Compliance of Documentation Transfer Pricing Requirements in Foreign Direct Investment Enterprises in Vietnam

The increase of inter-boundary transactions brings a number of benefits for enterprises. However, even when benefits of transfer pricing are evident, multinational organizations still face legal challenges, including performing parts of transactions in another jurisdiction and motives of tax officials in investigating transfer pricing. This is especially true when countries do not want to lose benefits from tax collection. Therefore, many countries and organizations such as the Organization for Economic Cooperation and Development （OECD）, Pacific Association of Tax Administrators （PATA）, the European Union （EU）, and Vietnam have introduced requirements for transfer pricing documentation to prevent transfer pricing manipulation and maintain benefits from taxes. The aim of this research was to assess the compliance of those requirements of foreign direct investment （FDI） enterprises in Vietnam. This article which is a summary of our research includes the following sections： （1） OECD guidelines of transfer pricing documentation; （2） Vietnam regulations of transfer pricing documentation; （3） results of the research; and （4） discussion and conclusion.

Modus operandi of transnational transfer pricing for window dressing

A goal of transfer pricing may be to maximize after tax revenue by setting transfer prices that reduce the total tax paid. ＂Transfer pricing＂ is the pricing of products or services provided by one division to other division of the same corporate entity. Most of the corporate entities are using the method of ＂Window dressing＂, which is a technique used in preparation of financial statements of corporate entities. A transnational corporation is any enterprise that undertakes Foreign Direct Investment （FDI）, owns or controls income gathering assets in more than one country, produces goods or services outsides its country of origin, or engages in international production. Profitability of the transnational corporate entities is being manipulated by the technique of transfer pricing. Abuse of transfer prices is a key tool used by the corporate entities to think that they have virtually no profit; hence, they shouldn＇t pay any taxes. India needs to realize the fundamental need for co-operation among tax administrations in order to remove the obstacles that international double taxation presents to the free movement of goods, services and capital between various countries. In this context, one needs to consider that transactions among associated enterprises may take place under different conditions from those taking place among independent enterprises, while enforcing the act of transfer price mechanism. This paper focuses on transfer pricing and its implications in transnational transactions.

Empirical Examination of Market Reaction to Transfer Pricing Taxation Announcement in Press： A Japanese Perspective

The Japanese Taxation Agency （JTA） introduced transfer pricing taxation （TPT） in order to suppress the outflow of profits and therefore taxes of Japanese companies, which are expanding overseas. There have been many press reports regarding the application of TPT, and so there is much public attention on this issue. TPT is applied to unnatural transfer prices （TP）. If TPT is applied to a multinational company （MNC）, the company will need to bear enormous documentation costs in its calculation of the ratable price. In addition, in the last few years, the target of TPT is shifting to the overseas transfer of intangible assets, such as trademarks, royalties, patents, and charges income. As a result, companies have become more careful about TPT and investors tend to pay attention to companies＇ TPT strategy. With regard to this point, this paper examines how the market evaluates news regarding TP by investigating the market reaction to an initial press report mentioning that a firm was involved in a TP manipulation and may be guilty of tax underpayment. We examine these events both because press reports are currently under intense scrutiny and because there has been very little research on firms that engage in tax sheltering （see, e.g., Graham ＆ Tucker, 2006; Hanlon ＆ Slemrod, 2009）. Some view the fact that not all firms engage in tax sheltering as surprising because of the widespread view that shelters, at least in the 1990s, in expectation, offered a positive net present value position. The potential negative public relations effect is often cited as one reason for this ＂under-sheltering＂ phenomenon （Bankman, 2004）. On the event study analysis, we find that the Japanese capital market has shown a statistically significant negative reaction to the press reports. This result is due to a strong distrust of corporate activity regarding TP strategies. Moreover, in order to clarify the reason why the market responds to reports of TPT being applied, we compute the cumulative abnormal returns （CARs） around the date of the press report and conduct two-stage least-squares estimation to examine where this result regarding the market reaction comes from. Our results indicate that the variables for intangible assets and effective tax rate and the variables which represent the extent of corporate governance （CG） are statistically significant with respect to these reactions.

