the first model reveal that WOSs and MAJVs have positive spillover effects whereas MIJVs have negative spillover effects in the Indian manufacturing sector. The second model finds that the net spillover effect in non-metropolitan regions is higher than in metropolitan regions. The thesis discusses the possible major policy implications of the results and considers possible reasons for the differences in the spillovers for different ownership modes and sub-national locations.

This study deals with foreign direct investments and their impacts on regional labour market and on domestic firms through spillover effects. The main goal was to find out if the foreign presence has positive influences on the host regional economy. This study has two important parts - quantitative and qualitative researches. The result of quantitative research based on multiple regression comes with no relevant empirical evidence of spillover effects. The qualitative research as a case study of TRCZ allows a trying to solve possible FDI-impacts on regional economy of Lovosice region. Keywords: foreign direct investment, multinational enterprises, impact of FDI, host economy, spillover effects

This thesis provides a cross-country analysis of potential tax revenue losses due to the ways different countries tax over-border dividend and interest incomes of multinational enterprise. Withholding taxation of outgoing dividends and interest payments is regulated by domestic tax rules as well as bilateral double tax treaties. The signing of such a treaty might substantially reduce the tax rate levied by the source country on the outgoing passive income and thus decrease its tax revenue. We create a large panel dataset and estimate withholding tax rate elasticities of dividend and interest outflows for a large set of countries around the world. Subsequently, we use these elasticities to estimate potential tax revenue losses due to outgoing dividend and interest payments for the source countries in our dataset. The results show highly elastic dividend outflows, 2.3% - 2.58% decrease related to 1% increase in the applicable withholding tax. We also find substantial tax revenue losses due to dividend outflows for a number of source countries, the largest for Canada (1.35 - 3.19 billion USD) and the United States (2.27 - 2.94 billion USD). The investor country behind the largest part of potential losses shows up to be the Netherlands. JEL Classification F21, F23, H25, H26 Keywords double tax treaty;...

China has had a remarkable development since the late 1970s, when the Chinese government started opening up its internal market for the outside world. The Chinese legislation and the legal system itself have been developing rapidly to adapt to the new economic environment, however not without complications. Many uncertainties still remain. Under the old income tax regime, corporations on the Chinese market were taxed under two different systems, one for domestic enterprises and one for foreign invested enterprises and foreign enterprises. With the new Corporate Income Tax Law, these two systems were merged and new concepts introduced. The new income tax law includes important articles that affect the transfer pricing regime in China. The OECD’s transfer pricing regulations have served as a model when China first started to regulate their transfer pricing, there are consequently similarities between the two. Multinational corporations consider the issue of transfer pricing as the most important issue in their international taxation. It is important both from the aspect of being the most effective way to maximize the world profit of the corporation and also in the aspect that an adjustment due to inaccuracies in the corporation’s transfer prices can be expensive. The Chinese transfer pricing system is considered to be young in comparison with other jurisdictions, for example the United States. The Chinese government and its tax authorities have in recent years put a lot of effort in improving the transfer pricing system and its execution. Due to the amount of loss in tax revenue that is believed to be due to transfer pricing measures, the issue is considered to be of outmost importance. The requirement on transfer pricing documentation has been an important issue for MNCs on the Chinese market, especially now when there is an interest levy on adjustments made through an audit. Since the current regulation on documentation is still quite vague, it constitutes an uncertainty for both taxpayers and tax authorities. However, an issuing of a clearer regulation on documentation requirements have long been anticipated but not yet released, although clarifying measures have been taken through the Corporate Income Tax Law and newly issued circulars during 2007.

<p>China has had a remarkable development since the late 1970s, when the Chinese government started opening up its internal market for the outside world. The Chinese legislation and the legal system itself have been developing rapidly to adapt to the new economic environment, however not without complications. Many uncertainties still remain.</p><p>Under the old income tax regime, corporations on the Chinese market were taxed under two different systems, one for domestic enterprises and one for foreign invested enterprises and foreign enterprises. With the new Corporate Income Tax Law, these two systems were merged and new concepts introduced. The new income tax law includes important articles that affect the transfer pricing regime in China. The OECD’s transfer pricing regulations have served as a model when China first started to regulate their transfer pricing, there are consequently similarities between the two.</p><p>Multinational corporations consider the issue of transfer pricing as the most important issue in their international taxation. It is important both from the aspect of being the most effective way to maximize the world profit of the corporation and also in the aspect that an adjustment due to inaccuracies in the corporation’s transfer prices can be expensive. The Chinese transfer pricing system is considered to be young in comparison with other jurisdictions, for example the United States. The Chinese government and its tax authorities have in recent years put a lot of effort in improving the transfer pricing system and its execution. Due to the amount of loss in tax revenue that is believed to be due to transfer pricing measures, the issue is considered to be of outmost importance.</p><p>The requirement on transfer pricing documentation has been an important issue for MNCs on the Chinese market, especially now when there is an interest levy on adjustments made through an audit. Since the current regulation on documentation is still quite vague, it constitutes an uncertainty for both taxpayers and tax authorities. However, an issuing of a clearer regulation on documentation requirements have long been anticipated but not yet released, although clarifying measures have been taken through the Corporate Income Tax Law and newly issued circulars during 2007.</p>