The literature on price setting has developed extensively in the last decade; albeit predominantly focused on the price setting behaviour of developed countries. This study reviews the survey results of price setting behaviours in the manufacturing sector within a developing economy. More than two thirds of manufacturing firms in South Africa purely follow time-dependent pricing rules; which, when compared to the results of surveys conducted in other international studies is almost three times as much, approximately one third of firms allow for components of state-dependent pricing rules.Higher input costs (cost of raw materials and labour costs) are the most important driver behind price increases. Declining market share is the most important factor behind price reductions. Firms review their prices more often than they actually change them. The median firm in this study has only adjusted its prices twice in the last 12 months.Co-ordination failure and temporary shocks are the most important sources of price stickiness. Mark-up pricing and price discrimination are common practices amongst South African manufacturing firms. The quality of a firm‟s product followed by its price is most important in determining the firm‟s level of competitiveness. Manufacturing firms in South Africa generally adopt a barometric price leadership strategy when setting their prices. / Dissertation (MBA)--University of Pretoria, 2012. / Gordon Institute of Business Science (GIBS) / unrestricted

This thesis addresses three relevant macroeconomic issues: (i) why Central Banks behave so cautiously compared to optimal theoretical benchmarks, (ii) do monetary variables add information about future Euro Area inflation to a large amount of non monetary variables and (iii) why national saving and investment are so correlated in OECD countries in spite of the high degree of integration of international financial markets. The process of innovation in the elaboration of economic theory and statistical analysis of the data witnessed in the last thirty years has greatly enriched the toolbox available to macroeconomists. Two aspects of such a process are particularly noteworthy for addressing the issues in this thesis: the development of macroeconomic dynamic stochastic general equilibrium models (see Woodford, 1999b for an historical perspective) and of techniques that enable to handle large data sets in a parsimonious and flexible manner (see Reichlin, 2002 for an historical perspective). Dynamic stochastic general equilibrium models (DSGE) provide the appropriate tools to evaluate the macroeconomic consequences of policy changes. These models, by exploiting modern intertemporal general equilibrium theory, aggregate the optimal responses of individual as consumers and firms in order to identify the aggregate shocks and their propagation mechanisms by the restrictions imposed by optimizing individual behavior. Such a modelling strategy, uncovering economic relationships invariant to a change in policy regimes, provides a framework to analyze the effects of economic policy that is robust to the Lucas'critique (see Lucas, 1976). The early attempts of explaining business cycles by starting from microeconomic behavior suggested that economic policy should play no role since business cycles reflected the efficient response of economic agents to exogenous sources of fluctuations (see the seminal paper by Kydland and Prescott, 1982} and, more recently, King and Rebelo, 1999). This view was challenged by several empirical studies showing that the adjustment mechanisms of variables at the heart of macroeconomic propagation mechanisms like prices and wages are not well represented by efficient responses of individual agents in frictionless economies (see, for example, Kashyap, 1999; Cecchetti, 1986; Bils and Klenow, 2004 and Dhyne et al., 2004). Hence, macroeconomic models currently incorporate some sources of nominal and real rigidities in the DSGE framework and allow the study of the optimal policy reactions to inefficient fluctuations stemming from frictions in macroeconomic propagation mechanisms. Against this background, the first chapter of this thesis sets up a DSGE model in order to analyze optimal monetary policy in an economy with sectorial heterogeneity in the frequency of price adjustments. Price setters are divided in two groups: those subject to Calvo type nominal rigidities and those able to change their prices at each period. Sectorial heterogeneity in price setting behavior is a relevant feature in real economies (see, for example, Bils and Klenow, 2004 for the US and Dhyne, 2004 for the Euro Area). Hence, neglecting it would lead to an understatement of the heterogeneity in the transmission mechanisms of economy wide shocks. In this framework, Aoki (2001) shows that a Central Bank maximizing social welfare should stabilize only inflation in the sector where prices are sticky (hereafter, core inflation). Since complete stabilization is the only true objective of the policymaker in Aoki (2001) and, hence, is not only desirable but also implementable, the equilibrium real interest rate in the economy is equal to the natural interest rate irrespective of the degree of heterogeneity that is assumed. This would lead to conclude that stabilizing core inflation rather than overall inflation does not imply any observable difference in the aggressiveness of the policy behavior. While maintaining the assumption of sectorial heterogeneity in the frequency of price adjustments, this chapter adds non negligible transaction frictions to the model economy in Aoki (2001). As a consequence, the social welfare maximizing monetary policymaker faces a trade-off among the stabilization of core inflation, economy wide output gap and the nominal interest rate. This feature reflects the trade-offs between conflicting objectives faced by actual policymakers. The chapter shows that the existence of this trade-off makes the aggressiveness of the monetary policy reaction dependent on the degree of sectorial heterogeneity in the economy. In particular, in presence of sectorial heterogeneity in price adjustments, Central Banks are much more likely to behave less aggressively than in an economy where all firms face nominal rigidities. Hence, the chapter concludes that the excessive caution in the conduct of monetary policy shown by actual Central Banks (see, for example, Rudebusch and Svennsson, 1999 and Sack, 2000) might not represent a sub-optimal behavior but, on the contrary, might be the optimal monetary policy response in presence of a relevant sectorial dispersion in the frequency of price adjustments. DSGE models are proving useful also in empirical applications and recently efforts have been made to incorporate large amounts of information in their framework (see Boivin and Giannoni, 2006). However, the typical DSGE model still relies on a handful of variables. Partly, this reflects the fact that, increasing the number of variables, the specification of a plausible set of theoretical restrictions identifying aggregate shocks and their propagation mechanisms becomes cumbersome. On the other hand, several questions