International Taxation in an Era of Digital Disruption: Analyzing the Current Debate

The “taxation of the digital economy” is currently at the top of the global international tax policymaking agenda. A core claim some European governments are advancing is that user data or user participation in the digital economy justifies a gross tax on digital receipts, new profit attribution criteria, or a special formulary apportionment factor in a future formulary regime targeted specifically at the “digital economy.” Just a couple years ago the OECD undertook an evaluation of whether the digital economy can (or should) be “ring-fenced” as part of the BEPS project, and concluded that it neither can be nor should be. Importantly, concluding that there should be no special rules for the digital economy does not resolve the broader question of whether the international tax system requires reform. The practical reality appears to be that all the largest economies have come to agree either that a) there is something wrong with the taxation of the “digital economy,” or b) there is something more fundamentally wrong with the structure of the current international tax system given globalization and technological trends. This paper is intended as a limited exploration of the second (or third, or fourth) best. It analyzes three policy options that have been discussed in general terms in the current global debate. First, I consider whether “user participation” justifies changing profit allocation results in the digital economy alone. I conclude that applying the user participation concept in a manner that is limited to the digital economy is intellectually indefensible; at most it amounts to mercantilist ring-fencing. Moreover, at the technical level user participation faces all the same challenges as more comprehensive and principled proposals for reallocating excess returns among jurisdictions. Second, I consider one such comprehensive international tax reform idea, loosely referred to by the moniker “marketing intangibles.” This idea represents a compromise between the present transfer pricing system and sales or destination-based reforms to the transfer pricing regime. I conclude that splitting taxing rights over “excess” returns between the present transfer pricing system and a destination-based approach is complex, creates new sources of potential conflict, and requires relatively extensive tax harmonization. This conclusion applies equally to user participation and marketing intangibles. If such a mechanism were nevertheless pursued, I suggest that a formulary system for splitting the excess return is the most manageable approach. Third, I consider “minimum effective taxation” ideas. I conclude that, as compared to the other two policy options discussed herein, minimum effective taxation provides a preferable path for multilateral cooperation

Managing sales and product returns under the word-of-mouth effect : pricing, quality, and restocking fee decisions

This paper considers a two-echelon supply chain involving a manufacturer and a retailer who make their pricing, quality, and restocking fee decisions under the word-of-mouth (WOM) effect. To investigate the decision-making problem for the sales and product returns, we construct a leader-follower game model in which the manufacturer first determines his quality effort and the wholesale price and the retailer then decides on her retail price and the restocking fee. Our results show that the wholesale and retail prices under no WOM effect are smaller than those when the WOM effect exists; and, as the WOM has a higher impact on consumer purchases, the retailer should increase her retail price, and the manufacturer should also spend more quality control effort and raise his wholesale price. In addition, when the WOM effect exists, both the restocking fee and the retail price are decreasing in the mismatch probability. It is interesting to learn that a positive WOM may not help achieve more total sales and realized sales than a negative WOM, and the realized sales under the full refund policy may be lower than those under a partial refund policy. We also find that the manufacturer and the retailer may not benefit under the WOM effect, which mainly depends on how consumers are sensitive to the restocking fee and the WOM. The retailer can benefit from the full refund policy when the mismatch chance is not high, whereas the manufacturer can always benefit from the full refund policy

Hyatt hotels corporation equity research - implications of the new industry outlook

The present report contains an in-depth analysis of the implications of the new lodging industry outlook at Hyatt Hotels Corporation as the market continues moving toward recovery after being profoundly affected by a global health crisis. The analysis fundaments on reviewing potential factors and new trends in the industry that can derive the future strategy of Hyatt. The present report is part of a broader Equity Research on Hyatt that aims to establish a target price for the company. A HOLD recommendation is given for investors, estimating a 9,3% return for a target share price of $104,07 for December 2023

Proceedings of the 7th International Conference on Business and Finance

Theme: ‘Creating futures: Sustainable economies?’ Purpose: To share continuous and collaborative research outputs that review existing strategies and to propose mechanisms for the likely achievement of a sustainable economy that is unique but inclusive to different entities in the world. Target audience: This year’s 7th International Conference on Business and Finance (ICBF) continues its tradition of being the premier forum for presentation of research results and experience reports on contemporary issues of finance, accounting, entrepreneurship, business innovation, big data, e-Government, public management, development economics and information systems, including models, systems, applications, and theory. Editorial Policy: All papers were refereed by a double blind reviewing process in line with the South African, Department of Higher Education Training (DHET) refereeing standards. Papers were reviewed according to the following criteria: relevance to conference themes, relevance to audience, contribution to scholarship, standard of writing, originality and critical analysi

Competition between State Universities

We analyse how state university competition to collect resources may affect both research and the quality of teaching. By considering a set-up where two state universities behave strategically, we model their interaction with potential students as a sequential noncooperative game. We show that different types of equilibrium may arise, depending on the mix of research and teaching supplied by each university, and the mix of low- and high-ability students attending each university. The most efficient equilibrium results in the creation of an élite institution attended only by high-ability students who enjoy a higher teaching quality but pay higher tuition fees.university competition, research, tuition fees

Critical realism: the gendering of what we know

This paper will attempt to explicate the contributory processes of gendering that are operant at a macro level of analysis. Specifically, we will focus on the academy in general, the managerial academy or business school in particular, and their roles in the production and diffusion of gendered knowledge in organizations. We will use the modal lenses of Critical Realism to show how much of the academy is unaware of their contribution to these gendering processes