Transfer pricing as a tax compliance risk

This paper studies the role of transfer pricing as a critical compliance issue. Specifically, we analyse whether and to what extent the perceived risk associated with transfer pricing responds to country-, industry- and firm-specific characteristics. Empirically, transfer pricing risk awareness is measured as a professional assessment reported by the person with ultimate responsibility for transfer pricing in their company. Based on a unique global survey conducted by a Big 4 accounting firm in 2007 and 2008, we estimate the number of firms reporting transfer pricing being the largest risk issue with regard to subsequent tax payments. We find that transfer pricing risk awareness depends on variables accounting for general tax and transfer pricing specific strategies, the types and characteristics of intercompany transactions the multinational firms are involved in, their individual transfer pricing compliance efforts and resources dedicated to transfer pricing matters.     

外商直接投资对中国国际收支影响的研究

外商直接投资（FDI）可以从多方面对一国的国际收支产生影响,包括对资本和金融账户的直接影响和对经常账户的间接影响。本文结合中国具体情况,利用1982-2009年的相关历史数据,通过建立贡献率指标,分析外商直接投资对国际收支产生的综合影响。结果显示,近年来,由于外商直接投资持续、大量的流入,不仅直接对国际收支产生正面影响,而且带动了出口快速增长,积累了巨额贸易顺差,成为导致国际收支失衡的重要因素之一。同时,撤资、利润汇出等负面效应所带来的国际收支风险也应被密切关注,尤其是在经济环境恶化时期。     

Using synthetic data to evaluate the impact of RTGS on systemic risk in the Australian payments system

This paper develops a new methodology for allowing researchers outside central banks to test the extent of payment system risk, and applies this methodology to an investigation of the impact that the introduction of real time gross settlement (RTGS) had on systemic risk in the Australian payments system. System-specific ratios are first developed to extract bilateral payment obligations from aggregate payments data in the Australian RTGS system. This synthetic data is then used to generate a deferred net settlement (DNS) system of similar dimensions to those the Australian system would have had, had RTGS not been introduced. Standard default simulation methodology is then applied to test the levels of systemic risk in both this system and the corresponding RTGS system to ascertain the degree to which the introduction of RTGS is likely to have reduced the level of risk. We find that while the level of systemic risk is likely to have been reduced in the Australian case, the size of the effect is small, a finding consistent with the results of payments system studies in other countries.     

Application of parametric insurance in principle‐compliant and innovative ways

There has been a rise of innovative parametric insurance solutions in recent years covering a wide range of risks and serving clients from individuals, to businesses, and to governments. These parametric insurance products cover risks that are otherwise uninsured or underinsured, by simplifying product design and reducing transaction costs. This paper offers a comprehensive review of parametric insurance including a classification of the types of contract and an overview of market practices. We outline the benefits and concerns of parametric insurance in comparison with indemnity insurance, and discuss the legal principle and regulatory compliance matters. We then survey the current global market and identify areas where insurance and reinsurance companies can play important roles in offering or supporting parametric insurance operations. Lastly, we offer a case study on a type of parametric insurance designed to cover earthquake risk in California.     

Optimal tax-timing and asset allocation when tax rebates on capital losses are limited

This article studies the portfolio problem with realization-based capital gain taxation when limited amounts of losses qualify for tax rebate payments, as is the case under current US tax law. When the tax rate applicable to realized losses exceeds that on realized capital gains, it can be optimal to realize capital gains immediately and pay capital gain taxes to regain the option to use potential future losses against a higher tax rate. This incentive adds an entirely new and as yet unstudied dimension to the portfolio problem. It causes risk averse investors to hold more equity and attain higher welfare levels than is the case when trading under a tax system that seeks to collect the same amount of taxes, but does not allow for tax rebate payments. This is because the benefit to these investors from having their losses subsidized is greater than the suffering from having profits taxed at a higher rate.     

