O teste de frequência de micronúcleos (FMN) in vitro é uma das metodologias de escolha no desenvolvimento de testes de segurança toxicológica. Para o seu desenvolvimento no trabalho foram realizadas modificações da técnica convencional, relativas ao substrato de cultivo das células e à sua coloração. As culturas celulares foram desenvolvidas diretamente nas lâminas e a coloração foi realizada com laranja de acridina (AO) ao invés da coloração segundo Giemsa. Foram utilizados controles positivos com potenciais clastogênico (mitomicina C, benzo[a]pireno) e aneugênico (colchicina), recomendados pela OCDE (Organização para Cooperação e Desenvolvimento Econômico). Como moléculas-teste, foram utilizados compostos cuja associação a isótopos radioativos compõem radiofármacos produzidos pelo IPEN. DOTATATO e Ubiquicidina foram testados em diferentes concentrações proporcionais às concentrações máximas utilizadas em pacientes adultos. Para tanto, foram realizadas diluições correspondentes às concentrações 0,1X, 1X e 10X e culturas de células CHO-KI foram expostas a estas concentrações para ensaios de citotoxicidade e FMN. Nenhuma das concentrações induziu citotoxicidade significativa. Para análise de FMN, foram contabilizadas todas as células mononucleadas e multinucleadas até atingir a contagem de 1000 células binucleadas, com ou sem micronúcleos. Desta maneira foi possível analisar a frequência de micronúcleos e o índice de proliferação (CBPI). As concentrações dos fármacos em teste (0,1X, 1X e 10X) não induziram agressão às células. Nenhuma das concentrações revelou citotoxicidade ou genotoxicidade, ou ainda qualquer alteração no ciclo celular em comparação aos controles, comprovando sua segurança conforme os parâmetros exigidos pelas normas internacionais. Os resultados mostraram também uma boa concordância entre a comparação das leituras realizadas por analistas independentes, com pequenas discrepâncias discutíveis, e boa correlação com resultados obtidos com a coloração convencional. Desta maneira as modificações realizadas na técnica de FMN mostraram potencial para cumprir todos os quesitos como teste pré-clínico. / The in vitro micronucleus frequency test (FMN) is one method of choice in the development of toxicological safety tests. For its development, this work carried out modifications of the conventional technique regarding the cultivation substrate of the cells and staining for microscopy evaluation. The cell cultures were grown directly on slides, and staining was performed with acridine orange (AO) instead of the classical Giemsa staining. Positive controls were used for potential clastogenic (mitomycin C, benzo [a] pyrene) and aneugenic (colchicine) effects, recommended by the OECD (Organization for Economic Cooperation and Development). As test molecules, compounds were used whose association with radioactive isotopes make up radiopharmaceuticals produced by IPEN. DOTATATE and Ubiquicidine were tested at different concentrations proportional to the maximum concentrations used in adult patients. Therefore, corresponding to the concentrations dilutions were performed 0.1X, 1X and 10X cultures and CHO-KI cells were exposed to these concentrations for cytotoxicity assays and FMN. None of the concentrations induced significant cytotoxicity. For FMN analysis, it was recorded every mononuclear cells and multinucleated up to 1000 counts binucleated cells with or without micronuclei. In this way it was possible to analyze the frequency of micronuclei and the proliferation index (CBPI). The concentrations of the test drug (0.1X, 1X and 10X) did not induce aggression to cells. None of the concentrations showed cytotoxicity and genotoxicity, or any changes in cell cycle compared to controls, demonstrating their safety according to the parameters required by international standards. The results also showed good agreement between the comparison of readings by independent analysts, with minor discrepancies debatable, and good correlation comparing to classical staining technique. Thus the changes made in FMN technique showed potential to fulfill all requirements as preclinical test.

<p><strong>Background</strong></p><p>International transfer pricing has been a highlighted issue during the last decades as country after country has revised and introduced new transfer pricing laws as a respond to the expanded globalization. Several countries are adopting similar approaches and the prime guiding principles are provided by the Organization for Economic Co-Operation (OECD). The international law as well as the laws of all 30 member countries is based on the OECD Guidelines.</p><p><strong>Purpose</strong></p><p>The purpose of this master’s thesis is to describe differences and similarities regarding the transfer pricing regulations in China and Sweden and to explain how a Swedish multinational enterprise (MNE) have to utilize and adjust their transfer pricing strategy when trading with group companies in China. The results then conclude into a step model for strategic transfer pricing.</p><p><strong>Result</strong></p><p>The differences between the regulations are mainly uncovered in the definition of associated parties and associated interest. The differences in the regulations are thus of minor importance and does not affect a Swedish MNE to any major extent. The challenging area is instead the conflict between the tax authority and the customs service. To enable this study, three Swedish MNEs are used as a case study. We discovered that all had very different transfer pricing strategies even though they are within the same industry and two of them even within same range of products. Out of this we made the conclusion that the strategy chosen is not just depending on what product or service you trade with but also the aim and purpose, the range of products and the structure of the company. International transfer pricing is a very complex issue that goes into nearly all business operations. The concept of transfer pricing can thus be broken down and simplified if the demands from the company is minor.</p>

