The Tax Sparing Provision Influence: A Credit versus Exempt Investors Analysis

This paper is concerned with the impact of tax sparing provisions on the location choices of multinational enterprises. Special attention is paid to the economic in°uence of tax sparing because the OECD proposal to reconsider the inclusion of this provision in bilateral tax treaties is highly controversial. An empirical analysis is proposed in order to apprehend the effects of tax sparing on both credit and exempt investors, since they do not benefit from the same advantages provided by tax sparing. Using data from 54 developing countries over the 1990-2000, and distinguishing Japanese credit investors from French exempt investors, we first find that the asymmetrical sensitivity between exempt and credit investors relative to foreign corporate taxes is considerably reduced with tax measures accounting for tax sparing. Second, we find that tax sparing provisions have a favorable impact on the location choices of credit investors and have no influence on the location choices of exempt investors. Third, the non-robust significance of both a tax sparing adjusted effective interest tax rate and effective royalties tax rate tends to suggest that tax incentives on passive incomes are not really considered by both credit and exempt investors when making the decision of where to invest.foreign direct investment, tax sparing, credit and exempt tax systems, corporate taxes, interest and royalty taxes

"Χριστοῦ τὸν ἱεράρχην": the course of the sticheron from the old (non-kalophonic) to the kalophonic melos

This paper aims to present the way in which the sticheron "Χριστοῦ τὸν ἱεράρχην", written in honour of St Athanasius the Great, in the plagal of the second mode, is set to music firstly according to the old (non-kalophonic) compositional style and secondly according to the kalophonic one. I shall then try to present the two compositions by contrasting and comparing the two melodies, examining the main notes on which each melody (melos) is constructed. To make this comparison more comprehensive I refer to the work of Chourmouzios and to the way in which these compositions are conveyed from the old notation system to that of the New Method (exegesis). Musicological analyses of various types follow this comparison, helping the attempt to suggest an answer to the question as to whether we can refer to the kalophonic compositional style and its practices by using a term such as ars nova or not

A normative perspective of the American opioid public health epidemic: regulatory lessons to Portugal

ABSTRACT - In response to the opioid epidemic, which has claimed approximately 700,000 lives, a national public health emergency was declared in the United States in 2017. The epidemic was triggered by medical overprescription under the influence of marketing strategies crafted to convince physicians pain was being poorly treated and that fear of addiction was unwarranted. This study describes the origins of the epidemic through a normative perspective and verifies similarities and differences between regulations from Portugal and the United States. The aim is to raise awareness of potential contributors to an opioid epidemic in Portugal. With this purpose, scientific literature and American and Portuguese regulations were reviewed. A qualitative study with semi-structured interviews of Portuguese keyinformants within the field of pain management was conducted to address their views and perceptions of opioid use in Portugal. Medical caution with opioid use was withdrawn and a new practice of treating chronic pain unrelated to cancer with opioids was consensually approved without adequate empiric evidence. Direct-to-consumer marketing, unregulated sales representatives visits and gifts and donations to physicians may have contributed to the conception of the epidemic. In Portugal, direct-to-consumer marketing is limited and physician-industry relations are strictly regulated, nonetheless, opioid use for chronic pain has been approved by legislation and opioid sales have increased by 54-fold since 2001. Key-informants agree opioid efficacy is limited and preventive measures for opioid overprescription, namely, pain management medical education, systematic monitoring of opioid dispensing, and information to patients are indicated.RESUMO - Em resposta à epidemia de opióides foi declarada uma emergência nacional de saúde pública nos Estados Unidos em 2017. A epidemia foi desencadeada por excesso de prescrição médica e estratégias de marketing criadas para convencer os médicos de que a dor estava a ser sub-tratada e que o medo da adição era injustificado. Este estudo descreve as origens da epidemia sob uma perspetiva regulamentar dos Estados Unidos, verificando semelhanças e diferenças com a situação portuguesa. O objetivo é consciencializar para prevenir a possibilidade de uma epidemia similar em Portugal. Foram analisadas literatura bem como regulamentação americana e portuguesa. Foi realizado um estudo qualitativo com entrevistas semi-estruturadas a informantes-chave portugueses, especialistas em tratamento da dor, com o objetivo de abordar as suas perceções sobre o uso de opióides em Portugal. A cautela médica com os opióides foi abandonada e o seu uso para tratar dor crónica não-oncológica consensualmente aprovado mesmo sem evidência suficiente. Do ponto de vista normativo, visitas de representantes de vendas, marketing direto ao consumidor e doações a médicos podem ter contribuído para a conceção da epidemia. Em Portugal, o marketing direto ao consumidor é restrito e as relações entre médicos e indústria são estritamente regulamentadas. No entanto, desde que o uso de opioides para dor crónica foi aprovado em 2001 as vendas destes medicamentos aumentaram 54 vezes. Os informantes-chave concordam que a eficácia do opióide é limitada e medidas preventivas para o excesso de prescrição são indicadas, nomeadamente, educação especializada, monitoramento e informação ao doente

Uncertainty, Imitation, and Plant Location: Japanese Multinational Corporations, 1990‐1996

In a study of a sample of 2,705 international plant location decisions by listed Japanese multinational corporations across a possible set of 155 countries in the 1990-1996 period, we use neoinstitutional theory and research on political institutions to explain organizational entry into new geographic markets. We extend neoinstitutional theory\u27s proposition that prior decisions and actions by other organizations provide legitimization and information to a decision marked by uncertainty, showing that this effect holds when the uncertainty comes from a firm\u27s lack of experience in a market but not when the uncertainty derives from the structure of a market\u27s policymaking apparatus