in macroeconomics require the study of a large amount of variables. Among others, two examples related to the second and third chapter of this thesis can help to understand why. First, policymakers analyze a large quantity of information to assess the current and future stance of their economies and, because of model uncertainty, do not rely on a single modelling framework. Consequently, macroeconomic policy can be better understood if the econometrician relies on large set of variables without imposing too much a priori structure on the relationships governing their evolution (see, for example, Giannone et al., 2004 and Bernanke et al., 2005). Moreover, the process of integration of good and financial markets implies that the source of aggregate shocks is increasingly global requiring, in turn, the study of their propagation through cross country links (see, among others, Forni and Reichlin, 2001 and Kose et al., 2003). A priori, country specific behavior cannot be ruled out and many of the homogeneity assumptions that are typically embodied in open macroeconomic models for keeping them tractable are rejected by the data. Summing up, in order to deal with such issues, we need modelling frameworks able to treat a large amount of variables in a flexible manner, i.e. without pre-committing on too many a-priori restrictions more likely to be rejected by the data. The large extent of comovement among wide cross sections of economic variables suggests the existence of few common sources of fluctuations (Forni et al., 2000 and Stock and Watson, 2002) around which individual variables may display specific features: a shock to the world price of oil, for example, hits oil exporters and importers with different sign and intensity or global technological advances can affect some countries before others (Giannone and Reichlin, 2004). Factor models mainly rely on the identification assumption that the dynamics of each variable can be decomposed into two orthogonal components - common and idiosyncratic - and provide a parsimonious tool allowing the analysis of the aggregate shocks and their propagation mechanisms in a large cross section of variables. In fact, while the idiosyncratic components are poorly cross-sectionally correlated, driven by shocks specific of a variable or a group of variables or measurement error, the common components capture the bulk of cross-sectional correlation, and are driven by few shocks that affect, through variable specific factor loadings, all items in a panel of economic time series. Focusing on the latter components allows useful insights on the identity and propagation mechanisms of aggregate shocks underlying a large amount of variables. The second and third chapter of this thesis exploit this idea. The second chapter deals with the issue whether monetary variables help to forecast inflation in the Euro Area harmonized index of consumer prices (HICP). Policymakers form their views on the economic outlook by drawing on large amounts of potentially relevant information. Indeed, the monetary policy strategy of the European Central Bank acknowledges that many variables and models can be informative about future Euro Area inflation. A peculiarity of such strategy is that it assigns to monetary information the role of providing insights for the medium - long term evolution of prices while a wide range of alternative non monetary variables and models are employed in order to form a view on the short term and to cross-check the inference based on monetary information. However, both the academic literature and the practice of the leading Central Banks other than the ECB do not assign such a special role to monetary variables (see Gali et al., 2004 and references therein). Hence, the debate whether money really provides relevant information for the inflation outlook in the Euro Area is still open. Specifically, this chapter addresses the issue whether money provides useful information about future inflation beyond what contained in a large amount of non monetary variables. It shows that a few aggregates of the data explain a large amount of the fluctuations in a large cross section of Euro Area variables. This allows to postulate a factor structure for the large panel of variables at hand and to aggregate it in few synthetic indexes that still retain the salient features of the large cross section. The database is split in two big blocks of variables: non monetary (baseline) and monetary variables. Results show that baseline variables provide a satisfactory predictive performance improving on the best univariate benchmarks in the period 1997 - 2005 at all horizons between 6 and 36 months. Remarkably, monetary variables provide a sensible improvement on the performance of baseline variables at horizons above two years. However, the analysis of the evolution of the forecast errors reveals that most of the gains obtained relative to univariate benchmarks of non forecastability with baseline and monetary variables are realized in the first part of the prediction sample up to the end of 2002, which casts doubts on the current forecastability of inflation in the Euro Area. The third chapter is based on a joint work with Domenico Giannone and gives empirical foundation to the general equilibrium explanation of the Feldstein - Horioka puzzle. Feldstein and Horioka (1980) found that domestic saving and investment in OECD countries strongly comove, contrary to the idea that high capital mobility should allow countries to seek the highest returns in global financial markets and, hence, imply a correlation among national saving and investment closer to zero than one. Moreover, capital mobility has strongly increased since the publication of Feldstein - Horioka's seminal paper while the association between saving and investment does not seem to comparably decrease. Through general equilibrium mechanisms, the presence of global shocks might rationalize the correlation between saving and investment. In fact, global shocks, affecting all countries, tend to create imbalance on global capital markets causing offsetting movements in the global interest rate and can generate the observed correlation across national saving and investment rates. However, previous empirical studies (see Ventura, 2003) that have controlled for the effects of global shocks in the context of saving-investment regressions failed to give empirical foundation to this explanation. We show that previous studies have neglected the fact that global shocks may propagate heterogeneously across countries, failing to properly isolate components of saving and investment that are affected by non pervasive shocks. We propose a novel factor augmented panel regression methodology that allows to isolate idiosyncratic sources of fluctuations under the assumption of heterogenous transmission mechanisms of global shocks. Remarkably, by applying our methodology, the association between domestic saving and investment decreases considerably over time, consistently with the observed increase in international capital mobility. In particular, in the last 25 years the correlation between saving and investment disappears.