This thesis analyzes the product cycles of five different product groups within the Swedish machinery export during the time period 1964-2003. The result is that even though Sweden is a preferable region to launch new products and adopt new technologies, according to the product cycle models, the production is approaching a decreasing regional specialisation.

The object of study is the international knowledge assessments and attention is given to the International Association for the Evaluation of Educational Achievement (IEA) and the Organisation for Economic Co-Operation and Development (OECD). As a way to explain the content in the international knowledge assessments an historical exposition about the IEA and OECD is written. International knowledge assessment is studied in relation to the national and international perspective, but also in relation to educational governing. By doing this concepts of globalisation and internationalisation are discussed as communication patterns. It is then possible to understand organisations like the IEA and OECD as institutionalised communication channels. If this is done it is possible to discuss globalisation and internationalisation as something else than an inevitable endpoint. Through institutionalised communication channels international knowledge assessments appear in national contexts and some observations can be made. The first one is that international knowledge assessments reformulate relationships. In this the educational actors on national levels are observed. These actors are involved in a struggle for power over definition in what should be seen as educational problems and solutions. In this the actors and the educational system they represent tries to strive and communicate modernity, strong international competitiveness and development. Secondly the actors when reformulating the international ideologies into national contexts transform extern priorities to internal priorities. Thirdly an international ideology might be understood as isomorphic ideology. When the isomorphic ideology impacts national contexts it has to be mediated. The mediation is driven by the fact that it is constituted by the national context, but also by the different roles the actors take or are given. The notion about isomorphic ideology is investigated more properly in Appendix I, in relation to UNESCO, and it is declared that international cooperations are part of nations urge to make their educational institutions more effective. In relation to the conclusion from Appendix I international knowledge assessments are interpreted as a technological/instrumental method for making the production process more effective. When the international knowledge assessments come down in national contexts some empirical reactions can be discussed. This is analysed from examples taken from the Swedish context, but these results are also in relation to the contexts in Denmark, Norway and the Netherlands. In the study examples are given on how international knowledge assessments are given meaning by political, administrative and media actors. It is primarily three results that can be uplifted. International knowledge assessments are used as an arena for communication in which arguments can be fetched and discussions can be made. International knowledge assessments are also used as present point descriptions, and point of departure for descriptions of educational vision of the future. And finally they are used for legitimising or repudiating politics of education.

Background International transfer pricing has been a highlighted issue during the last decades as country after country has revised and introduced new transfer pricing laws as a respond to the expanded globalization. Several countries are adopting similar approaches and the prime guiding principles are provided by the Organization for Economic Co-Operation (OECD). The international law as well as the laws of all 30 member countries is based on the OECD Guidelines. Purpose The purpose of this master’s thesis is to describe differences and similarities regarding the transfer pricing regulations in China and Sweden and to explain how a Swedish multinational enterprise (MNE) have to utilize and adjust their transfer pricing strategy when trading with group companies in China. The results then conclude into a step model for strategic transfer pricing. Result The differences between the regulations are mainly uncovered in the definition of associated parties and associated interest. The differences in the regulations are thus of minor importance and does not affect a Swedish MNE to any major extent. The challenging area is instead the conflict between the tax authority and the customs service. To enable this study, three Swedish MNEs are used as a case study. We discovered that all had very different transfer pricing strategies even though they are within the same industry and two of them even within same range of products. Out of this we made the conclusion that the strategy chosen is not just depending on what product or service you trade with but also the aim and purpose, the range of products and the structure of the company. International transfer pricing is a very complex issue that goes into nearly all business operations. The concept of transfer pricing can thus be broken down and simplified if the demands from the company is minor.