Pricing,no-arbitrage bounds and robust hedging of instalment options

An instalment option is a European option in which the premium, instead of being paid up-front, is paid in a series of instalments. If all instalments are paid the holder receives the exercise value, but the holder has the right to terminate payments on any payment date, in which case the option lapses with no further payments on either side. We discuss pricing and risk management for these options, in particular the use of static hedges, and also study a continuous-time limit in which premium is paid at a certain rate per unit time.     

Weather Derivative Risk Measures for Extreme Events

We consider pricing weather derivatives for use as protection against weather extremes by using max-stable processes to estimate risk measures. These derivatives are not currently traded on any open markets, but their use could help some institutions manage weather risks from extreme events. The central challenge is to model the dependence of payments, which increases the risk of holding multiple weather derivatives. The method described utilizes results from spatial statistics and extreme value theory to first model extremes in the weather as a max-stable process, and then simulate payments for a general collection of weather derivatives. As the joint likelihood function for max-stable processes is unavailable, we use two approaches: The first is based on the composite likelihood, and the second is based on approximate Bayesian computing (ABC). Both capture the spatial dependence of payments. To incorporate parameter uncertainty into the pricing model, we use bootstrapping with the composite likelihood approach, while the ABC method naturally incorporates parameter uncertainty. We show that the additional risk from the spatial dependence of payments can be quite substantial, and that the methods discussed can compute standard actuarial risk measures in both a frequentist and Bayesian setting.     

Risk assessment in internal auditing: a neural network approach

Risk assessment is a systematic process for integrating professional judgments about relevant risk factors, their relative significance and probable adverse conditions and/or events leading to identification of auditable activities (IIA, 1995, SIAS No. 9). Internal auditors utilize risk measures to allocate critical audit resources to compliance, operational, or financial activities within the organization (Colbert, 1995). In information rich environments, risk assessment involves recognizing patterns in the data, such as complex data anomalies and discrepancies, that perhaps conceal one or more error or hazard conditions (e.g. Coakley and Brown, 1996; Bedard and Biggs, 1991; Libby, 1985). This research investigates whether neural networks can help enhance auditors’ risk assessments. Neural networks, an emerging artificial intelligence technology, are a powerful non‐linear optimization and pattern recognition tool (Haykin, 1994; Bishop, 1995). Several successful, real‐world business neural network application decision aids have already been built (Burger and Traver, 1996). Neural network modeling may prove invaluable in directing internal auditor attention to those aspects of financial, operating, and compliance data most informative of high‐risk audit areas, thus enhancing audit efficiency and effectiveness. This paper defines risk in an internal auditing context, describes contemporary approaches to performing risk assessments, provides an overview of the backpropagation neural network architecture, outlines the methodology adopted for conducting this research project including a Delphi study and comparison with statistical approaches, and presents preliminary results, which indicate that internal auditors could benefit from using neural network technology for assessing risk. Copyright © 1999 John Wiley & Sons, Ltd.     

Current trends in hospital mergers and acquisitions

Healthcare reform will impact hospital consolidation in three key areas: Payment rates will decrease, indirectly encouraging consolidation by forcing hospitals to find new ways to reduce costs and increase negotiating clout with suppliers and payers. The cost of doing business will increase as hospitals spend more on compliance, technology, and physician employment. The ACO model will encourage hospital network formation by rewarding integrated healthcare systems that can reduce costs and improve quality.     

Representations of coastal risk (erosion and marine flooding) among inhabitants of at-risk municipalities

As part of an interdisciplinary research programme on coastal risks, a combined environmental psychology–geography approach was used to study representations of coastal erosion and sea flooding among inhabitants of coastal areas. The relationship between these representations and place, or more specifically sense of place, will initially be examined, followed by individuals’ preferred risk adaptation strategies. Face-to-face interviews were conducted with 894 inhabitants from five coastal municipalities in Brittany. Results show that coastal risks are not a top priority for respondents. Paying particular attention to respondents who spontaneously cited coastal rather than other risks or no risk, we show that their relationship to place differs from the other respondents, as do their preferred adaptation strategies. These results lead to a better understanding of attitudes towards coastal risks among inhabitants of at-risk areas and provide more in-depth knowledge on coastal zone vulnerability.     

