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<p>This dissertation examines the economic effects of alternative taxation policies on household consumption and investment decisions under uncertainty. A consideration of the alternative approaches to a theory of decision-making under uncertainty (Part 1) reveals that maximisation of expected utility is consistent with rational behaviour in a world of uncertainty. Howeve~, an alternative criterion of minimising the probability that the risky outcome will fall below some critical level (the "safety-:first" principle) may also appear as rational. Consequently, we consider both types of behavioural models.</p> <p>In a single-period framework (Part 2), the particular decision process we consider is that of an individual allocating his initial wealth between riskless assets with a secure rate of return and risky assets with a random rate of return. We then investigate the effects of taxation on risk-taking (both social and private).</p> <p>We observe that a chance-constrained portfolio choice model can be interpreted as a reasonable description of the investor's concern for safety, and that the qualitative results regarding portfolio separation (implying that optimal risky asset ratios are independent of initial wealth) and the effects of taxation (suggesting that a proportional or a lump-sum tax with full loss offsets encourages a movement towards the riskier assets) are the same both for a normal distribution of asset returns and the alternative assumption of a lognormal securities market.</p> <p>Part 2 also investigates the effects of a simple progressive tax schedule (a linear tax with a marginal tax rate which applies both above and below an exemption level) on risk~taking. Assuming only that the investor is a risk-avertor and that the risky asset is superior (or alternatively, assuming only decreasing absolute risk-aversion), we show that linearly progressive taxation of investment income (with full loss offsets) encourages the demand for the risky asset, and that exempting risky capital gains (losses) from taxation discourages (total) risktaking. We further show that a linearly progressive tax on investment income leads to greater risk-taking than a flat rate proportional tax where both of these taxes lead to equal losses of expected utility for the investor, or alternatively, where they yield the same expected revenue.</p> <p>Part 3 considers models of portfolio choice and consumption allocation in an intertemporal context. Apart from taxation of non-asset income and the case where the rate of return on riskless investment is zero, the kind of a priori restrictions we have placed on single-period preferences are no longer sufficient to determine the effects of taxation. However, given the relative nagnitudes of the income elasticities of consumption and of the risky asset demand, assumptions on the riskaversion measures allow us to determine these results. This analyssis, therefore, also indicates the kind of empirical knoftledge that is required in order to meaningfully discuss the implications of alternative taxation policies.</p> <p>We further pursue the framework of intertemporal consumption portfolio allocation to analyze the long debated issue of the differential incidence of a consumption (expenditure) tax rather than an (investment) income tax. We find that under some reasonably interpretable conditions, the differential incidence of a consumption tax is to encourage risktaking and discourage saving more effectively than an investment income tax. This result is in conflict with the general consensus in the literature that an income tax discourages saving as compared to a consumption tax. We, therefore, conclude in this context that with the introduction of uncertainty, the implications of fiscal policy are modified in an important way.</p> / Doctor of Philosophy (PhD)

Tato práce se zabývá úlohou odhadování prostorové funkce z hlediska regrese pomocí Gaussovských procesů (GPR) za současné nejistoty tréninkových pozic (pozic senzorů). Nejdříve je zde popsána teorie v pozadí GPR metody pracující se známými tréninkovými pozicemi. Tato teorie je poté aplikována při odvození výrazů prediktivní distribuce GPR v testovací pozici při uvážení nejistoty tréninkových pozic. Kvůli absenci analytického řešení těchto výrazů byly výrazy aproximovány pomocí metody Monte Carlo. U odvozené metody bylo demonstrováno zlepšení kvality odhadu prostorové funkce oproti standardnímu použití GPR metody a také oproti zjednodušenému řešení uvedenému v literatuře. Dále se práce zabývá možností použití metody GPR s nejistými tréninkovými pozicemi v~kombinaci s výrazy s dostupným analytickým řešením. Ukazuje se, že k dosažení těchto výrazů je třeba zavést značné předpoklady, což má od počátku za následek nepřesnost prediktivní distribuce. Také se ukazuje, že výsledná metoda používá standardní výrazy GPR v~kombinaci s upravenou kovarianční funkcí. Simulace dokazují, že tato metoda produkuje velmi podobné odhady jako základní GPR metoda uvažující známé tréninkové pozice. Na druhou stranu prediktivní variance (nejistota odhadu) je u této metody zvýšena, což je žádaný efekt uvážení nejistoty tréninkových pozic.