This dissertation consists of three essays on monetary economics. The first two essays have a focus on the zero lower bound on the nominal interest rate (ZLB) and the Great Recession. In the first essay, I investigate optimal discretionary monetary policy under the ZLB in the case of a distorted steady state due to monopoly and taxation. I find that the central bank in a more distorted economy would cut the interest rate less aggressively under a particular adverse demand shock. This occurs because the ZLB is less likely to bind and the economy escapes from the ZLB sooner. In addition, I show that the conventional linear-quadratic method is not accurate when the ZLB binds. In the second essay, I model the role of subprime lending, deleveraging and an incomplete financial market in driving an economy to the liquidity trap with binding ZLB. There are two key features that differentiate my work from the current literature of deleveraging and the ZLB. First, I endogenize the debt limit of borrowing-constrained households by tying it to the market value of collateral assets. Second and more importantly, I allow for subprime lending. I am able to show that the second feature drives the economy to the ZLB more likely under an adverse shock to the credit market. When the ZLB binds, a great recession emerges with a free fall in output and the price level, mostly due to the Fisherian debt deflation that puts more debt burden on the borrowers. The third essay examines the role of habit formation in solving the persistence problem - output response is transient and not hump-shaped under a monetary shock - in the conventional state dependent pricing model. Intuitively, incorporating habit formation makes consumers less aggressive in spending under a shock, resulting in more persistent response of output. With a moderate habit formation, I am able to show that the model produces hump-shaped and very persistent response of output under a monetary growth shock.

Die Dissertation handelt über Wettbewerbsökonomie. Kapitel 1 betrachtet eine Fusion zwischen zwei regulierten Firmen, die in getrennten Märkten agieren und jeweils mit unregulierten Firmen konkurrieren. Die optimale Fusionspolitik für regulierte Firmen hängt von der Intensität des Wettbewerbs zwischen den unregulierten Firmen ab, verschärfter Wettbewerb zwischen den unregulierten Firmen induziert eine mildere Fusionspolitik. Das Gegenteil gilt, wenn die regulierten Firmen in ein wettbewerbsfähiges Marktsegment expandieren und die regulierten und unregulierten Waren komplementär sind. Kapitel 2 untersucht die optimale Fusionspolitik zwischen zwei wettbewerbsfähigen Firmen. Unter den strukturellen Auflagen, die sich am effektivsten herausgestellt haben um einen wirksamen Wettbewerb wiederherzustellen, gibt es eine die sich stark hervorhebt, nämlich die Veräußerung von differenzierten Marken an andere Wettbewerber. Dies ist eine effektive Möglichkeit, um die Marktmacht der neuen Firma zu verringern und sie kann die Möglichkeiten für privat und sozial wünschenswerte Fusionen erhöhen. Vor allem wenn die Güter annähernd perfekt substituierbar sind, ist der Bereich der Effizienzgewinne, die eine Fusion unter Auflagen erlauben, größer. Kapitel 3 untersucht die allgemein etablierte Feststellung, dass Einzelhandelspreise sich schneller anpassen, wenn Input Preise steigen, als wenn sie fallen. Durch die Anwendung eines dynamischen zwei Perioden Preiswettbewerb Modells zeigt sich das Folgende für die Angebotsseite für asymmetrische Preisanpassung: die Existenz von profitablen Lagerungsmöglichkeiten ermöglicht es wettbewerbsfähigen Firmen sich glaubhaft zu verpflichten, ihre Preise umgehend über die marginalen Kosten zu setzen, wenn sie höhere Input Preise antizipieren. Dies lockert den Wettbewerb sodass Firmen positive Gewinne erzielen. Wenn erwartet wird das Input Preise sinken, landen die Firmen im Bertrand Paradoxon und die Preisanpassung erfolgt langsamer. / This thesis is about competition economics. Chapter 1 considers a merger between two regulated firms operating in two separate markets, and in each market there are unregulated competitors. The optimal merger policy for regulated firms depends on the intensity of competition between unregulated firms, fiercer competition between unregulated firms induces a more lenient merger policy. These results are reversed if the regulated firms expand into a competitive segment of the market and the regulated and unregulated goods are complements. Chapter 2 studies the optimal merger policy between two competitive firms. Among the structural remedies which have being treated as the most effective manners to restore effective competition, there is one relevant type, namely, the divestiture of differentiated brands to other competitor(s). It is a powerful tool to lessen the merged entity''s market power and can increase the scope for privately and socially desirable mergers. In particular, when goods are closer to perfect substitutability, the range of the efficiency gains which allows the merger with remedies to be approved is larger. Chapter 3 investigates the well-established observation that retail prices adjust faster when input costs rise than when they fall. From the supply side to asymmetric price adjustments, using a model of two-period dynamic price competition, it shows that the presence of profitable storing allows competitive firms to credibly commit to immediately increase their prices above current marginal costs when they anticipate higher input costs. This relaxes competition and firms earn positive profits. If input costs are expected to decline, the firms are trapped in the Bertrand paradox and price adjustment is slower.