Cohesion, COVID-19 and contemporary challenges to globalization

In the years preceding the COVID-19 pandemic, the decades-long, pan-continental globalization consensus was being questioned. In our view, the pandemic has accelerated the rate at which the globalization consensus is being defied. To better understand the implications of this defiance, we turn to research on people, organizations and international competition to see whether this defiance weakens the cohesion needed to keep globalization moving apace. People and organizations create cohesive forces that can link and constrain the differences that are encountered when people and organizations move across international borders. Meanwhile, the nature of international competition, particularly as connected to the level of active involvement by state actors, can lead to fractures that reduce cohesion across polities and societies

Taxation and the international strategy of Japanese multinational enterprises

This paper analyzes the effect of statutory tax rates on the location of Japanese capital in emerging countries. Considering the fact that the difference between Japan and foreign tax rates can engender transfer pricing manipulation to diminish tax liabilities, and that some firms are more able to manipulate transfer pricing, such as wholly-owned ventures and high technology affiliates, we investigate the sensitivity of Japanese capital to foreign tax rates by distinguishing wholly-owned ventures from joint-ventures and high R&D affiliates from low R&D affiliates. Based on country, parent firm and sector characteristics an investment equation is estimated on a sample of 3774 Japanese affiliates in 49 emerging countries. We obtain a greater semi-elasticity between investment and the statutory tax rate for wholly-owned affiliates and R&D intensive parents. We interpret these results as indirect evidence for abusive transfer pricing to be one of the determinants of FDI flows.Nous analysons l'effet des taux statutaires d'impôt sur les sociétés sur l'investissement direct japonais dans les pays émergents. Les écarts de taux entre le Japon et les pays hôtes créent des incitations à la manipulation des prix de transfert. Nous nous intéressons à la sensibilité à l'impôt de certains investissements plus susceptibles d'en bénéficier, telles que ceux dans les filiales détenues à 100%, ou pour lesquels la recherche et développement joue un rôle majeur. Nous estimons une équation d'investissement comprenant des caractéristiques du pays hôte, du secteur et de la firme mère à partir d'un échantillon de 3774 filiales de firmes japonaises localisées dans 49 pays. Nous obtenons une semi-élasticité de l'investissement au taux d'impôt statutaire plus élevée dans les cas de filiales détenues à 100% et de firmes mères intensives en recherche et développement. Nous interprétons ces résultats comme une preuve indirecte que la manipulation des prix de transfert appartient aux déterminants des flux d'investissement direct

The role peer responses to adolescent expression of emotions plays in their emotion regulation : A systematic literature review

Introduction Peer responses to adolescents’ emotional expressions (PREE), are thought to influence the continued development of emotion regulation (ER). Unsupportive (e.g., dismissive) PREE, for example, are expected to be associated with greater maladaptive ER. Poor ER is known to place adolescents at risk of psychopathology. The aim of this systematic review was to collate and synthesize the emerging evidence exploring the role that peer emotion socialization, specifically PREE, plays in adolescent ER and identify future directions. Methods In adherence with PRISMA guidelines, PsychINFO, Medline Complete, CINAHL Complete, Scopus and Web of Science were searched on April 20th, 2021, May 28th, 2022, and April 12th, 2023 for English language reports published after 1998. To be included, studies needed to report on PREE and its relation to adolescent ER. Results A total of eight studies, one qualitative and seven quantitative, met inclusion criteria and had a combined N of 785 participants (aged 10–18 years). Studies were primarily undertaken in the US and mostly included males and females, with one study only including female participants. Conclusions Although only eight studies were identified, the review identified preliminary evidence for an association between PREE and ER in adolescents. This association appeared to vary depending on adolescent gender, age, the closeness of the friendship and the PREE. Several limitations were identified, and suggestions are made for future research in this emerging area

Japanese Investment in Transitional Economies: Characteristics and Performance

This paper presents and analyzes comparative data on 2,343 foreign-owned organizations operating in the transitional economies of China, Viet Nam and the countries of Central and Eastern Europe (CEE). Specifically, it compares the extent, sectoral distribution, characteristics and performance of Japanese subsidiaries established in these three regions. Among the three, most Japanese investment has flowed to China where subsidiary performance was highest and where subsidiaries were concentrated in the manufacturing sector. Further, the employment levels of expatriate managers, and the propensity to engage in joint ventures, were higher in China and Viet Nam. The tighter linkages between domestic and foreign organizations, and the greater incidence of investment, provided more significant opportunities and scope for the transfer of organizational practices, and change, in domestic incumbents in China and Viet Nam than in the CEE.

"Traditional innovation" in Byzantine Chant: The case of kalophonia

During the last two centuries of the Eastern Roman Empire, liturgical chant reached its point of highest development, producing an impressive wealth of compositions which are both grounded in the past classical style of the 10th-13th centuries and bringing a new, theretofore unknown flowering in the realm of the musical life of Byzantium – the so-called kalophonia. After a brief introduction, we will focus on some fragments from the oeuvre of three coryphées of the kalophonic style, namely Ioannis Glykys, St John Koukouzelis and Xenos Koronis. The presentation will end with some preliminary conclusions concerning the way in which old and new elements intermingled in the creation of the kalophonic style