我国外商投资企业转移定价避税应对策略

根据跨国公司转移定价避税与东道国税务机关反避税调查博弈分析的结论,在新《企业所得税法》实施的环境下,我国有效应对外商投资企业转移定价避税的措施是:提高避税的处罚率,加大对外商投资企业滥用转移定价避税的处罚力度;通过完善税务操作规程与细则,增大外商投资企业利用转移定价避税的成本;推广预约定价制度,严格控制税务机关对转移定价进行反避税的调查成本。     

Safeguarding Children: Ofsted and Regulatory Failure

This article analyses two aspects of the regulatory conduct of Ofsted in protecting children from abuse by strangers. The first concerns the problems associated with child protection and safeguarding in the context of facilitating multicultural norms whereby certain social behaviours which would be unacceptable in one culture can be tolerated or condoned in another. The second aspect arises because, following Ofsted's failure to protect thousands of children from child abuse in many UK cities, children's social services' departments may have adopted strategic behaviour which may protect them rather than the children.     

DECISION THEORY UNDER AMBIGUITY

Abstract We review recent advances in the field of decision making under uncertainty or ambiguity. We start with a presentation of the general approach to a decision problem under uncertainty, as well as the ‘standard’ Bayesian treatment and issues with this treatment. We present more general approaches (Choquet expected utility, maximin expected utility, smooth ambiguity and so forth) that have been developed in the literature under the name of models of ambiguity sensitive preferences. We draw a distinction between fully subjective models and models incorporating explicitly some information. We review definitions and characterizations of ambiguity aversion in these models. We mention the challenges posed by some of the models presented. We end with a review of part of the experimental literature and applications of these models to economic settings.     

Public perception of scientific uncertainty in relation to food hazards

The research reported here aims to understand how people react to statements expressing risk uncertainty information in the context of a commonly experienced potential hazard, food related risks. Public perception of seriousness of risk for themselves, and for other people was examined for different types of uncertainty, for each of five different food hazards. The results indicated that participants responded to the different types of uncertainty in a uniform way, suggesting that perception of risk associated with uncertainty is not affected by the 'type' of uncertainty. The results further indicated that the seriousness of risk, in the presence of statements of uncertainty, was perceived to be greater for pesticides and genetic modification compared to BSE, high fat diets and Salmonella . It was argued that this could be due to the perceptions of low personal control, and high societal responsibility to protect people and societal control over exposure to the potential risks of pesticides and genetic modification. Under circumstances where people feel they have little personal control over their exposure to a particular hazard, and those social institutions that are perceived to be in control of protecting the public indicate that there is uncertainty associated with risk estimates, the hazard may appear to be 'out of control', which is associated with a perception of serious risk.     

Growth,deficits and uncertainty: Theoretical aspects and empirical evidence from a panel of 27 countries

We examine the relationship between fiscal deficits and per-capita income growth in a panel of 27 European countries, allowing for perceived risks, in terms of fiscal sustainability, associated with additional government spending. Such risks are proxied by the conditional variability of manufacturing production and stock market returns and by the unconditional variability of two survey-based economic-sentiment indicators. To help clarifying how fiscal variables impact on growth and to provide a point of reference for the interpretation of the empirical results a structural growth model is first identified. We find evidence of an asymmetric relationship, in that fiscal deficits give rise to adverse growth effects if they coincide with high uncertainty regarding the prospects of the economy and no significant negative growth effects in the low-uncertainty case.     

A General Model of the Behavioral Response to Taxation

This paper generalizes the standard model of how taxes affect the labor-leisure choice by allowing individuals to change both their labor supply and avoidance effort in response to tax changes. Doing so reveals that the income and substitution effect of taxes depend on both preferences and the avoidance technology. Econometric analysis will not in general allow one to separately identify the two influences, unless one can specify observable determinants of the cost of avoidance. The effective marginal tax rate on working must be modified by the addition of an avoidance-facilitating effect, which measures how the cost of avoidance changes with higher income. This model provides a conceptual structure for evaluating to what extent, and in what situations, the opportunities for tax avoidance mitigate the real substitution response to taxation.     