A large theoretical and empirical literature has studied the response in prices to changes in demands and costs. Three of the essays in this thesis are empirical studies of price-setting. The most important reason for studying the properties of price adjustments is the possible link between pricing and the business cycle. One family of models deals with price rigidities. If prices adjust slowly to changes in costs or demand, it will magnify fluctuations in output. A second family of models examines price changes due to changes in intensity of competition. Many of these models build on the idea that changes in demand affect the possibility of maintaining implicit collusion. Cyclical changes in the intensity of competition may cause a cyclical pricing pattern that magnifies fluctuations in output. Another line of research models the effects of liquidity constraints on the business cycle. One possible effect is that prices in markets where consumers have switching costs may increase, if the firms are hit by increased liquidity constraints. As increased liquidity constraints are common in recessions, prices will get a counter-cyclical tendency, which magnifies fluctuations in output. Another reason for studying price-setting patterns is that they can give an indication of the form of interaction between competing firms, which are of importance for competition policy. The fourth essay models sex discrimination formally. It shows that it is possible that sex discrimination in the labor market might be due to self-fulfilling sex stereotypes on the distribution of time out for child care between men and women. Both an even and an uneven distribution of time out for child care are possible equilibria in the model. The four essays can be read separatelyEssay 1 Price Responses to Seasonal Demand Changes in the Swedish Gasoline MarketA common idea in a number of papers on cyclical pricing is that implicit price collusion may be affected by changes in demand. In these models, tacit collusion is modeled as a game where agents balance gains from deviating from the collusive price, thereby gaining a short-run profit, against the gains from maintaining collusion in future periods. If demand fluctuates, the gains from deviating is high in periods of high demand; collusion may still be sustainable, however, if the collusive price is allowed to vary with demand. A lower price in high demand states reduces the gains from deviating, since it reduces the gain from each unit sold in these demand states. Hence, in order to equalize the profit from deviating and the profit from sticking to the implicit agreement, the price must move in the opposite direction to demand. Changes in demand can, naturally, be correlated with other factors affecting the price, such as cost changes. Thus, prices do not necessarily fall when demand increases in the data. According to the theory the, however, increase in demand should add a tendency to lower prices in order to make implicit collusion sustainable. The basic idea that changes in demand should affect prices if firms are engaged in implicit collusion has been employed in a number of papers, with different models for different assumptions on the pattern of demand changes. The demand for gasoline in Sweden follows a seasonal cycle, with demand being 42 percent higher in July than in January. Haltiwanger and Harrington provide a theory for implicit collusion over deterministic cycles, such as the seasonal cycle. Borenstein and Shepard (1996) tested Haltiwanger and Harrington’s model on the American gasoline retail market and found support for the theory. In this essay the model is tested for Swedish data, but no support for this theory is found. It is also investigated whether the effects on margins of the demand fluctuations induced by tax increases are compatible with theories of implicit collusion, but this is found not to be the case.Essay 2 Price Adjustments by a Gasoline Retail ChainEssay 2 is joint with Marcus Asplund and Richard Friberg. Stickiness of prices is an important building block in many business cycle models. This has spurred an empirical literature on price adjustments. Different types of price rigidities have different policy implications. Price setting can be state dependent, e.g. prices are adjusted when costs have changed by at least some minimal amount since the last price adjustment, or time-dependent e.g. adjusted once a week or once a year. Another issue is whether prices are equally rigid downwards as upwards. The second essay examines price responses in the Swedish gasoline retail market to changes in the Rotterdam spot price of gasoline, exchange rates and taxes. The main results are that cost changes are not fully passed through in the short run, but gradually moves towards the long-run equilibrium. Prices are stickier downwards than upwards. There is a minimum absolute size of price changes. Only very limited evidence of time-dependent price setting is found.Essay 3 Prices, Margins and Liquidity Constraints: Swedish Newspapers 1990-1996Essay 3 is written with Marcus Asplund and Niklas Strand. Chevalier and Scharfstein (1996) provide a model where consumer switching costs in combination with liquidity constraints give rise to a counter-cyclical tendency in prices. Customer stocks can be viewed as an investment, when consumers have switching costs when changing suppliers. Firms can exploit captured customers by setting a high price to raise short-run profits. However, a high price will induce consumers to search for alternatives, and customers once lost are costly to win back. Liquidity constraints, for instance in recessions, may force firms to sacrifice long-run profits for short-run gains. In this case, firms may have to cut back on investments in customer stocks by raising prices. Using firm level data from the Swedish daily newspaper industry, we test the effects of liquidity constraints on prices in markets with consumer switching costs. The newspaper industry is of particular interest, since firms set prices in two markets, the subscription market, where switching costs are high, and the advertising market, where switching costs are low. With accounting data from newspaper firms we can, by solvency, broadly categorize them as being more or less liquidity constrained. When Sweden enters a recession at the beginning of the nineties, we find a relative increase in subscription prices and margins for liquidity constrained firms. This is not the case for