This thesis uses innovative approaches to analyse energy policy interventions aimed at enhancing the environmental sustainability of energy use as well as its consequential welfare implications. First, we examine the relationship between energy efficiency improvement and CO2 emissions at the macro level. We use the Index Decomposition Analysis to derive energy efficiency by separating out the impact of shifts in economic activity on energy intensity. We then employ econometric models to relate energy efficiency and CO2 emissions accounting for non-economic factors such as consumers lifestyle and attitudes. The applications for 13 OPEC and 30 OECD countries show that at the country-group and individual country level, increase in energy intensity for OPEC is associated with both deteriorations in energy efficiency and shifts towards energy-intensive activities. The model results suggest that the reduction in energy efficiency in general go in tandem with substantial increases in CO2 emissions. The decline in energy intensity for OECD can be attributed mainly to improvements in energy efficiency which is found to compensate for the impact on CO2 emissions of income changes. The results confirm the empirical relevance of energy efficiency improvements for the mitigation of CO2 emissions. The method developed in this chapter further enables the separate assessment of non-economic behavioural factors which according to the results exert a non-trivial influence on CO2 emissions. Secondly, having empirically confirmed the relationship between energy efficiency improvements and CO2 emission at the macro level in Chapter 2, we investigate potential underlying drivers of energy efficiency improvements taking into account potential asymmetric effects of energy price change in Chapter 3. This is crucial for designing effective and efficient policy measures that can promote energy efficiency. In addition to the Index Decomposition Analysis used to estimate the economy-wide energy efficiency in Chapter 2, we also use Stochastic Frontier Analysis and Data Envelop Analysis as alternative methods. The driving factors are examined using static and dynamic panel model methods that account for both observed and unobserved country heterogeneity. The application for 32 OECD countries shows that none of the three methods leads to correspondence in term of ranking between energy efficiency estimates and energy intensity at the country level corroborating the criticism that energy intensity is a poor proxy for energy efficiency. The panel-data regression results using the results of the three methods show similarities in the impacts of the determinants on the energy efficiency levels. Also, we find insignificant evidence of asymmetric effects of total energy price but there is proof of asymmetry using energy specific prices. Thirdly, in Chapter 4 we offer an improved understanding of the impacts to expect of abolishing fuel price subsidy on fuel consumption, and also of the welfare and distributional impacts at the household level. We develop a two-step approach for this purpose. Key aspect of the first step is a two-stage budgeting model to estimate various fuel types elasticities using micro-data. Relying on these estimates and the information on households expenditure shares for different commodities, the second step estimates the welfare (direct and indirect) and distributional impacts. The application for Nigeria emphasises the relevance of this approach. We find heterogeneous elasticities of fuel demand among household groups. The distributional impact of abolishing the kerosene subsidy shows a regressive welfare loss. Although we find a progressive loss for petrol, the loss gap between the low- and high-income groups is small relative to the loss gap from stopping kerosene subsidy, making the low-income groups to suffer a higher total welfare loss. Finally, from the highlighted results, we draw the following concluding remarks in chapter 5. Energy efficiency appears a key option to mitigate CO2 emissions but there is also a need for additional policies aiming for behavioural change; energy specific prices and allowing for asymmetry in analysing the changes in energy efficiency is more appropriate and informative in formulating reliable energy policies; the hypothesis that only the rich would be worse-off from fuel subsidy removal is rejected and the results further suggest that timing of the fuel subsidy removal would be crucial as a higher international oil price will lead to higher deregulated fuel price and consequently, larger welfare loss.

<p>In 2001 Sweden founded the government agency of VINNOVA, named after the OECD-endorsed innovation system concept. Criticising the common assumption that countries are passive and uncritical recipients of the approaches promoted by the OECD, this dissertation tries to show that Swedish actors were in fact very active and strategic as they contributed to the national adoption of the concept.</p><p>With inspiration from conceptual history and Quentin Skinner’s analysis of the rhetorical use of concepts, this study focuses on the research funding reform process between 1995 and 2001, investigating how actors trying to defend the contested institution of sectoral research used the innovation system concept to rhetorically legitimise their project. To compare these uses with earlier ways of discussing innovation in Sweden, the innovation debate that arose in relation to the industrial crises of the 1970s and 1990s has also been studied.</p><p>It was found that the early Swedish innovation debate had paid little attention to the university sector. When <i>Research 2000</i> in 1998 proposed that researcher-dominated research councils should be given control over sectoral research funding, a coalition in favour of industrially relevant research mobilised to protect its influence over research funding. The concept was now appropriated and used to rhetorically reframe the universities as part of a system with the main function of promoting innovations. By using the concept it was also possible to draw on the legitimacy offered by the OECD and science.</p>