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Purpose – The purpose of this thesis is to investigate how film festivals use project management techniques to manage uncertain resources. Design/methodology/approach – Fourteen case studies are used to explore the project management techniques used by film festivals across Europe. An extensive theoretical framework brings together a number of key fields for the first time and provides an informative background to the study. Based on this theoretical framework a conceptual model was developed, ‘the film festival ‘smoothie’ model’, which provides a guide for data collection and analysis. The research focuses on traditional and contemporary project management techniques, but also contextual factors that impact upon the project management of film festivals. Findings – The findings show that a creative, reactive and flexible approach to project management is vital within film festival organisations and supports earlier research calling for a rethinking of project management to consider the growing presence of ‘soft projects’ and contextual factors of projects. Furthermore, it highlights interesting characteristics and lessons that can be learnt from film festivals, warranting further investigation, since film festivals are ‘interesting repositories of knowledge that provide rich data for organisation and management researchers’ (Rüling and Strandgaard Pedersen, 2010, p. 322) and that cultural projects can be source of inspiration for refreshing project management techniques (Cwikla and Jalocha, 2015). Research limitations – The research gives an initial picture of the European panorama and presents studies of film festivals from Italy, Portugal, United Kingdom and Sweden. Originality/value – Our research contributes to a detailed understanding of the project management processes within film festivals and the way film festivals minimise the negative impact of uncertain resources, and exercise control without stifling creativity. Practical implications - This thesis intends to be descriptive, and therefore does not provide solid ground for practical recommendations of a recipe for success for project management within film festivals. The research does, however, provide evidence of the interesting project management approaches within film festival organisations and therefore advocates further research to be done in this field.

La création photographique fonde et se fonde sur des conditions et des conduites d’émergence et de développement, que l’image ne saisit pas toujours, ou dont elle choisit de se dessaisir. Notre travail propose d’explorer les modalités et les enjeux du dévoilement des instances poïétiques dans l’image photographique. Par le biais d’une mise en tension des termes propres à l’atelier et au laboratoire photographique, nous situons ces deux espaces d’actions au coeur d’un territoire plastique ouvert aux interactions et aux circulations des éléments en jeu dans les divers processus et procédures suivis ou tracés. Notre pratique plastique engage le procédé photographique vers des dispositifs archaïques et vers de nouvelles fonctionnalités qui privilégient les voies de l’élaboration plastique, de l’expérience et de la réflexivité. Les motifs réflexifs mettent en question les fictions en construction et en éclairent en même temps les fondations ou les fondements. Le processus ne tend plus vers la restitution d’un résultat visé, mais vers des visions singulières qui retracent les expériences menées et vécues dans le laboratoire-atelier. Les ressorts poïétiques de la dissémination, de la sédimentation et de la fiction participent d’un chantier d’instauration plastique et photographique qu’ils donnent à voir et qu’ils redéfinissent sans cesse. / Creative photography implies and is based on conditions and emerging and developing behaviours, that the image does not always seize or chooses to impart. Our work aims to explore the modalities and goals of poietic disclosure inside the image. Through the opposition of terms specific to the studio and photographic laboratory, we set both spaces at the heart of an artistic territory, open to interactions and flows of the elements involved in the various processes and procedures followed or traced. Our fin art practice engages the photographic process to archaic devices and new functionalities that focus on developing artistic work, experience, and reflexivity. The reflexive patterns disturb fictions in construction, and point to their foundation. The process does not tend anymore towards the restoration of a preexistent outcome, but rather to singularities reflecting the experiments made or experienced in the photographic studio. Poietic methods of dissemination, sedimentation and fiction are part of en establishing fine art and photographic site, they present and remodel.

Product and system designers face many challenges in the modern world. Designing products that will be subject to emerging or uncertain requirements can be one of the most significant of these challenges. A major risk associated with emerging or uncertain requirements is premature obsolescence. Large-scale, complex engineered systems, such as, aircraft, spacecraft, large seagoing vessels, communication and power systems are especially susceptible to this issue. However, this challenge is not limited to only large-scale complex systems. Even relatively simple products can suffer from premature obsolescence and even failure to be initially accepted, due to inadequately understood or changing requirements. One approach to mitigating this challenge is to increase the product's flexibility and adaptability, thus enabling it to evolve or adapt to meet unforeseen requirements. The flexibility of a product to adapt to new or changing requirements has been shown to increase acceptance rates and reduce the risk of premature obsolescence. Methodologies to accomplish this include product family platform design, transformable product design, reconfigurable product design and modular product design. The literature presents several techniques to aid designers, such as design structure matrices (DSM), change propagation analysis, change modes and effects analysis (CMEA), metrics and guides. These techniques address the challenge by seeking to understand and manage the relationships and interfaces between functions or components within the design. While these are excellent techniques, they do not provide quantifiable functions or models for the design alternatives. Quantifiable functions and models are of value to designers, because they enable numerical design aids. Numerical optimization techniques have been shown to aid designers in efficiently determining appropriate design parameters. This dissertation identifies, analyzes and presents new techniques, which are based on designed-in excess capabilities and to which numerical optimization can be directly applied. There are four parts to the dissertation. In the first part, a technique is presented for determining the relative value of a product, which has been over-designed (excess capabilities) to address future requirements versus redesigning the product once the future requirements emerge. It is shown that in many cases the over-design approach provides greater benefit. In the second part, a numerical metric for the evolvability of a product based on excess capability is presented. An important result of this metric is that the evolvability of a product and the usability of each excess capability can be numerically determined. The third part presents a technique to design products for increased adaptability, based on optimally designed-in excess. Deterministic, and non-deterministic conditions are included in this optimization. Once a numerical model of the design is available the issue of uncertain requirements can be mitigated by directly focusing on the uncertainties. In the fourth part, a technique employing optimization and sensitivity analysis is used to systematically and efficiently guide the designer toward minimizing or eliminating the most critical uncertainties.

