Regulating multinational enterprises (MNEs) transactions to minimise tax avoidance through transfer pricing : case of Zimbabwe

Abstract in English, Afrikaans and ZuluIn 2016, Zimbabwe introduced specific transfer pricing legislation to prevent abusive tax strategies by taxpayers. This study uses a qualitative interpretive inquiry to assess the adequacy of the new transfer pricing regime. This study contributes to the body of knowledge in that it explores transfer pricing as a tax avoidance tool, a concept that is at its nascent stage in academic taxation literature. Furthermore, it addresses a methodological gap by employing a qualitative inquiry in an area that is predominated by quantitative research. Indepth interviews and document review were used to gather data, and deductive content analysis was employed with the aid of ATLAS.ti 8™. This study confirms previous findings that tax consultants play a significant role in the compliance decisions of Multinational Enterprises (MNEs) through the examination of the exploitative strategies practiced by these MNEs. The comparison of the OECD and UN transfer pricing guidelines in search for the applicability of international guidelines to Zimbabwe’s specific needs helped uncover the contemporary dilemmas in global standards versus domestic standards. This study responds to the knowledge gap regarding the transfer pricing phenomenon in Zimbabwe through the lenses of an under-explored three-layered rationality concept; legal, implementation and exploitative rationality. The argument maintained in this study is that this rationality trichotomy is a useful lens to understand transfer pricing as a tax avoidance tool, and that international standards are not universal and so each country’s unique situation should be addressed at a domestic level.Zimbabwe het in 2016 bepaalde oordragprysingswetgewing ingestel om onregmatige belastingstrategieë deur belastingbetalers te voorkom. Hierdie studie het ’n kwalitatief-interpretatiewe ondersoek gebruik om die toereikendheid van die nuwe oordragprysingsregime te assesseer. Die studie lewer ’n bydrae tot die kennismateriaal omdat dit oordragprysing as ’n belastingvermydingsinstrument ondersoek, ’n konsep wat in sy kinderskoene in akademiese belastingliteratuur staan. Dit verken ook ’n metodologiese gaping deur ’n kwalitatiewe ondersoek te gebruik op ’n gebied wat deur kwantitatiewe navorsing oorheers word. Omvattende onderhoude en dokumentbeoordelings is gebruik om data in te samel en deduktiewe inhoudsontleding is met behulp van ATLAS.ti 8™ gedoen. Hierdie studie bevestig vorige bevindinge dat belastingkonsultante ’n baie belangrike rol speel by die nakomingsbesluite van multinasionale ondernemings (MNO’s), gebaseer op die ondersoek van die uitbuitende strategieë wat deur hierdie MNO’s beoefen word. ’n Vergelyking van die Organisasie vir Ekonomiese Samewerking en Ontwikkeling (OESO) en die Verenigde Nasies (VN) se oordragprysingsriglyne om die toepaslikheid van internasionale riglyne ten opsigte van Zimbabwe se bepaalde behoeftes te bepaal, het gehelp om die eietydse dilemmas van globale standaarde versus huishoudelike standaarde bloot te lê. Hierdie studie stem ooreen met die kennisgaping rakende die oordragprysingsverskynsel in Zimbabwe deur deur die lens van ’n onderontgindedrielaag-rasionaliteitskonsep, naamlik wetlike, implementerings- en uitbuitende rasionaliteit, te kyk. Die studie voer aan dat hierdie rasionaliteitsdrieledigheid ’n nuttige manier is om oordragprysing as ’n belastingvermydingsinstrumente te verstaan, dat internasionale standaarde nie universeel is nie en dat elke land se unieke situasie derhalwe op ’n huishoudelike vlak aangespreek moet word.Ngonyaka we-2016, izwe laseZimbabwe lithula imithetho ebhekene ngqo nokwedluliselwa kwezezimali zentengiselwano ukuvimbela ukusetshenziswa ngendlela esakuhlukumeza amasu ezentela ngabakhokhintela. Lolu cwaningo lusetshenziselwa uphenyo olukhombisa ukuhumusha okuphathelene nobungaki bento ukuze luhlolisise ukudluliselwa kwesikhathi sokuphatha esisha ekudlulisweni kokubekwa kwamanani emali. Ucwaningo lunomethelela olwazini olufanele ngokuthi lihlola ukubekwa kwamanani njengethuluzi eligwema ukukhokhwa kwentela, njengomqondo osesesigabeni sokuqala ukukhula ezifundweni zemibhalo yezentela. Ngaphezu kwalokho, sikhuluma ngegebe elikhombisa indlela yokwenza izinto ngokusebenzisa uphenyo olukhombisa ubungako bento endaweni egxile ocwaningweni olubheke obungako bento. Ukuthola ulwazi ngalokhu kuye kwasetshenziswa izinhlolokhono ezijulile kanye nokubuyekezwa kwemiqulu yamabhuku, kanye nokusetshenziswa kokuhlaziya okuqukethwe okuphunguliwe ngokubambisana nosizo le-ATLAS.ti 8™. Lolu cwaningo luqinisekisa okutholakale ngaphambilini okubonisa ukuthi abeluleki bezentela badlala indima ebalulekile ezinqumweni zokuthobela imithetho yezinkampani zamazwe angaphandle ngokusekelwe ekuhlolweni kokuxhashazwa kwamasu enziwa yizo izinkampani zamazwe angaphandle. Ukuqhathaniswa kwe-OECD kanye ne-UN mayelana nokudlulisela imihlahlandlela yamanani ekufuneni ukusebenza kwemihlahlandlela yeziqondiso zomhlaba wonke ngokwezidingo zaseZimbabwe kusize ekwembuleni izinkinga zesikhathi esizayo emazingeni omhlaba ngokuhambisana namazinga ezindinganiso zomhlaba jikelele ngokuhambisana namazinga asekhaya. Lesi sifundo siphendula igebe lolwazi elimayelana nokwedluliselwa kwesimo sokubekwa kwenani lemali kwezezintengiselwano eZimbabwe ngokusetshenziswa kokubhekwa komqondo onezigaba ezintathu ongaphansi kwesilanganiso sokuhlola, okungumthetho, ukwenziwa kwakhona kanye nokuxhashazwa kwemiqondo. Lolu cwaningo luphikisana nokuthi lomqondo ongunxantathu yinto ebhekwe ngamehlo abomvu futhi ebalulekile ekuqondeni ukudluliselwa kokubekwa kwesimo sezemali njengethuluzi lokugwema ukukhokhwa kwentela, okusho ukuthi amazinga omhlaba awasiyo into efanayo nokuthi izwe ngalinye linesimo salo esingafanani nelinye okwenza ukuthi isimo ngasinye sibhekwe ngokwesimo sezinga lasekhaya.Financial AccountingD. Phil. (Accounting Sciences