In 2001 Sweden founded the government agency of VINNOVA, named after the OECD-endorsed innovation system concept. Criticising the common assumption that countries are passive and uncritical recipients of the approaches promoted by the OECD, this dissertation tries to show that Swedish actors were in fact very active and strategic as they contributed to the national adoption of the concept. With inspiration from conceptual history and Quentin Skinner’s analysis of the rhetorical use of concepts, this study focuses on the research funding reform process between 1995 and 2001, investigating how actors trying to defend the contested institution of sectoral research used the innovation system concept to rhetorically legitimise their project. To compare these uses with earlier ways of discussing innovation in Sweden, the innovation debate that arose in relation to the industrial crises of the 1970s and 1990s has also been studied. It was found that the early Swedish innovation debate had paid little attention to the university sector. When Research 2000 in 1998 proposed that researcher-dominated research councils should be given control over sectoral research funding, a coalition in favour of industrially relevant research mobilised to protect its influence over research funding. The concept was now appropriated and used to rhetorically reframe the universities as part of a system with the main function of promoting innovations. By using the concept it was also possible to draw on the legitimacy offered by the OECD and science.

Den svenska CFC-lagstiftningens förenlighet med internationella åtaganden i form av skatteavtal baserade på OECD:s modellavtal har varit ett omdiskuterat ämne inom svensk lagstiftning under mer än ett decennium. Tvistigheten kring CFC-lagstiftningens förenlighet med skatteavtal förekommer också i andra medlemsstater av OECD. Den svenska CFC-lagstiftningen tillämpas sedan 1 januari 2004. Rättsföljden av lagstiftningen framgår av 39 a kap. 13 § IL. Syftet med CFC-lagstiftningen är att förhindra en erosion av den svenska skattebasen. Utan CFC-lagstiftning skulle en skattebetalare kunna etablera företag i lågbeskattde jurisdiktioner enbart i syfte att minska den totala skattebördan. Genom att tillämpa CFC-lagstiftningen beskattas en delägare löpande för sitt innehav i den utländska juridiska personen. Enligt förarbeten är CFC-lagstiftningen förenlig med de svenska skatteavtalen. Lagstiftaren lägger stor vikt vid ordalydelsen i kommentarerna till OECD:s modellavtal. OECD rekommenderar medlemsstaterna att tillämpa lagstiftningen. Uppsatsen visar att CFC-lagstiftningen är förenlig med skatteavtal baserade på OECD:s modellavtal. Syftet med skatteavtal är att förhindra juridisk dubbelbeskattning. CFC-lagstiftningen ger upphov till ekonomisk dubbelbeskattning. Diskussionen gällande CFC-lagstiftningens förenlighet med skatteavtal beror på kommentarernas rättsliga verkan samt därtill framställda anmärkningar. / The Swedish CFC legislation and its compatibility with international commitments in form of tax treaties based on OECD Model have been disputed in the Swedish legislation for more than a decade. Whether CFC legislation is compatible with tax treaties is also disputed in many other Member States of the OECD. The Swedish controlled foreign company legislation entered into force on 1 January 2004. The legal effect of the legislation is covered in chapter 39 a, section 10 of the Swedish Income Tax Act. The basic purpose of CFC legislation is to prevent an erosion of the Swedish tax basis. Without CFC regulations a taxpayer would be free to establish companies in low-tax jurisdictions for the sole purpose of reducing the overall tax burden. By applying the legislation a Swedish resident shareholder will be taxed on all the income that is attributed from a foreign subsidiary, regardless of when the income is distributed. In the preparatory works the government argues that the CFC legislation is compatible with Sweden’s tax treaties, based on OECD Model. The government’s opinion is mostly based on the statement in the Commentary to the OECD Model. The legislation is recommended by the OECD. This thesis concludes that the CFC legislation is compatible with tax treaties based on the OECD Model. The purpose with tax treaties is to avoid juridical double taxation. The CFC-legislation gives rise to economic double taxation. Therefore the legislation can be justified. The discussion of the CFC legislation compatible with tax treaties depends of the relevance of the Commentary but also on observations given to the Commentaries.