Analyzing and modeling data is a well established research area and a vast variety of different methods have been developed over the last decades. Most of these methods assume fixed positions of data points; only recently uncertainty in data has caught attention as potentially useful source of information. In order to provide a deeper insight into this subject, this thesis concerns itself with the following essential question: Can information on uncertainty of feature values be exploited to improve in silico modeling? For this reason a state-of-art random forest algorithm is developed using Matlab R. In addition, three techniques of handling uncertain numeric features are presented and incorporated in different modified versions of random forests. To test the hypothesis six realworld data sets were provided by AstraZeneca. The data describe biochemical features of chemical compounds, including the results of an Ames test; a widely used technique to determine the mutagenicity of chemical substances. Each of the datasets contains a single uncertain numeric feature, represented as an expected value and an error estimate. Themodified algorithms are then applied on the six data sets in order to obtain classifiers, able to predict the outcome of an Ames test. The hypothesis is tested using a paired t-test and the results reveal that information on uncertainty can indeed improve the performance of in silico models.

<p>Analyzing and modeling data is a well established research area and a vast variety of different methods have been developed over the last decades. Most of these methods assume fixed positions of data points; only recently uncertainty in data has caught attention as potentially useful source of information. In order to provide a deeper insight into this subject, this thesis concerns itself with the following essential question: Can information on uncertainty of feature values be exploited to improve in silico modeling? For this reason a state-of-art random forest algorithm is developed using Matlab R. In addition, three techniques of handling uncertain numeric features are presented and incorporated in different modified versions of random forests. To test the hypothesis six realworld data sets were provided by AstraZeneca. The data describe biochemical features of chemical compounds, including the results of an Ames test; a widely used technique to determine the mutagenicity of chemical substances. Each of the datasets contains a single uncertain numeric feature, represented as an expected value and an error estimate. Themodified algorithms are then applied on the six data sets in order to obtain classifiers, able to predict the outcome of an Ames test. The hypothesis is tested using a paired t-test and the results reveal that information on uncertainty can indeed improve the performance of in silico models.</p>

This thesis is based on the regulations found in the OECD model and the OECD TP guidelines concerning the arm’s length principle. The core of the arm’s length principle is that transactions between associated enterprises should be treated the same as transactions between independent enterprises. This principle can be found in Article 9 of the OECD model. One transaction that may fall within the scope of Article 9 of the OECD model is business restructuring. Business restructuring was previously an unregulated TP area but with the new OECD TP guidelines, from 2010, regulations have been formulated. The aim with thesis is therefore to examine how the arm’s length principle should be applied to the new guidelines for business restructurings of intangibles with an uncertain value at the time of the restructuring. In order to answer the question set out in this thesis some of the factors that affect the application of the arm’s length principle have been examined separately. Firstly the arm’s length principle that is the generally accepted TP method used by both taxpayers and tax administrations in order to find a fair price for transactions between associated enterprises. The principle seeks to identify the controlled transaction and thereafter find a comparable uncontrolled transaction that is similar to the transaction performed between the associated enterprises. The second part examined the meaning of the term business restructuring according to the new guidelines since there is no other legal or general definition. Business restructurings are defined as cross-border redeployments of functions assets and risks, performed by MNEs. As long as a transaction falls within this definition it will be subjected to the arm’s length principle for tax purposes. The third part examined intangibles since that also lack a general definition. The identification and valuation of intangibles is a complex and uncertain thing to do for both taxpayers and tax administrations. When applying the arm’s length principle it is however found that the issue of identification of what constitutes and intangible may be unnecessary. The aspect that should be considered is instead the value of the intangible or more precise, the value that independent enterprises would have agreed upon in a similar situation. The applicability of the arm’s length principle to business restructurings of intangibles with an uncertain value at the time of the restructuring should be found by performing a comparability analysis. In order to perform a comparability analysis, the controlled transaction firstly has to be identified. Thereafter, a comparable uncontrolled transaction needs to be found. An equivalent uncontrolled transaction may not be found in all cases and it should in those cases be examined what independent enterprises would have done if they had been in a comparable situation. The arm’s length principle should be applied to business restructurings of intangibles with an uncertain value in the same manner as for any other uncontrolled transaction. The issues for this type of a transaction become the identification of what constitutes a business restructuring and also how to determine a fair value for the intangibles. The OECD TP guidelines lack some guidance as to the issues that can occur when a comparable uncontrolled transaction cannot be found. This creates an unsatisfactory guesswork for both taxpayers and tax administrations when trying to determine what independent enterprises would have done if they had been in a similar situation. This creates an unnecessary uncertainty when trying to apply the arm’s length principle.