TP-PCR法构建抗人CD28嵌合抗体双启动子昆虫杆状病毒重组转移载体

为构建能同时表达抗人CD28嵌合重链和嵌合轻链基因的双启动子杆状病毒转移载体,利用PCR法扩增出抗人CD28鼠源性单抗的可变区基因和人IgG1的恒定区基因,再采用一种不需要限制性核酸内切酶和连接酶的新方法———三引物PCR(TP_PCR)法将两者拼接后分别插入杆状病毒转移载体pAcUW3的ph和p10启动子后,并通过酶切、电泳、PCR扩增和测序对重组体进行了鉴定。研究结果表明,TP_PCR法快速、方便、准确,无需设计外源的DNA序列,就能构建完好的融合表达基因。该转移载体的构建成功为嵌合抗体基因在昆虫细胞中的表达奠定了基础。

基于FTP的商业银行利率期限结构实证研究

该文基于内部资金转移定价(FTP)体系的建设,对商业银行的债券业务、贷款业务和存款业务分别构建了相应的利率期限结构模型,并进行实证检验,研究结果支持了这些结构模型的有效性。

Optimal Operation for Baoying Pumping Station in East Route Project of South-to-North Water Transfer

Baoying pumping station is a part of source pumping stations in East Route Project of South-to-North Water Transfer in China. Aiming at the characteristics of head varying, and making use of the function of pump adjustable blade, mathematical models of pumping station optimal operation are established and solved with genetic algorithm. For different total pumping discharge and total pumping volume of water per day, in order to minimize pumping station operation cost, the number and operation duties of running pump units are respectively determined at different periods of time in a day. The results indicate that the saving of electrical cost is significantly effected by the schemes of adjusting blade angles and time-varying electrical price when pumping certain water volume of water per day, and compared with conventional operation schemes （namely, the schemes of pumping station operation at design blade angles based on certain pumping discharge）, the electrical cost is saved by 4.73%-31.27%. Also, compared with the electrical cost of conventional operation schemes, the electrical cost is saved by 2.03%-5.79% by the schemes of adjusting blade angles when pumping certain discharge.

Study on the Influencing Factors of Land Transfer Price in the Context of Rural Land Reform

Agricultural land is the key to large-scale agricultural management,and the transfer price is the key to the success or failure of land transfer. At present,there are many problems in the pricing of rural land transfer in China,such as low price,random pricing,and large price difference,which seriously hinder the development of rural land transfer. Drawing lessons from the research results of domestic and foreign scholars,combined with the actual situation of rural land transfer in China,this paper analyzes the influencing factors of land transfer price in the context of rural land reform. Finally,according to the influence of different factors on the behavior of agricultural land transfer,this paper proposes establishing and perfecting the evaluation system of contracted land,perfecting the evaluation institution of transferred land assets and establishing a unified dynamic monitoring system of land transfer price in the whole country,and then driving the broad masses of farmers to get rich together,which is of great significance to achieving the revitalization of China’s rural areas.

Big Data Knowledge Pricing Schemes for Knowledge Recipient Firms

Big data knowledge,such as customer demands and consumer preferences,is among the crucial external knowledge that firms need for new product development in the big data environment.Prior research has focused on the profit of big data knowledge providers rather than the profit and pricing schemes of knowledge recipients.This research addresses this theoretical gap and uses theoretical and numerical analysis to compare the profitability of two pricing schemes commonly used by knowledge recipients:subscription pricing and pay-per-use pricing.We find that:(1)the subscription price of big data knowledge has no effect on the optimal time of knowledge transaction in the same pricing scheme,but the usage ratio of the big data knowledge affects the optimal time of knowledge transaction,and the smaller the usage ratio of big data knowledge the earlier the big data knowledge transaction conducts;(2)big data knowledge with a higher update rate can bring greater profits to the firm both in subscription pricing scheme and pay-per-use pricing scheme;(3)a knowledge recipient will choose the knowledge that can bring a higher market share growth rate regardless of what price scheme it adopts,and firms can choose more efficient knowledge in the pay-per-use pricing scheme by adjusting the usage ratio of knowledge usage according to their economic conditions.The model and findings in this paper can help knowledge recipient firms select optimal pricing method and enhance future new product development performance.