advertising prices, however. The results support the theory.Essay 4 Statistical Discrimination and Sex Stereotypes in the Labor MarketTime out for child care is unevenly distributed between the sexes. Parental leave benefits are usually exclusively given to the mother or distributed to both parents according to their choice. In Sweden, one month is reserved for each parent, however. One reason for this is to give the child better contact with both parents, but increased equality between the sexes in the labor market has also been put forward as an argument. This argument implicitly rests on the idea that sex stereotypes create sex discrimination, and that sex discrimination affects the distribution of time out for child care between the sexes. Essay 4 investigates if the uneven distribution of time out for child care can be explained by self-fulfilling sex stereotypes. It provides a model of distribution of time out for child care based on statistical discrimination and human capital investments. The model has three equilibria. In one equilibrium, time out for child care is evenly distributed between the sexes. In the second equilibrium, there is full specialization. The third equilibrium is an intermediate case, where time out for child care is unevenly distributed without full specialization There are no differences in ability or variance of ability between the sexes, the only differences between the equilibria are the self-fulfilling expectations of firms and workers. / Diss. (sammanfattning) Stockholm : Handelshögsk., 2001

Submitted by Mariana Monte Alegre de Paiva (mmapaiva@hotmail.com) on 2018-01-16T15:25:28Z No. of bitstreams: 1 tese.pdf: 1826581 bytes, checksum: a1ad1d51ebdcc40ec1744c71de92b05e (MD5) / Approved for entry into archive by Thais Oliveira (thais.oliveira@fgv.br) on 2018-01-16T16:24:43Z (GMT) No. of bitstreams: 1 tese.pdf: 1826581 bytes, checksum: a1ad1d51ebdcc40ec1744c71de92b05e (MD5) / Made available in DSpace on 2018-01-16T19:05:27Z (GMT). No. of bitstreams: 1 tese.pdf: 1826581 bytes, checksum: a1ad1d51ebdcc40ec1744c71de92b05e (MD5) Previous issue date: 2017-12-18 / O trabalho pretende examinar as principais controvérsias tributárias decorrentes dos mecanismos contratuais de ajuste de preço, usualmente utilizados em contratos de aquisição de participação societária, no contexto de operações societárias de fusões e aquisições (também denominadas em conjunto como “transações”). Especialmente em grandes transações, é bastante comum que as partes envolvidas, com base nos resultados da auditoria e da diligência legal, discordem em relação a alguns aspectos da própria avaliação financeira da empresa (“empresa-alvo”) ou a respeito de passivos e contingências específicos envolvidos no negócio. Para alcançar um consenso, as partes podem estabelecer condições, ajustes e limitações ao pagamento do preço. Assim, o preço poderá variar dependendo de certos eventos, sofrendo alterações – complementações ou até reduções – conforme as cláusulas contratuais acordadas. Existem diversos mecanismos contratuais que vem sendo aprimorados ao longo do tempo para flexibilizar a determinação do preço, dentre os quais destacamos aqueles utilizados com mais frequência na prática: earn out; holdback e escrow, ajustes de preço e indenizações. No caso brasileiro, é possível verificar que esses mecanismos contratuais são usados, às vezes, sem tanta atenção aos seus desdobramentos no campo tributário. Como a legislação tributária existente não regulamenta de forma totalmente precisa e completa os impactos desses mecanismos contratuais, a sua implementação pode eventualmente gerar problemas para o comprador e o vendedor perante o Fisco. Diante disso, a intenção desse trabalho é abordar as principais controvérsias tributárias envolvendo tais mecanismos. Para tanto, é preciso comentar a respeito do propósito e do funcionamento desses mecanismos, abordar sua natureza jurídica e determinar os seus respectivos impactos no campo tributário, levando em consideração a legislação vigente e a jurisprudência. O trabalho destacará as questões polêmicas envolvidas, indicando pontos de atenção que podem gerar possíveis questionamentos pelo Fisco. O trabalho ainda propõe sugestões e recomendações práticas na utilização de cada mecanismo contratual e aponta alguns cuidados essenciais na redação dos contratos e nos procedimentos adotados para mitigar os riscos tributários. / This thesis aims to examine the main tax controversies related to the contractual mechanisms of price adjustment commonly used in share sales and purchase agreements in the context of merger and acquisition transactions (“M&A transactions”). Especially in large transactions, based on the due diligence results, the parties usually disagree in relation to some aspects of the valuation of the target company or in respect to certain liabilities involved in the deal. In order to reach an agreement, the parties may establish some conditions, adjustments or restrictions in respect to the purchase price payment. Hence, the purchase price may be modified, either through increases or reductions, depending on certain events and considering the actual clauses agreed by the parties. There are several contractual mechanisms that have been improved over time to enable the purchase price determination, among which we stress those used more frequently, namely: earn out, holdback / escrow account, other price adjustments and indemnification. In Brazil, these contractual mechanisms are often used without much attention to the tax impacts. Their use may lead to disputes between Tax Authorities and the parties to the acquisition, mainly because the current tax legislation does not address the impacts of such mechanisms in a precise and complete manner. In view of the above, this thesis aims to examine the main tax controversies involved in those contractual mechanisms. For that purpose, it is relevant to first comment on the business and economic purpose and the function of these main mechanisms, and then analyze their legal nature, considering the current tax legislation and case law. Finally, the thesis covers the contentious tax aspects involved, highlighting the issues that may eventually be challenged by Tax Authorities. The thesis also provides some practical suggestions and recommendations on the use of each contractual mechanism, as well as points out some aspects to be considered when drafting clauses and procedures to be adopted to mitigate additional tax risks.