Proceedings of the Second International Mobile Satellite Conference (IMSC 1990)

Presented here are the proceedings of the Second International Mobile Satellite Conference (IMSC), held June 17-20, 1990 in Ottawa, Canada. Topics covered include future mobile satellite communications concepts, aeronautical applications, modulation and coding, propagation and experimental systems, mobile terminal equipment, network architecture and control, regulatory and policy considerations, vehicle antennas, and speech compression

Exploring identity adjustment following adolescent acquired brain injury from the perspectives of adolescents and their parents

Aim: This thesis explored a systemic understanding of psychosocial outcomes in young people with brain injury (BI) by examining psychosocial adjustment within a family context. Design: First, a systematic review (SR) examined and appraised the evidence base for psychosocial outcomes from parent-involved interventions post child and adolescent traumatic brain injury (TBI). Psychosocial outcomes pertaining to the young person (YP), the parent, and the dyad/family were synthesised. Secondly, an empirical paper (EP) was presented. Six semi structured interviews were conducted with adolescents with BI and six synchronous interviews with their mothers. Grounded theory methodology was applied to elucidate the process of identity adjustment post adolescent TBI within this dyadic context. Findings: The potential for parent-involved interventions to impact dyadic outcomes post injury was demonstrated in the SR, but significant issues regarding bias were found. Suggestions were made on ways to better consider research with dyadic populations to more robustly research and capture outcomes. In the EP, themes of continuity and change were described for the dyad. The accounts given by young people with BI focused mainly on their own social peer relationships, as the context for their experience of identity adjustment. This was in the context of mothers describing extensive involvement in many other aspects of their child’s life, as they engaged in dilemmas over how to support their child’s adjustment. The child's identity adjustment was understood as a predominantly socially determined process, while relational processes with mum were often a lived yet unspoken narrative. Conclusion: The two papers taken in tandem illustrated the role of the parent in effecting adolescent adjustment in terms of a range of psychosocial outcomes (SR) and in terms of identity adjustment (EP) post BI. Highlighted is the need for parents to be adequately supported, given their potential to support YP adjustment. A second issue highlighted is the risk of others failing to see, attend to or understand the YPs experiences post BI

The Relative information content of complementary and supplementary narrative commentary in UK interim reports.