Price Analysis of Water Supply for South-to-North Water Transfer Project

The factors influencing the water supply price of a hydraulic project include natural conditions and economic policies. This paper thoroughly demonstrates the water price of South-to-North Water Transfer Project from the viewpoint of economic policies. It is considered that if the project is assigned as a profitable one and built depending on commercial loan from bank completely or mostly, the water price will be too high to be undertaken by users,and if the project places the public good at first while considering the economic benefit, its investment mainly relies on the state (national or local governments) appropriation and self-raised funds and a little from the bank loan on favorable terms, the price determined according to the principle of satisfying the cost and reasonable profit will be relatively lower and can be undertaken by the users in the North China where water shortage is serious. The problem of higher water price of agricultural irrigation to the north of the Yellow River can be tackled by taking measures such as "compensating agriculture by industry" according to foreign practical experiences and relevant suggestions.

An Analysis of the Factors that Affect Collective Construction Land Transfer Price: A Case Study of Yichang City

The transfer of the rural collective construction land is increasingly accelerating,and the factors affecting transfer price are manifold. In this paper,the research area is Yichang,and we establish hedonic price model to explore and analyze the factors which affect the collective construction land transfer price. The simulation results show that in geographical factors,the higher degree of prosperity,road accessibility and soundness of infrastructure will result in higher collective construction land transfer price; in economic factors,the higher farmers' per capita net income and added value of the village's tertiary industry will lead to higher collective construction land transfer price; in ownership factors,the integrity of usufruct,disposition and possession has increasingly significant impact on collective construction land transfer price. In the process of establishing rural collective construction land circulation market,the government should gradually improve conditions of collective construction land; strengthen the construction of the rural economy,improve the economic attribute of the collective construction land; establish and improve China's rural collective construction land-related laws and regulations,make the rural collective construction land use rights clear,and give the whole rights of occupation,use,earning and disposition.

基于贷款市场报价利率(LPR)内嵌内部资金转移定价(FTP)曲线的模型研究

在利率市场化改革深入推进的大背景下,中国人民银行指导市场利率定价自律机制发布了《关于将贷款市场报价利率纳入金融机构内部资金转移定价体系的实施指引》(以下简称“指引”),明确要求贷款内部资金转移定价(FTP)曲线应参考贷款市场报价利率(LPR),旨在发挥内部资金转移定价在利率传导过程中的重要作用,进一步打通市场利率向贷款利率传导的堵点。本文梳理了FTP曲线的主流构建方法,对商业银行如何将LPR引入到FTP曲线的构建模型进行研究,并通过案例进行分析,旨在为商业银行构建符合自身管理需要的FTP曲线提供方法,充分发挥FTP体系在货币政策利率传导中的作用,同时更好地引导商业银行对客户利率定价,不断提升利率定价的市场化、精细化、差异化水平,优化资源配置,提升服务实体经济的能力。

Carbon Price Forecasting Approach Based on Multi-Scale Decomposition and Transfer Learning

Accurate carbon price forecasting is essential to provide the guidance for production and investment.Current research is mainly dependent on plenty of historical samples of carbon prices,which is impractical for the newly launched carbon market due to its short history.Based on the idea of transfer learning,this paper proposes a novel price forecasting model,which utilizes the correlation between the new and mature markets.The model is firstly pretrained on large data of mature market by gated recurrent unit algorithm,and then fine-tuned by the target market samples.An integral framework,including complexity decomposition method for data pre-processing,sample entropy for feature selection,and support vector regression for result post-processing,is provided.In the empirical analysis of new Chinese market,the root mean square error,mean absolute error,mean absolute percentage error,and determination coefficient of the model are 0.529,0.476,0.717%and 0.501 respectively,proving its validity.