Linking dividends and capital injections – a probabilistic approach

In the context of collective risk theory, we give a sample path identity relating capital injections in the original model and dividend payments in the time-reversed counterpart. We exploit this duality to provide an alternative view on some of the known results on the expected discounted capital injections and dividend payments for risk models driven by spectrally negative Lévy processes. Furthermore, we present a probabilistic analysis and simple resulting expressions for a model with two dividend barriers, which was recently shown by Schmidli to be optimal in various Lévy risk models when maximizing the difference of dividend payments and injections in the presence of tax exemptions.     

A monetary model of balance of payments: The case of Venezuela

The monetary approach to the balance of payments has gained considerable appeal in the literature and is viewed as being concerned with the long run since it does not analyze the adjustment process of the balance of payments. The model developed in this paper is concerned essentially with the short-run implications of this approach and the model is applied to the case of Venezuela. The results were very encouraging for the monetary approach as the model was able to explain a great part of the fluctuations in the balance of payments of Venezuela during the period of study.     

Managing unintentional dwelling fire risk

In this paper, we examine the management of unintentional dwelling fire risk through the development of a geographical information system (GIS) for dwelling fire prevention support based upon an 18-month case study in a UK fire and rescue service. Previous research into causal factors in unintentional dwelling fire incidents was used to guide the development of a multiple linear regression risk model for dwelling fire incidents that was the basis of the GIS developed. The GIS provided a more detailed analysis of unintentional dwelling fire risk factors, and enabled more targeted fire prevention activities for the identified at-risk social groups.     

Lévy insurance risk process with Poissonian taxation

The idea of taxation in risk process was first introduced by Albrecher, H. & Hipp, C. Lundberg’s risk process with tax. Blätter der DGVFM 28(1), 13–28, who suggested that a certain proportion of the insurer’s income is paid immediately as tax whenever the surplus process is at its running maximum. In this paper, a spectrally negative Lévy insurance risk model under taxation is studied. Motivated by the concept of randomized observations proposed by Albrecher, H., Cheung, E.C.K. & Thonhauser, S. Randomized observation periods for the compound Poisson risk model: Dividends. ASTIN Bulletin 41(2), 645–672, we assume that the insurer’s surplus level is only observed at a sequence of Poisson arrival times, at which the event of ruin is checked and tax may be collected from the tax authority. In particular, if the observed (pre-tax) level exceeds the maximum of the previously observed (post-tax) values, then a fraction of the excess will be paid as tax. Analytic expressions for the Gerber–Shiu expected discounted penalty function and the expected discounted tax payments until ruin are derived. The Cramér-Lundberg asymptotic formula is shown to hold true for the Gerber–Shiu function, and it differs from the case without tax by a multiplicative constant. Delayed start of tax payments will be discussed as well. We also take a look at the case where solvency is monitored continuously (while tax is still paid at Poissonian time points), as many of the above results can be derived in a similar manner. Some numerical examples will be given at the end.     

Internal loss data collection implementation: evidence from a large UK financial institution

The paper conducts a critical analysis of internal loss data collection implementation in a UK financial institution. We use elite semi-structured interviews, with a sample of 15 operational risk consultants from a leading international financial institution. Using content analysis, the data covers a wide range of business areas, with particular attention drawn towards the development of internal loss collection and operational risk management. The results suggest that the development of operational risk management as a function stems from external compliance (Basel II) and the internal pressure to add value to the business portfolio. This need for compliance was augmented as a driver of internal loss data collection; however, participants also recognised that the function of loss data collection is a tool of solid internal risk management and enhances managerial decision-making. The research also highlights the problems in cleansing data in order to ensure that all information implemented in the capital allocation model is valid and reliable.     