The main objective of the research is to investigate the relative information content of complementary and supplementary narrative commentaries in UK interim reports. The study also examines the relative importance of complementary and supplementary narrative attributes. The subsidiary objective of the study is to investigate incremental information content of complementary and supplementary narratives. The study used 309 interim reports of 103 companies for the years 2005 to 2007. The returns used were daily market adjusted cumulative abnormal returns ±5 days around the announcement of interim reports. The disclosure index method was used to capture complementary and supplementary information using disclosure variety (number of information items) and disclosure depth set of attributes (good news, amounts and comparison of current with past performance, reasons for performance and forward-looking). The control variables included financial performance measures of dividend yield, earnings per share and total assets. Event studies based multiple regression models were used to measure information content. The findings in respect of the main objective indicate that supplementary narratives had higher but insignificant infonnation content than complementary narratives for the model based on disclosure variety. However, when disclosure depth is used, complementary narratives have higher and significant relative information content than supplementary narratives. The results also show that complementary good news, complementary amounts and comparisons of current with past performance and complementary reasons for performance were associated with returns unlike their respective counterparts in supplementary narratives. Both complementary and supplementary forward-looking attributes were not associated with returns. The results of the subsidiary objective suggest that the disclosure varit)ty model combining complementary and supplementary narratives when compared with the disclosure variety model having supplementary narratives does not have a significant difference. All other incremental information content comparisons based on either disclosure variety or disclosure depth had significant differences. This study has a number of research and policy implications, especially after the 2007 subprime financial crisis

Academic catalog 2016-2018

Midlands Technical College publishes an annual academic catalog with information for students about procedures, academic programs, and course descriptions

Possessions and the Self: Downstream Consequences of Ownership and Sharing What We Own

My dissertation is based on the premise that possessions are an extension of the self. Beyond simple functional benefits that possessions provide us, I question whether possessions affect our self-perception and behavior. Specifically, I focus on two aspects of possessions: Ownership (Essay 1) and Sharing (Essay 2). In Essay 1, I find that feeling a sense of product ownership has downstream consequences in one’s representation of who s/he is. Here I reveal that salient feelings of product ownership activate a product-related self in one’s mind, but more importantly deactivate product-unrelated self. By identifying simultaneous identity activation and deactivation, I show that an individual can only hold a limited number of salient selves, and activating one’s self aspect requires a trade-off. This finding updates the prior assumption in the literature that an individual can hold an unlimited number of selves, and further suggests that there is still a finite limit to what can be salient at a given time. My interest in ownership extends to Essay 2, where I examine another behavioral aspect of consumers: sharing. Sharing behavior has received much attention lately due to the rise of sharing economy platforms, which provide new opportunities for consumers to share personal belongings with others. In Essay 2, I mine people’s latent motivation behind sharing by using a transaction dataset from one of the largest sharing economy platforms, Airbnb. Here I find that people are driven by not only monetary, but also non-monetary reasons, such as desires to meet others and share the beauty of their homes. Then I explore how each motivation affects people’s engagement on the sharing economy platform and their continued effort to share. This second essay highlights individuals’ new role as micro-entrepreneurs in this new era of the 21st century

Seamless knitted sports bra design: A responsive system design exploration

ABSTRACT The transition of sports bras’ uses, from an active lifestyle to resting activities, requires dynamic and adaptable comfort properties of the design, as well as adequate breast support, fit, and comfort. Thus, the two-fold purpose of this study was to: (a) analyze the use of current materials and processes in the product development process of seamless sports bras, via industry interview and observation, and (b) propose a design solution for a seamless sports bra that offers variable breast support during running versus resting activities. Using a case study approach, an in-depth interview with a Santoni seamless knitting technician provided data that led to mapping out the design and product development processes used for prototyping seamless sports bras. A seamless business model for a sports bra was created, and relationships among the over-arching themes of planning, marketing, product development, innovation, and production, which emerged from the grounded theory analysis, were discussed. Moreover, a detailed Product Development framework and a Tech Pack model were created and used to communicate the new design for a responsive seamless sports bra. Interactions between design, prototyping and functionality and how these themes relate to the components of the tech pack were discussed. At the materials level, a biomimetic system framework was used to identify solutions to responsive interactions within wool/Nylon/spandex blended yarns and various knitting structures when actuated by moisture. Twenty pattern designs were knitted on a Santoni circular knitting machine, using two different yarn combinations: (a) wool/spandex, and (b) wool/nylon/ spandex. Physical properties of the knit swatches were documented, as well as their thickness when dry versus three different moisture activation situations: (a) immediately after wetting, (b) after 30 minutes of air-drying, and (c) after 60 minutes of air-drying. Results showed that the Santoni circular knitting technology has capabilities to create a variety of texturally knit fabric designs that have a wide range of thicknesses, densities, and moisture responsiveness properties. Selections of knit patterns were made based on the textile testing results and used to design a responsive sports bra that incorporated female sweat maps and sports bra user needs. Sustainability considerations regarding the wet processing of the new responsive design were implemented, and the bra samples were not dyed, but only cold-washed and tumble-dried at low temperature. Fifteen prototypes were developed via a Santoni circular seamless knitting machines and tested using human subjects and 3D body scanning technology. A convenience sample of fifteen semi-athlete female college students wore the new sports bra prototypes during three different moisture conditions: (a) before a run (dry), (b) after 30 minutes run on a treadmill (wet), and (c) after resting 30 minutes (starting to dry out). 3D body scans were collected in fully inhaled, as well as relaxed respiratory states after each condition. Questionnaires were used to evaluate comfort and responsiveness of the new design. The results revealed that the new responsive sports bra offers compression during the dry conditions, breathability and some level of breast support during running, and moisture management during the resting stage, all while offering high overall comfort and fabric softness. However, the length of the bra straps needs to be shortened, and the breast support during running needs improvement, therefore further design iterations are needed. The proposed integrative approach to the sports bra design offers a new framing for the systematic design process of a sports bra as a functional design garment and fills knowledge gaps within the seamless knitting process using performance wool blend yarns. The new biomimetic-inspired sports bra solution has a potential for commercial applications that can offer women a responsive, adaptable sports bra, to encourage healthier lifestyles, as well as to accommodate for the athleisure trend