This thesis addresses three relevant macroeconomic issues: (i) why<p>Central Banks behave so cautiously compared to optimal theoretical<p>benchmarks, (ii) do monetary variables add information about<p>future Euro Area inflation to a large amount of non monetary<p>variables and (iii) why national saving and investment are so<p>correlated in OECD countries in spite of the high degree of<p>integration of international financial markets.<p><p>The process of innovation in the elaboration of economic theory<p>and statistical analysis of the data witnessed in the last thirty<p>years has greatly enriched the toolbox available to<p>macroeconomists. Two aspects of such a process are particularly<p>noteworthy for addressing the issues in this thesis: the<p>development of macroeconomic dynamic stochastic general<p>equilibrium models (see Woodford, 1999b for an historical<p>perspective) and of techniques that enable to handle large data<p>sets in a parsimonious and flexible manner (see Reichlin, 2002 for<p>an historical perspective).<p><p>Dynamic stochastic general equilibrium models (DSGE) provide the<p>appropriate tools to evaluate the macroeconomic consequences of<p>policy changes. These models, by exploiting modern intertemporal<p>general equilibrium theory, aggregate the optimal responses of<p>individual as consumers and firms in order to identify the<p>aggregate shocks and their propagation mechanisms by the<p>restrictions imposed by optimizing individual behavior. Such a<p>modelling strategy, uncovering economic relationships invariant to<p>a change in policy regimes, provides a framework to analyze the<p>effects of economic policy that is robust to the Lucas'critique<p>(see Lucas, 1976). The early attempts of explaining business<p>cycles by starting from microeconomic behavior suggested that<p>economic policy should play no role since business cycles<p>reflected the efficient response of economic agents to exogenous<p>sources of fluctuations (see the seminal paper by Kydland and Prescott, 1982}<p>and, more recently, King and Rebelo, 1999). This view was challenged by<p>several empirical studies showing that the adjustment mechanisms<p>of variables at the heart of macroeconomic propagation mechanisms<p>like prices and wages are not well represented by efficient<p>responses of individual agents in frictionless economies (see, for<p>example, Kashyap, 1999; Cecchetti, 1986; Bils and Klenow, 2004 and Dhyne et al. 2004). Hence, macroeconomic models currently incorporate<p>some sources of nominal and real rigidities in the DSGE framework<p>and allow the study of the optimal policy reactions to inefficient<p>fluctuations stemming from frictions in macroeconomic propagation<p>mechanisms.<p><p>Against this background, the first chapter of this thesis sets up<p>a DSGE model in order to analyze optimal monetary policy in an<p>economy with sectorial heterogeneity in the frequency of price<p>adjustments. Price setters are divided in two groups: those<p>subject to Calvo type nominal rigidities and those able to change<p>their prices at each period. Sectorial heterogeneity in price<p>setting behavior is a relevant feature in real economies (see, for<p>example, Bils and Klenow, 2004 for the US and Dhyne, 2004 for the Euro<p>Area). Hence, neglecting it would lead to an understatement of the<p>heterogeneity in the transmission mechanisms of economy wide<p>shocks. In this framework, Aoki (2001) shows that a Central<p>Bank maximizing social welfare should stabilize only inflation in<p>the sector where prices are sticky (hereafter, core inflation).<p>Since complete stabilization is the only true objective of the<p>policymaker in Aoki (2001) and, hence, is not only desirable<p>but also implementable, the equilibrium real interest rate in the<p>economy is equal to the natural interest rate irrespective of the<p>degree of heterogeneity that is assumed. This would lead to<p>conclude that stabilizing core inflation rather than overall<p>inflation does not imply any observable difference in the<p>aggressiveness of the policy behavior. While maintaining the<p>assumption of sectorial heterogeneity in the frequency of price<p>adjustments, this chapter adds non negligible transaction<p>frictions to the model economy in Aoki (2001). As a<p>consequence, the social welfare maximizing monetary policymaker<p>faces a trade-off among the stabilization of core inflation,<p>economy wide output gap and the nominal interest rate. This<p>feature reflects the trade-offs between conflicting objectives<p>faced by actual policymakers. The chapter shows that the existence<p>of this trade-off makes the aggressiveness of the monetary policy<p>reaction dependent on the degree of sectorial heterogeneity in the<p>economy. In particular, in presence of sectorial heterogeneity in<p>price adjustments, Central Banks are much more likely to behave<p>less aggressively than in an economy where all firms face nominal<p>rigidities. Hence, the chapter concludes that the excessive<p>caution in the conduct of monetary policy shown by actual Central<p>Banks (see, for example, Rudebusch and Svennsson, 1999 and Sack, 2000) might not<p>represent a sub-optimal behavior but, on the contrary, might be<p>the optimal monetary policy response in presence of a relevant<p>sectorial dispersion in the frequency of price adjustments.<p><p>DSGE models are proving useful also in empirical applications and<p>recently efforts have been made to incorporate large amounts of<p>information in their framework (see Boivin and Giannoni, 2006). However, the<p>typical DSGE model still relies on a handful of variables. Partly,<p>this reflects the fact that, increasing the number of variables,<p>the specification of a plausible set of theoretical restrictions<p>identifying aggregate shocks and their propagation mechanisms<p>becomes cumbersome. On the other hand, several questions in<p>macroeconomics require the study of a large amount of variables.