Cost information sharing with uncertainty averse firms

Summary. A homogeneous Cournot duopoly with asymmetric information is analyzed. Every firm learns its own marginal cost parameter, but not the marginal cost parameter of the opponent. Every firm can commit to revealing its private information to the other firm, i.e. to share information. The influence of uncertainty aversion on the readiness of the duopolists to share cost information is analyzed. Uncertainty aversion is modeled according to the Choquet utility theory. It is shown that low uncertainty aversion leads the firms to share information, while high uncertainty aversion leads the firms not to share. A simple economic explanation for this result is given.Received: 5 January 2001, Revised: 7 May 2003, JEL Classification Numbers: D43, D81, D82.I wish to thank Jürgen Eichberger, Volker Krätschmer, Willy Spanjers, seminar participants at Universität des Saarlandes, seminar participants at University College London, participants in the conference of the Verein für Socialpolitik in Mainz 1999 and an anonymous referee for helpful comments. The views expressed in this paper are those of the author and do not necessarily reflect the views of the European Central Bank.     

Corporate and personal income tax declarations

Decisions by firms and individuals on the extent of their tax payments have generally been treated as separate choices. Empirically, a positive relationship between corporate and personal income tax evasion can be observed. The theoretical analysis in this paper shows that a manager's decision on the firm's behaviour will be independent of his personal preferences if the gain from reducing corporate tax payments is certain, as in the case of tax avoidance. If, however, the firm evades taxes so that the manager's income depends on whether the firm's activities are detected or not, corporate and personal income tax evasion choices cannot be separated. Jel Code H 24 · H 25 · H 26     

Stochastic optimization of sustainable hybrid generation bioethanol supply chains

This paper focuses on designing a hybrid generation bioethanol supply chain (HGBSC) that will account for economic, environmental and social aspects of sustainability under various uncertainties. A stochastic mixed integer linear programming model is proposed to design an optimal HGBSC. A case study set in the state of North Dakota in the United States is used as an application of the proposed model. The results suggest that the designs of optimal HGBSC change when different sustainability standards are applied. In addition, sensitivity analysis is conducted to provide deeper understanding of the proposed model.     

On Conformity Testing and the Use of two Stage Procedures

Conformity testing is a systematic examination of the extent to which an entity conforms to specified requirements. Such testing is performed in industry as well as in regulatory agencies in a variety of fields. In this paper we discuss conformity testing under measurement or sampling uncertainty. Although the situation has many analogies to statistical testing of a hypothesis concerning the unknown value of the measurand there are no generally accepted rules for handling measurement uncertainty when testing for conformity. Usually the objective of a test for conformity is to provide assurance of conformity. We therefore suggest that an appropriate statistical test for conformity should be devised such that there is only a small probability of declaring conformity when in fact the entity does not conform. An operational way of formulating this principle is to require that whenever an entity has been declared to be conforming, it should not be possible to alter that declaration, even if the entity was investigated with better (more precise) measuring instruments, or measurement procedures. Some industries and agencies designate specification limits under consideration of the measurement uncertainty. This practice is not invariant under changes of measurement procedure. We therefore suggest that conformity testing should be based upon a comparison of a confidence interval for the value of the measurand with some limiting values that have been designated without regard to the measurement uncertainty. Such a procedure is in line with the recently established practice of reporting measurement uncertainty as “an interval of values that could reasonably be attributed to the measurand”. The price to be paid for a reliable assurance of conformity is a relatively large risk that the procedure will fail to establish conformity for entities that only marginally conform. We suggest a two‐stage procedure that may improve this situation and provide a better discriminatory ability. In an example we illustrate the determination of the power function of such a two‐stage procedure.