Purpose: The overall purpose of this thesis is to provide an analysis of the effects of the documentation requirements on transfer pricing and provide a clearer picture of the documentation requirements in transfer pricing. Furthermore, the purpose is to analyze whether the chosen method of Superfos is adequate related to the new regulations. Background: In 2007, new regulations concerning the documentation of transfer pricing was enacted in Swedish law based on OECD guidelines. This change has led to new internal guidelines for companies regarding their transfer pricing work since the requirements apply to both Swedish owned companies and foreign owned companies. Furthermore, with this change, a great uncertainty about the requirements is shared by companies. Method: This thesis has been conducted as a qualitative case study with Superfos as the case company. A deductive approach has been used and the collection of data consists of both primary and secondary data. Primary in the form of an interview with the finance manager at Superfos and secondary through the use of the Swedish tax authority's stated guidelines concerning transfer pricing as well as books, journals and databases. Conclusion: In the conclusion we present a clarifying model of the documentation in transfer pricing based on the data collected for this thesis. In six steps, a clarifying picture of the overview, company structure, transactions identification, functional analysis, comparability analysis and results is provided.

This master’s thesis has analyzed the issues multinational enterprises (MNE) have when determining the arm’s length price from intra group services rendered from a group service center (GSC). The thesis is based on the recommendations from the Organization for Economic Co-operation and Development (OECD), and the legislations in Sweden, Germany, USA, and Denmark. There are several factors that could cause issues for services rendered from a GSC. GSCs render services to the members of a MNE. These types of services are often managerial, supervisory, marketing, or other kinds of services, which are preformed more efficiently if centralized in the MNE rather than if each member of the MNE would perform the services themselves. The research has shown three specific issues that have caused problems for MNEs: When is a service chargeable? Is the applied method for charging appropriate? And, how should the remuneration be determined? The concerned countries have different rules and regulations towards dealing with these issues, which have caused problems for MNE operating in these countries. There is no other category of transaction that has caused as much disagreement between taxpayers and tax authorities as intra group services. Countries seem to have different approaches towards when services are chargeable, which in situations create disputes between taxpayers and the countries’ tax authorities. The appropriate method for charging is dependent of the concerned countries. Three of the countries have a negative attitude towards indirect charging, while one has no preference. Consequently, this has caused problems for MNE to price services. Three of the countries apply the OECD’s recommendations, when determine the appropriate pricing method. OECD has a hierarchy of the methods, whereas USA applies the best method rule, which means that they have no preference over a certain pricing method. The most common methods for pricing services are the cost plus method and the transactional net margin method. However, there are situations where some of the countries do not approve a profit element in the charge. In these situations, the OECD‘s recommendations do not provide a clear and straight answer, whereas the US Regulations have very strict and clear regulations when a service should be charged without a profit element. There could be many factors to why countries have different interpretations: ambiguous recommendations from the OECD; subjective opinions from governments, tax authorities and courts; protectionism; language barriers; accounting standards; the differences in the legal value of the OECD recommendations; and probably other factors which has not been considered. Inferentially, the OECD should be more open to a “US approach”, by giving more clear, precise and direct recommendations. A “US approach” gives more predictability to practitioners. Direct, clear and precise recommendations will give less room for interpretation, thus, less confusion in practice. Even if this has to be accepted by countries it should lead to less confusion and hopefully decrease double taxation for MNEs.

No description available.

Globalization and neo-liberal practices have influenced education and schooling in various ways, particularly through curricula. As a result, interest in elementary school, particularly kindergarten, education has been generated by supranational organizations; specifically the Organization for Economic Co-operation and Development (OECD) and the United Nations Educational, Scientific and Cultural Organization (UNESCO), as well as international organizations such as the European Union and numerous federal and provincial governments, including the Canadian, Ontario and Hellenic governments. This research explores how democratic citizenship education is reflected in kindergarten curricula in Ontario, Canada and Hellas, Greece. Because of growing concerns with democratic citizenship education, in this study, I have analyzed and compared the kindergarten education curricula of Ontario and Hellas in terms of democratic citizenship education and how it is reflected in their respective curricula. I analyzed supplementary and supportive reports, guides and other educational documents about democratic citizenship education published by supranational and international organizations. In order to accomplish this, I utilized a critical pedagogic perspective through Critical Discourse Analysis. In addition, important concerns about citizenship education in kindergarten are discussed and recommendations for curriculum studies are provided. This study is significant in its exploration of the ways that democratic citizenship education is being reflected in kindergarten curricula in Ontario and Hellas and in the revelation of similarities and differences between them, as well as within a global context.

This thesis analyzes the bank-specific, industry-specific and macroeconomic determinants of bank profitability (ROA) in 31 OECD Countries between 2000 and 2009 using a panel data. Each country