<p>Among others, two examples related to the second and third chapter<p>of this thesis can help to understand why. First, policymakers<p>analyze a large quantity of information to assess the current and<p>future stance of their economies and, because of model<p>uncertainty, do not rely on a single modelling framework.<p>Consequently, macroeconomic policy can be better understood if the<p>econometrician relies on large set of variables without imposing<p>too much a priori structure on the relationships governing their<p>evolution (see, for example, Giannone et al. 2004 and Bernanke et al. 2005).<p>Moreover, the process of integration of good and financial markets<p>implies that the source of aggregate shocks is increasingly global<p>requiring, in turn, the study of their propagation through cross<p>country links (see, among others, Forni and Reichlin, 2001 and Kose et al. 2003). A<p>priori, country specific behavior cannot be ruled out and many of<p>the homogeneity assumptions that are typically embodied in open<p>macroeconomic models for keeping them tractable are rejected by<p>the data. Summing up, in order to deal with such issues, we need<p>modelling frameworks able to treat a large amount of variables in<p>a flexible manner, i.e. without pre-committing on too many<p>a-priori restrictions more likely to be rejected by the data. The<p>large extent of comovement among wide cross sections of economic<p>variables suggests the existence of few common sources of<p>fluctuations (Forni et al. 2000 and Stock and Watson, 2002) around which<p>individual variables may display specific features: a shock to the<p>world price of oil, for example, hits oil exporters and importers<p>with different sign and intensity or global technological advances<p>can affect some countries before others (Giannone and Reichlin, 2004). Factor<p>models mainly rely on the identification assumption that the<p>dynamics of each variable can be decomposed into two orthogonal<p>components - common and idiosyncratic - and provide a parsimonious<p>tool allowing the analysis of the aggregate shocks and their<p>propagation mechanisms in a large cross section of variables. In<p>fact, while the idiosyncratic components are poorly<p>cross-sectionally correlated, driven by shocks specific of a<p>variable or a group of variables or measurement error, the common<p>components capture the bulk of cross-sectional correlation, and<p>are driven by few shocks that affect, through variable specific<p>factor loadings, all items in a panel of economic time series.<p>Focusing on the latter components allows useful insights on the<p>identity and propagation mechanisms of aggregate shocks underlying<p>a large amount of variables. The second and third chapter of this<p>thesis exploit this idea.<p><p>The second chapter deals with the issue whether monetary variables<p>help to forecast inflation in the Euro Area harmonized index of<p>consumer prices (HICP). Policymakers form their views on the<p>economic outlook by drawing on large amounts of potentially<p>relevant information. Indeed, the monetary policy strategy of the<p>European Central Bank acknowledges that many variables and models<p>can be informative about future Euro Area inflation. A peculiarity<p>of such strategy is that it assigns to monetary information the<p>role of providing insights for the medium - long term evolution of<p>prices while a wide range of alternative non monetary variables<p>and models are employed in order to form a view on the short term<p>and to cross-check the inference based on monetary information.<p>However, both the academic literature and the practice of the<p>leading Central Banks other than the ECB do not assign such a<p>special role to monetary variables (see Gali et al. 2004 and<p>references therein). Hence, the debate whether money really<p>provides relevant information for the inflation outlook in the<p>Euro Area is still open. Specifically, this chapter addresses the<p>issue whether money provides useful information about future<p>inflation beyond what contained in a large amount of non monetary<p>variables. It shows that a few aggregates of the data explain a<p>large amount of the fluctuations in a large cross section of Euro<p>Area variables. This allows to postulate a factor structure for<p>the large panel of variables at hand and to aggregate it in few<p>synthetic indexes that still retain the salient features of the<p>large cross section. The database is split in two big blocks of<p>variables: non monetary (baseline) and monetary variables. Results<p>show that baseline variables provide a satisfactory predictive<p>performance improving on the best univariate benchmarks in the<p>period 1997 - 2005 at all horizons between 6 and 36 months.<p>Remarkably, monetary variables provide a sensible improvement on<p>the performance of baseline variables at horizons above two years.<p>However, the analysis of the evolution of the forecast errors<p>reveals that most of the gains obtained relative to univariate<p>benchmarks of non forecastability with baseline and monetary<p>variables are realized in the first part of the prediction sample<p>up to the end of 2002, which casts doubts on the current<p>forecastability of inflation in the Euro Area.<p><p>The third chapter is based on a joint work with Domenico Giannone<p>and gives empirical foundation to the general equilibrium<p>explanation of the Feldstein - Horioka puzzle. Feldstein and Horioka (1980) found<p>that domestic saving and investment in OECD countries strongly<p>comove, contrary to the idea that high capital mobility should<p>allow countries to seek the highest returns in global financial<p>markets and, hence, imply a correlation among national saving and<p>investment closer to zero than one. Moreover, capital mobility has<p>strongly increased since the publication of Feldstein - Horioka's<p>seminal paper while the association between saving and investment<p>does not seem to comparably decrease. Through general equilibrium<p>mechanisms, the presence of global shocks might rationalize the<p>correlation between saving and investment. In fact, global shocks,<p>affecting all countries, tend to create imbalance on global<p>capital markets