A Multimodel Transfer-Learning-Based Car Price Prediction Model with an Automatic Fuzzy Logic Parameter Optimizer

Cars are regarded as an indispensable means of transportation in Taiwan.Several studies have indicated that the automotive industry has witnessed remarkable advances and that the market of used cars has rapidly expanded.In this study,a price prediction system for used BMW cars was developed.Nine parameters of used cars,including their model,registration year,and transmission style,were analyzed.The data obtained were then divided into three subsets.The first subset was used to compare the results of each algorithm.The predicted values produced by the two algorithms with the most satisfactory results were used as the input of a fully connected neural network.The second subset was used with an optimization algorithm to modify the number of hidden layers in a fully connected neural network and modify the low,medium,and high parameters of the membership function(MF)to achieve model optimization.Finally,the third subset was used for the validation set during the prediction process.These three subsets were divided using k-fold cross-validation to avoid overfitting and selection bias.In conclusion,in this study,a model combining two optimal algorithms(i.e.,random forest and k-nearest neighbors)with several optimization algorithms(i.e.,gray wolf optimizer,multilayer perceptron,and MF)was successfully established.The prediction results obtained indicated a mean square error of 0.0978,a root-mean-square error of 0.3128,a mean absolute error of 0.1903,and a coefficient of determination of 0.9249.

Factor Price Distortion and Conseq uential A dverse Wealth Transfers in China

As critical piece of China＇s gradualist economic transition, domestic price reform still faces major challenges. In particular, factor price, which is still tightlycontrolled and not market-based, is lower than market equilibrium price. Factor price distortion not only reduces market efficiency but also affects wealth distribution. Subsequent wealth transfer has, over the past ten to fifieen years, created a powerful vested interests and spawned social resentment, both of which may constitute major hazards in China＇s future reform and development. Keeping in mind that China will have to address factor price distortion in its next step of reform, this paper takes stock of China＇s journey toward price rejorm; examines the relationship among factor price distortion, previous economic growth, and policy; and estimates＇ the size of resulting wealth transfer.

Fronius TPS/i焊接系统的先进工艺及其应用

简要阐述了Fronius伏能士TPS/i智能焊接平台中几种先进的焊接工艺,同时介绍了几种工艺的焊接应用,为客户的实际应用提供参考与借鉴。

信任水平、感知成本与农户林地流转契约选择

基于福建省319户农户调查数据,采用Tobit、IV-2SLS等计量模型,实证分析信任水平和感知成本对林地流转契约选择的影响,并进一步探究不同流转主体差异、代际差异和感知风险差异在林地流转契约选择方面的异质性。结果表明:1)农户的信任水平和感知成本越高,林地流转时越倾向于选择更长的流转期限和更大的流转面积,转出主体的流转价格越高;信任水平和感知成本的交互项发挥调节作用。2)林地流转契约选择存在代际差异和感知风险差异,在流转期限和流转规模方面,信任水平、感知成本对新生代及感知低风险农户的有效影响更显著;在流转价格方面,信任水平、感知成本对老一代和感知高风险转出农户的影响更显著。据此,建议完善市场机制,激活社会资本,并保持林业政策的稳定性和持久性。

Research on the Pricing of Convertible bonds in China Migration risk based on credit rating