<p>Den svenska CFC-lagstiftningens förenlighet med internationella åtaganden i form av skatteavtal baserade på OECD:s modellavtal har varit ett omdiskuterat ämne inom svensk lagstiftning under mer än ett decennium. Tvistigheten kring CFC-lagstiftningens förenlighet med skatteavtal förekommer också i andra medlemsstater av OECD.</p><p>Den svenska CFC-lagstiftningen tillämpas sedan 1 januari 2004. Rättsföljden av lagstiftningen framgår av 39 a kap. 13 § IL. Syftet med CFC-lagstiftningen är att förhindra en erosion av den svenska skattebasen. Utan CFC-lagstiftning skulle en skattebetalare kunna etablera företag i lågbeskattde jurisdiktioner enbart i syfte att minska den totala skattebördan. Genom att tillämpa CFC-lagstiftningen beskattas en delägare löpande för sitt innehav i den utländska juridiska personen.</p><p>Enligt förarbeten är CFC-lagstiftningen förenlig med de svenska skatteavtalen. Lagstiftaren lägger stor vikt vid ordalydelsen i kommentarerna till OECD:s modellavtal. OECD rekommenderar medlemsstaterna att tillämpa lagstiftningen.</p><p>Uppsatsen visar att CFC-lagstiftningen är förenlig med skatteavtal baserade på OECD:s modellavtal. Syftet med skatteavtal är att förhindra juridisk dubbelbeskattning. CFC-lagstiftningen ger upphov till ekonomisk dubbelbeskattning. Diskussionen gällande CFC-lagstiftningens förenlighet med skatteavtal beror på kommentarernas rättsliga verkan samt därtill framställda anmärkningar.</p> / <p>The Swedish CFC legislation and its compatibility with international commitments in form of tax treaties based on OECD Model have been disputed in the Swedish legislation for more than a decade. Whether CFC legislation is compatible with tax treaties is also disputed in many other Member States of the OECD.</p><p>The Swedish controlled foreign company legislation entered into force on 1 January 2004. The legal effect of the legislation is covered in chapter 39 a, section 10 of the Swedish Income Tax Act. The basic purpose of CFC legislation is to prevent an erosion of the Swedish tax basis. Without CFC regulations a taxpayer would be free to establish companies in low-tax jurisdictions for the sole purpose of reducing the overall tax burden. By applying the legislation a Swedish resident shareholder will be taxed on all the income that is attributed from a foreign subsidiary, regardless of when the income is distributed.</p><p>In the preparatory works the government argues that the CFC legislation is compatible with Sweden’s tax treaties, based on OECD Model. The government’s opinion is mostly based on the statement in the Commentary to the OECD Model. The legislation is recommended by the OECD.</p><p>This thesis concludes that the CFC legislation is compatible with tax treaties based on the OECD Model. The purpose with tax treaties is to avoid juridical double taxation. The CFC-legislation gives rise to economic double taxation. Therefore the legislation can be justified. The discussion of the CFC legislation compatible with tax treaties depends of the relevance of the Commentary but also on observations given to the Commentaries.</p>