Attention to Competition: The Role of Managerial Cognition in Shaping the Response to Competitive Actions

The competitive dynamics literature has examined various characteristics of actions/response dyads (e.g., new product release, market entry, marketing campaigns) along with their antecedents and competitive outcomes. For the most part, the emphasis has been on objective and structural factors that influence the dynamics of competition. What is often overlooked is that organizations’ actions are a result of individual level perceptions and interpretations. To gain a more comprehensive understanding of competitive dynamics, I integrate micro and macro perspectives in the study of competition. By drawing from theories in managerial cognition, organizational attention, and behavioral strategy, I examine how mental structures of decision-makers can influence the way competitive moves by a rival are perceived, which in turn shapes the subsequent responses to those moves. The main mechanisms linking cognition to competitive decisions are rooted in the literature on organizational attention and the processes that explain how and why managers notice and act on some competitive moves and ignore others. I develop and test hypotheses that link managerial regulatory focus, perception of identity, and external/internal orientation to the likelihood and speed of response to competitive actions. I also examine how the salience of a competitive action within the industry can moderate these relationships. The Awareness-Motivation-Capability framework in competitive dynamics is used as a theoretical bridge between cognition and the nature of response to competitive moves by rivals. Using data from one industry, I test the proposed relationships and discuss the implications for research and management practice. The results show that while perceptions regarding identity and external/internal orientation influence the likelihood of response, regulatory focus seems to have no effect. The salience of the competitive attack also influenced likelihood of response and positively moderated the relationship between external/internal orientation and the likelihood of response. None of the hypotheses related to the speed of response dependent variable were supported

An Optimization Theoretical Framework for Resource Allocation over Wireless Networks

With the advancement of wireless technologies, wireless networking has become ubiquitous owing to the great demand of pervasive mobile applications. Some fundamental challenges exist for the next generation wireless network design such as time varying nature of wireless channels, co-channel interferences, provisioning of heterogeneous type of services, etc. So how to overcome these difficulties and improve the system performance have become an important research topic. Dynamic resource allocation is a general strategy to control the interferences and enhance the performance of wireless networks. The basic idea behind dynamic resource allocation is to utilize the channel more efficiently by sharing the spectrum and reducing interference through optimizing parameters such as the transmitting power, symbol transmission rate, modulation scheme, coding scheme, bandwidth, etc. Moreover, the network performance can be further improved by introducing diversity, such as multiuser, time, frequency, and space diversity. In addition, cross layer approach for resource allocation can provide advantages such as low overhead, more efficiency, and direct end-to-end QoS provision. The designers for next generation wireless networks face the common problem of how to optimize the system objective under the user Quality of Service (QoS) constraint. There is a need of unified but general optimization framework for resource allocation to allow taking into account a diverse set of objective functions with various QoS requirements, while considering all kinds of diversity and cross layer approach. We propose an optimization theoretical framework for resource allocation and apply these ideas to different network situations such as: 1.Centralized resource allocation with fairness constraint 2.Distributed resource allocation using game theory 3.OFDMA resource allocation 4.Cross layer approach On the whole, we develop a universal view of the whole wireless networks from multiple dimensions: time, frequency, space, user, and layers. We develop some schemes to fully utilize the resources. The success of the proposed research will significantly improve the way how to design and analyze resource allocation over wireless networks. In addition, the cross-layer optimization nature of the problem provides an innovative insight into vertical integration of wireless networks