At present,further research and exploration on credit risks are being carried out in the global field,and increasingly profound modem credit risks are exposed to the bond market.This requires that we cannot ignore the impact of credit rating migration risk on bond pricing,so as to adapt to the sustainable and healthy development of the bond market under the new normal of China's economy.The innovation point of this paper is to try to analyze the pricing of Convertible bonds in China from the perspective of credit rating migration risk.Tsiveriotis and Femandes(1998)model is selected,and the credit risk in the model is assumed to be caused by the credit rating migration risk,and the credit spread is used to measure the credit rating migration risk.The research conclusion of this paper is as follows:First,it is valid to consider the risk of credit rating migration in the TF(1998)model.The market price of convertible bonds is on average 1.22% higher 1han the theoretical value of the model.In general,the theoretical value obtained from the model has little deviation from the market price,and has a good fitting degree.Second,from the Angle of credit rating,the selection of 32 samples of convertible bonds only empirical research shows that the credit rating of AA-convertible bonds average deviation rate is negative,suggest that the credit rating of AA-the phenomenon of convertible bonds value is underestimated,and AAA credit rating to AA,AA+,the average deviation rate of convertible bonds is positive,that credit rating AA(containing AA)more convertible bond value is overrated phenomenon,and the higher the credit rating of the average deviation rate of convertible bond,the greater the overvalued levels.It has certain guiding significance for participants in the convertible bond market.

Characterization and Synthesis through Fast Phase-Transfer of Oil-Soluble Double-Coordinated Tea-Polyphenols Arsenic

Fast phase-transferring was adopted in ethanol solution at the condition of n (oil-soluble tea pol-yphenol): N (As3﹢) = 2:1, 4:1, 6:1, pH = 4.0, temperature 40°C - 45°C, action period of 15 h to compose the target, of which the productivity was 59%, UV was 267.50, 218.00, 220.50 nm, FTIR was 6291, 34158.6, 2850.2, 1708.2;1457.3;1370.4, 1224.2, 1144.0, 760.5 cm﹣1, fluorescence value λmax = 257, 591.1, 593.7, 590.3, 591.0, 591.5, XRD λ/nm is 3.6974, 4.186, 12.0762, 15.4747, 1H-NMRδ = 0.782, 1.193, 1.483 - 1.586, 1.959 - 2.184, 2.479, 3.116, 3.970 - 3.981, 5.231 - 5.753, 6.537 - 7.300. Finally it was ascertained through XRD as double-coordinated polycrystal compound.

China futures price forecasting based on online search and information transfer

The synchronicity effect between the financial market and online response for time-series forecasting is an important task with wide applications.This study combines data from the Baidu index(BDI),Google trends(GT),and transfer entropy(TE)to forecast a wide range of futures prices with a focus on China.A forecasting model based on a hybrid gray wolf optimizer(GWO),convolutional neural network(CNN),and long short-term memory(LSTM)is developed.First,Baidu and Google dual-platform search data were selected and constructed as Internetbased consumer price index(ICPI)using principal component analysis.Second,TE is used to quantify the information between online behavior and futures markets.Finally,the effective Internet-based consumer price index(ICPI)and TE are introduced into the GWO-CNN-LSTM model to forecast the daily prices of corn,soybean,polyvinyl chloride(PVC),egg,and rebar futures.The results show that the GWO-CNN-LSTM model has a significant improvement in predicting future prices.Internet-based CPI built on Baidu and Google platforms has a high degree of real-time performance and reduces the platform and language bias of the search data.Our proposed framework can provide predictive decision support for government leaders,market investors,and production activities.

计及负荷转移需求响应的低碳数据中心光储容量优化配置

为了解决高耗能数据中心低碳化转型问题,提出一种计及负荷转移需求响应的低碳数据中心光储容量配置方法。根据延时特性将数据中心负载分为交互性负载与延时性负载,通过比特-瓦特变换与数据中心电能使用效率得出负载与数据中心能耗之间的关系,以总净现值成本最低为目标函数,考虑清洁能源高渗透率水平、数据流需求响应管控约束,获得数据中心的光储容量配置结果。算例验证了所提方法的有效性。