Multinational enterprises have been widely accused of using aggressive tax planning schemes to avoid paying tax all over the world. The purpose of this study is to analyse the methods used by multinational enterprises in the context of business restructurings to shift profits from high to low tax jurisdictions. Transactions between associated entities have generally been manipulated by applying non-arm’s length prices to these transactions, as well as devising agreements where the economic substance varies from the form of the transaction. The study aims to investigate some of the practical challenges faced by tax administrators in the application of the arm’s length principle. The study was conducted based on a literature review, as well as analysing specific examples reported in newspapers where multinational enterprises have used aggressive tax planning schemes to shift profits. International case law was also analysed to evaluate some of the factors considered by the courts in the determination of the arm’s length price. It was found that multinational enterprises definitely use aggressive tax planning schemes to shift profits. The practical challenges in the determination of arm’s length prices, complexity of the transactions involved, as well as a lack of resources, especially in the developing nations, are some of the factors that cause tax administrators to battle to find a solution to deter and detect these schemes. Other methods such as the unitary taxation method and the country by country reporting concept have been brought forward as alternatives to the arm’s length principle. These alternatives have been proposed in an effort to find a solution to the challenges posed by the arm’s length principle. Specific measures have also been recommended for developing nations’ tax administrators to resolve the issues that they currently experience in this context. / Thesis (MCom (South African and International Taxation))--North-West University, Potchefstroom Campus, 2013

Multinational enterprises have been widely accused of using aggressive tax planning schemes to avoid paying tax all over the world. The purpose of this study is to analyse the methods used by multinational enterprises in the context of business restructurings to shift profits from high to low tax jurisdictions. Transactions between associated entities have generally been manipulated by applying non-arm’s length prices to these transactions, as well as devising agreements where the economic substance varies from the form of the transaction. The study aims to investigate some of the practical challenges faced by tax administrators in the application of the arm’s length principle. The study was conducted based on a literature review, as well as analysing specific examples reported in newspapers where multinational enterprises have used aggressive tax planning schemes to shift profits. International case law was also analysed to evaluate some of the factors considered by the courts in the determination of the arm’s length price. It was found that multinational enterprises definitely use aggressive tax planning schemes to shift profits. The practical challenges in the determination of arm’s length prices, complexity of the transactions involved, as well as a lack of resources, especially in the developing nations, are some of the factors that cause tax administrators to battle to find a solution to deter and detect these schemes. Other methods such as the unitary taxation method and the country by country reporting concept have been brought forward as alternatives to the arm’s length principle. These alternatives have been proposed in an effort to find a solution to the challenges posed by the arm’s length principle. Specific measures have also been recommended for developing nations’ tax administrators to resolve the issues that they currently experience in this context. / Thesis (MCom (South African and International Taxation))--North-West University, Potchefstroom Campus, 2013

Mass., Harvard Univ., Dep. of Economics, Diss.--Cambridge, 2003. / Kopie, ersch. im Verl. UMI, Ann Arbor, Mich. - Enth. 3 Beitr.

Univ., Diss.--Osnabrück, 2000.

This paper aims to describe the dynamics of objective health and welfare in five populations, from the year 2000 to 2009, qua a methodological study. It proposes a three step approach to ensure the validity criteria in the conducted research process: firstly, to identify the relevant variables as predictors of the two phenomena, empiric studies and sociological theories by Esping-Andersen (1999) Nussbaum (1999, 2000, 2011), were consulted. This (with the data availability) frames the study to include five related categories of objective health and welfare indicators, including (1) demographic (e. g. life expectancy (LE), total fertility rate (TFR)), (2) child-welfare (i. e. under-five mortality rate (U5MR), (3) welfare services (immunization coverage and prevalence of tuberculosis (TB)), (4) education, and (5) indicators on health expenditure (HE). The applied theoretical frame–in a combination with the four posed research questions–indicates a need of an overall methodological approach that is primary quantitative. The data analysis follows an observational epidemiological type that is descriptive study, to analyse the indicators in five populations and two control groups. The study obtains descriptive data from three data bases, which are selected upon a qualitative analysis, to account for their validity and reliability. Further data analysis is strengthened qua the inclusion of the two control groups of populations, when appropriate. Since it wasn’t possible to compare data on populations across time, due to different data production methodologies. Main findings indicate that HE, immunization, TFR, male and female LE, U5MR and school enrolment, tend to diverge between and within the five populations, expressed in absolute and relative terms. The comparison of the estimated data for the five populations with the two control groups of populations, shows that most objective health and welfare indicators tend to converge, (within categories 1, 2 and 3, except TFR) when expressed in absolute and relative terms. When estimated data is analysed in the light of two sociological theories, it is evident that the existing gap between male and female LE, U5MR, and HE indicators can improve further. / B