causing offsetting movements in the global<p>interest rate and can generate the observed correlation across<p>national saving and investment rates. However, previous empirical<p>studies (see Ventura, 2003) that have controlled for the effects<p>of global shocks in the context of saving-investment regressions<p>failed to give empirical foundation to this explanation. We show<p>that previous studies have neglected the fact that global shocks<p>may propagate heterogeneously across countries, failing to<p>properly isolate components of saving and investment that are<p>affected by non pervasive shocks. We propose a novel factor<p>augmented panel regression methodology that allows to isolate<p>idiosyncratic sources of fluctuations under the assumption of<p>heterogenous transmission mechanisms of global shocks. Remarkably,<p>by applying our methodology, the association between domestic<p>saving and investment decreases considerably over time,<p>consistently with the observed increase in international capital<p>mobility. In particular, in the last 25 years the correlation<p>between saving and investment disappears.<p> / Doctorat en sciences économiques, Orientation économie / info:eu-repo/semantics/nonPublished

Globaliseringen bidrar till en ökad världshandel och medför även ett växande antal gränsöverskridande koncerninterna transaktioner inom multinationella företag. Prissättningen av transaktioner vilka vidtas mellan närstående företag måste ske i enlighet med armlängdsprincipen som om transaktionerna vidtagits mellan två oberoende företag. Skattemyndigheterna kan justera internpriserna i slutet av beskattningsåret i de fall de anser att internprissättningen avviker från armlängdsprincipen och marknadsmässiga villkor. Utöver inkomstbeskattning åläggs företagen att betala tullavgifter i samband med transaktioner vidtagna med närstående företag etablerade utanför EU. I likhet med skattemyndigheterna granskar tullmyndigheterna företagens importpriser i syfte att säkerställa att parternas närståenderelation inte påverkat prissättningen. Båda myndigheterna arbetar således för samma mål, att upprätthålla prissättningens förenlighet med marknadsmässiga villkor. Skatte- och tullmyndigheterna tillämpar dock olika prissättningsmetoder i syfte att uppnå målet. Inkomstskatten baseras på företagens totala inkomster, relaterade till transaktionerna och tullavgiften beräknas baserat på varje specifik transaktion och vara. Det faktum att myndigheterna inkluderar olika tillgångar i de respektive beskattningsunderlagen kan medföra att de bedömer värdet av samma transaktion olika. Varierande bedömningar av samma pris kan vidare medföra krav på olika prisjusteringar i syfte att uppnå marknadsmässig prissättning. Prisjusteringar kan leda till onödiga skattetillägg och liknande straffavgifter. Det föreligger svårigheter för multinationella företag att bestämma transaktionspriser som uppfyller båda myndigheternas i syfte att undvika straffavgifter.     Problematiken är ännu relativt ouppmärksammad av företag i världen. I amerikansk praxis framkommer att möjligheterna är små för företag att förlita sig på dokumentation upprättad för internprissättning, i syfte att styrka tullavgifter och tullvärde. Det är således betydelsefullt att företag upprättar dokumentationer för både internprissättning och tullvärde för att undvika straffavgifter. Dokumentationen utgör huvudsakligt bevis och ligger till grund för bedömningen av huruvida företagen uppfyllt bevisbördan avseende prisernas förenlighet med marknadsmässiga villkor. Företagen bör etablera en öppen kommunikation med de respektive myndigheterna i syfte att minimera risker för missförstånd eventuella framtida prisjusteringar. Det är bättre att förekomma än att förekommas. / The ‘arm’s length principle’ is fundamental to transfer pricing and cross-border intercompany transactions. The principle states that the prices charged for transactions of goods between related parties must be the same as if the parties were unrelated. Simply, the price needs to equal market values. If the Tax Authority finds the pricing to be inconsistent with the arm’s length principle, the price may be adjusted. In relation to cross-border intercompany transactions outside of the EU, companies have to pay customs duty and regard customs values. The Customs Authorities work to ensure that the price has not been influenced by the intercompany relationship. Thus, the Tax and Customs Authorities share the same goal, which is to ensure that the transaction price is consistent with market values. However, the methods of pursuing the goal differ. The Tax Authorities determine the amount of income tax based on the company’s total revenues deriving from cross-border intragroup transactions. The Customs Authorities on the contrary determine the amount of taxable income based on the value of every specific imported product. The authorities usually consider different values and assets when determining the amount of taxable income. Therefore the same transaction price may be evaluated differently by the Tax and Customs authorities. Price adjustments may be made if the transaction price is considered to differ in relation to market values. Thus, the companies may be obligated to pay tax surcharges or similar monetary penalties. The authorities’ different assessments of the same transaction price may result in difficulties for multinational enterprises in their efforts of meeting both requirements. The problem is regarded in varying degrees in different countries. In American precedent the court has determined the opportunities to be low for companies to depend on transfer pricing documentation when supporting customs value. It is important for companies to keep detailed documentation of both transfer pricing and customs valuation. The documentation serve as vital evidence when proving the compatibility of transaction prices with market values. Companies should also establish good communications with the authorities in order to prepare them for potential future price adjustments.  Prevention is better than cure.