Empirical essays on tax planning and transfer pricing

This dissertation consists of three empirical studies contributing to the literature on tax planning and transfer pricing. The first study investigates the impact of U.S. state taxation on the geographical allocation of the intra-U.S. trademark ownership of large U.S. multinationals. The study documents that the U.S. State of Delaware has a leading position as a trademark holding location and that the major-ity of trademarks are registered there. Moreover, it contains an analysis of the effectiveness of group consolidation (combined reporting) and provides evidence that combined reporting signifi-cantly reduces the share of trademarks allocated to Delaware. Nevertheless, the identified effects indicate that Delaware-based trademark strategies have not been entirely abandoned. The second study examines the use of information technologies in a firm’s transfer pricing system. In particular, it investigates the role of firms’ information environment in mitigating the conflict of managerial and tax objectives in transfer pricing. The study provides empirical evi-dence that if firms facing conflicting objectives make intensive use of information technologies, they are more profitable, report lower effective tax rates, and face lower tax risk. The third study analyzes whether the strictness of transfer pricing regulations and their en-forcement affect intrafirm trade of U.S. multinational firms. In particular, the results suggest that stricter transfer pricing in a country decrease the tax rate sensitivity of bilateral U.S. intrafirm trade. Thus, the possibilities of U.S. multinationals to engage in transfer pricing related tax plan-ning schemes are effectively reduced

Expression levels of immune markers in Actinobacillus pleuropneumoniae infected pigs and their relation to breed and clinical symptoms

<p>Abstract</p> <p>Background</p> <p>In pigs little is known about the role of innate immune defence in bacterial infections of the respiratory tract, despite their major role in pig production. In the present study we characterized and compared <it>in vitro </it>and <it>in vivo </it>activation of immune markers of different pig breeds 7 days before, and 4 and 21 days after an experimental aerosol infection with <it>Actinobacillus (A.) pleuropneumoniae</it>.</p> <p>Results</p> <p><it>In vitro </it>stimulation of bronchoalveolar lavage fluid (BALF) and blood leukocytes with <it>A. pleuropneumoniae, Streptococcus suis</it>, PMA and LPS led to production of different amounts of H₂O₂, NO and TNF-α, depending on the stimulus, individual, breed and time of infection. Generally, significant responses to <it>in vitro </it>stimulation were observed only in blood leukocytes, whereas the alveolar macrophages showed a high basal activation. In addition, the production of haptoglobin and cytokines (TNF-α, IFN-γ and IL-10) <it>in vivo </it>was measured in plasma and BALF. Plasma haptoglobin levels mirrored the clinical manifestations at 4 days post-infection. In plasma and BALF TNF-α could not be detected, whereas variable levels of IFN-γ were found at pre- and post-infection times. IL-10 was found in some plasma but in none of the BALF samples. The different expression levels in individuals within the breeds correlated for some markers with the severity of clinical manifestations, e.g. H₂O_2,plasma haptoglobin and BALF IFN-γ for German Landrace pigs.</p> <p>Conclusion</p> <p>Our findings revealed differences in the activation of the immune markers with respect to infection time, individuals and breeds. Moreover, results showed different correlation grades between the immune markers produced <it>in vitro </it>or <it>in vivo </it>and the clinical manifestations. Further analyses will have to show whether these markers may serve as correlates of protection against porcine respiratory infections.</p

Observations de trois pollinisateurs endémiques et d’un pollinisateur indigène sur les fleurs de Hibiscus boryanus DC. sur l’île de La Réunion (Passeriformes : Zosteropidae ; Squamata : Gekkonidae ; Hymenoptera : Apidae)

Dans son jardin à la Plaine des Palmistes (950 m d’altitude), Jean-Maurice Tamon a observé pendant plusieurs années la présence de pollinisateurs de Hibiscus boryanus.Dans cette note, nous rapportons les différentes observations qui ont été faites ces trois dernières années

Determinants of the acceptability of health problems in different ages: exploring a new application of the EQ VAS

Background We aimed to determine the acceptability of non-perfect health states with age using the EQ VAS and analyse the infuencing factors. Methods We conducted a cross-sectional survey on a convenience sample from the general population (N=200). Respondents were asked to indicate on the EQ VAS the health states that are still acceptable for ages between 30 and 80 years in 10-year intervals (VAS acceptable health curve, AHCvas). We recorded respondents’ current health, health-related lifestyle, demographic background and explored the reference person they imagined when evaluating acceptable health states. We evaluated the AHCvas by estimating linear multilevel models including a random intercept (estimated at age 30) and a random slope for age. Results AHCvas scores were available for 194 respondents (mean age=42.8 years, range 19–93, 58% female). For ages of 30, 40, 50, 60, 70 and 80 years, mean AHCvas scores were 93, 87, 80, 73, 65 and 57, respectively. The decline of AHCvas was linear with age. Respondents’ age, health status, lifestyle and health-related experiences, as well as their reference point taken (e.g. imagining themselves, others or both during the valuation task) infuenced signifcantly the acceptability of health problems. Conclusions When measured with the EQ VAS, health problems were increasingly acceptable with age. Capturing well the individual variability in the assessment of acceptable health states at diferent ages, the EQ VAS is a useful addition to EQ-5D-3L descriptive system-based measures of acceptable health