基于因子分析的普惠金融发展评价研究—以贵州省为例

以贫困地区的普惠金融发展为实证研究对象,选取支付环境条件等五个维度指标,涵盖人均移动支付笔数等25个三级指标构建了普惠金融评价指标体系。将贵州省及其九个市州作为贫困地区的案例,运用因子分析法,对上述地区2014-2016年三年的普惠金融发展 情况进行了实证分析,分析显示：一是贵州省普惠金融整体发展水平提升明显,但部分深度贫困县域进步不大;二是贵州省普惠金融发展水平区域之间差异较大,贵阳市处于绝对领先地位;三是基础金融服务是引起普惠金融变化的主要因素,且金融服务、信用建设及金融基础设施均等水平等因素不可或缺。     

Bailouts in a Federation

The recent move towards decentralization in countries such as Spain, Hungary, and South Africa and the difficulties that central governments have had in dealing with fiscal irresponsibility on the part of regional governments in countries such as Argentina, Brazil, and India has made the study of transfer systems one of the most important areas of research in federalism today. A model of a federation is developed in which regional governments act as Nash competitors with each other but are first-movers in a Stackelberg game with the central government. The central government finds that it will maximize its expected votes by increasing transfers as regions borrow. This bail out of regional governments creates a regional soft budget constraint and results in two incentive effects, a common pool effect on tax payments and an opportunity cost effect. The soft budget constraint lowers the opportunity cost of borrowing for the region, but also increases the tax-cost since a portion of the borrowing must be paid for through increased taxes. The common property problem associated with tax payments implies that the increased tax cost must be less than the decrease in the opportunity cost (leading to excessive borrowing) unless the central government increases grants to other regions when it institutes a bailout. Somewhat surprisingly, in the latter case the additional increased taxes may increase costs enough to offset the lower opportunity cost resulting from the bailout, leading to efficient borrowing decisions as in the case of a hard budget constraint. The results are also useful for understanding the empirical estimation of soft budget constraints.     

A bootstrap-based comparison of portfolio insurance strategies

This study presents a systematic comparison of portfolio insurance strategies. We implement a bootstrap-based hypothesis test to assess statistical significance of the differences in a variety of downside-oriented risk and performance measures for pairs of portfolio insurance strategies. Our comparison of different strategies considers the following distinguishing characteristics: static versus dynamic protection; initial wealth versus cumulated wealth protection; model-based versus model-free protection; and strong floor compliance versus probabilistic floor compliance. Our results indicate that the classical portfolio insurance strategies synthetic put and constant proportion portfolio insurance (CPPI) provide superior downside protection compared to a simple stop-loss trading rule and also exhibit a higher risk-adjusted performance in many cases (dependent on the applied performance measure). Analyzing recently developed strategies, neither the TIPP strategy (as an ‘improved’ CPPI strategy) nor the dynamic VaR-strategy provides significant improvements over the more traditional portfolio insurance strategies.     

Prediction of outstanding payments in a Poisson cluster model

We consider a simple Poisson cluster model for the payment numbers and the corresponding total payments for insurance claims arriving in a given year. Due to the Poisson structure one can give reasonably explicit expressions for the prediction of the payment numbers and total payments in future periods given the past observations of the payment numbers. One can also derive reasonably explicit expressions for the corresponding prediction errors. In the (a, b) class of Panjer's claim size distributions, these expressions can be evaluated by simple recursive algorithms. We study the conditions under which the predictions are asymptotically linear as the number of past payments becomes large. We also demonstrate that, in other regimes, the prediction may be far from linear. For example, a staircase-like pattern may arise as well. We illustrate how the theory works on real-life data, also in comparison with the chain ladder method.     

交易型操纵行为影响证券价格的微观机制研究--以连续交易、虚假申报、对倒操纵典型案例为切入点

中国证监会行政处罚的典型案例显示,交易型操纵行为包括建仓持仓、通过不正当交易行为影响证券价格、反向交易获利或谋取其他利益等三个步骤。在连续交易操纵中,行为人大量以高于市场卖一价的价格申报并高比例成交,影响证券交易价格。虚假申报操纵是通过不以成交为目的频繁或大额申报、撤单,制造买盘汹涌的假象,误导市场投资者跟风交易,从而影响证券交易价格。对倒操纵是利用资金优势或持股优势,通过自买自卖放大证券交易量并拉抬证券价格。因此,交易型操纵实质上是通过不正当交易行为,在特定期间内制造虚假证券供求关系,从而扭曲证券市场价格。