Causes of death and comorbidities in hospitalized patients with COVID-19

Infection by the new corona virus strain SARS-CoV-2 and its related syndrome COVID-19 has been associated with more than two million deaths worldwide. Patients of higher age and with preexisting chronic health conditions are at an increased risk of fatal disease outcome. However, detailed information on causes of death and the contribution of pre-existing health conditions to death yet is missing, which can be reliably established by autopsy only. We performed full body autopsies on 26 patients that had died after SARS-CoV-2 infection and COVID-19 at the Charite University Hospital Berlin, Germany, or at associated teaching hospitals. We systematically evaluated causes of death and pre-existing health conditions. Additionally, clinical records and death certificates were evaluated. We report findings on causes of death and comorbidities of 26 decedents that had clinically presented with severe COVID-19. We found that septic shock and multi organ failure was the most common immediate cause of death, often due to suppurative pulmonary infection. Respiratory failure due to diffuse alveolar damage presented as immediate cause of death in fewer cases. Several comorbidities, such as hypertension, ischemic heart disease, and obesity were present in the vast majority of patients. Our findings reveal that causes of death were directly related to COVID-19 in the majority of decedents, while they appear not to be an immediate result of preexisting health conditions and comorbidities. We therefore suggest that the majority of patients had died of COVID-19 with only contributory implications of preexisting health conditions to the mechanism of death

A comparison of European, Polish, Slovenian and British EQ-5D-3L value sets using a Hungarian sample of 18 chronic diseases

Background In the Central and Eastern European region, the British EQ-5D-3L value set is used commonly in quality of life (QoL) studies. Only Poland and Slovenia have country-specifc weights. Our study aimed to investigate the impact of value set choice on the evaluation of 18 chronic conditions in Hungary. Methods Patients’ EQ-5D-3L index scores were calculated using the VAS-based Slovenian and European and the time-tradeof-based Polish and British value sets. We performed pairwise comparisons of mean index values by dimensions, diagnoses and age groups. We evaluated disease burden by comparing index values matched by age and gender in each condition with those of the general population of the CEE region in all four value sets. Results Altogether, 2421 patients (55% female) were included in our sample with the average age of 55.87 years (SD=17.75). The average Slovenian, European, Polish and British EQ-5D-3L scores were 0.598 (SD=0.279), 0.661 (SD=0.257), 0.770 (SD=0.261) and 0.644 (SD=0.279), respectively. We found highly signifcant diferences in most diagnoses, with the greatest diference between the Polish and Slovenian index values in Parkinson’s disease (0.265). Systematic pairwise comparison across all conditions and value sets revealed greatest diferences between the time-trade-of (TTO) and VAS-based value sets as well as varying sensitivity of the disease burden evaluations of chronic disease conditions to the choice of value sets. Conclusions Our results suggest that the choice of value set largely infuences the health state utility results in chronic diseases, and might have a signifcant impact on health policy decisions

Non-Enzymatic Template-Directed Recombination of RNAs

RNA non-enzymatic recombination reactions are of great interest within the hypothesis of the “RNA world”, which argues that at some stage of prebiotic life development proteins were not yet engaged in biochemical reactions and RNA carried out both the information storage task and the full range of catalytic roles necessary in primitive self-replicating systems. Here we report on the study of recombination reaction occuring between two 96 nucleotides (nts) fragments of RNAs under physiological conditions and governed by a short oligodeoxyribonucleotide template, partially complementary to sequences within each of the RNAs. Analysis of recombination products shows that ligation is predominantly template-directed, and occurs within the complementary complex with the template in “butt-to-butt” manner, in 1- or 3- nts bulges or in 2–3 nts internal loops. Minor recombination products formed in the template-independent manner are detected as well

Na(+)-D-glucose cotransporter SGLT1 is pivotal for intestinal glucose absorption and glucose-dependent incretin secretion.

To clarify the physiological role of Na(+)-D-glucose cotransporter SGLT1 in small intestine and kidney, Sglt1(-/-) mice were generated and characterized phenotypically. After gavage of d-glucose, small intestinal glucose absorption across the brush-border membrane (BBM) via SGLT1 and GLUT2 were analyzed. Glucose-induced secretion of insulinotropic hormone (GIP) and glucagon-like peptide 1 (GLP-1) in wild-type and Sglt1(-/-) mice were compared. The impact of SGLT1 on renal glucose handling was investigated by micropuncture studies. It was observed that Sglt1(-/-) mice developed a glucose-galactose malabsorption syndrome but thrive normally when fed a glucose-galactose-free diet. In wild-type mice, passage of D-glucose across the intestinal BBM was predominantly mediated by SGLT1, independent the glucose load. High glucose concentrations increased the amounts of SGLT1 and GLUT2 in the BBM, and SGLT1 was required for upregulation of GLUT2. SGLT1 was located in luminal membranes of cells immunopositive for GIP and GLP-1, and Sglt1(-/-) mice exhibited reduced glucose-triggered GIP and GLP-1 levels. In the kidney, SGLT1 reabsorbed ∼3% of the filtered glucose under normoglycemic conditions. The data indicate that SGLT1 is 1) pivotal for intestinal mass absorption of d-glucose, 2) triggers the glucose-induced secretion of GIP and GLP-1, and 3) triggers the upregulation of GLUT2