Tourism in Latin America Essay Example for Free

Tourism in Latin America Essay Imagine that you are a tour guide in Latin America. Your clients want to see the artwork and ruins of the earliest known pre-Columbian civilization. They also want to know the history behind them. To satisfy their interests, you must custom develop a tour just for them. You will call it The Legacies of the Olmec, Zapotec, and Chavà ­n. Describe each of the 3 artifacts below: Describe this artifact: 1. The name of the civilization that created it (Olmec, Zapotec, Chavà ­n) ? 2. An explanation of the evidence that the artifact belongs to that civilization 3. A description of the characteristics of the artifact 4. A logical explanation of the purpose that the artifact would have served Describe this artifact: 5. The name of the civilization that created it (Olmec, Zapotec, Chavà ­n) ? Chavin 6. An explanation of the evidence that the artifact belongs to that civilization Common Chavin design are people ands animals 7. A description of the characteristics of the artifact Art and engineering innovations can be found in distant settlements 8. A logical explanation of the purpose that the artifact would have served To percent the temple from flooding during highlands rainy seasons Describe this artifact: 1. The name of the civilization that created it (Olmec, Zapotec, Chavà ­n)? The Olmec 2. An explanation of the evidence that the artifact belongs to that civilization They were the people who built the heads 3. A description of the characteristics of the artifact The most recognizable artifacts are carved stone heads 4. A logical explanation of the purpose that the artifact would have served They are portraits of the Olmec ruler

Vodafone group: An analysis

Vodafone group: An analysis Chapter 1 Firms Profile Vodafone Group is a mobile telecommunications company. The company has a significant presence in Europe, the Middle East, Africa, Asia Pacific and the United States. In the United States the groups associated undertaking operates as Verizon Wireless. From a UK start-up company in 1984, Vodafone is now the worlds leading mobile telecommunications company. So Vodafone its a market leader in its current production. Businesses know that consumers position products in relation to those of competitors. There can be a ‘pecking order or ‘product ladder. Products might be market leaders. They are usually the main selling product and decisions on prices and promotion are often followed by other products, known as market followers. (Dave Hall et al, 2006) Vodafone is amongst the major global providers of telecommunication services. The company has a strong presence in Germany, the UK, Italy, Spain and other European countries. Through its direct and partner networks, its global reach extends to more than 38 countries. Vodafone offers a wide range of mobile services such as voice, messaging, data, and roaming services to customers and business enterprises. Vodafone has a strong network infrastructure comprising 2G and 3G networks, which are operated over GSM and GPRS network standards. These networks enable the group provide high speed data services. Legal Type Of Firm Vofadone was formerly known as Racal Strategic Radio Limited and changed its name to Racal Telecommunications Group Limited in 1985. Further, the company changed its name to Racal Telecom Limited in 1988; to Vodafone Group Public Limited Company in 1991; to Vodafone AirTouch Plc in 1999; and subsequently to Vodafone Group Public Limited Company in 2000. Vodafone Group is headquartered in Newbury, the United Kingdom. Source: http://www.scripophily.net/ratepulicoen.html Public limited companies tends to be larger and is the second type of o limited company. This company name ends in plc. There are around 1.2 million registered limited companies in the UK, but only around 1% of them are public limited companies. Shares in public limited companies may be freely bought and sold by the general public on the stock market. Owners of plcs are therefore rarely closely involved with the business. The stock exchange is a market where second hand shares are bought and sold. Operating as a public limited company is associated with both advantages and disadvantages. Advantages: All members have limited liability. Huge amounts of money can be raised from the sale of shares to the public. Production costs may be lower as firms may gain and this leads to ability to expand and benefit from economies of scale which means as the production increases the cost of production per unit decreases. In this case Vodafone will be able to set lower prices than competitors and in this way increase sales revenue and maybe profits. The great size of Vodafone, can often dominate the market and lead to a market leader where the competitor firms will have to follow. Disadvantages: There can be potential management problems in the organization. There may be danger of takeover There may be danger of shares loosing value through fashion and rumour and this to lead to a reduction of the stock market shares. Some public limited companies such as Vodafone are very large indeed. They have millions of shareholders and a wide variety of business interests situated all over the world. So, Vodafone is a multinational company which means that it has production plants in a number of different countries. Type Of Competition Vodafone Group Plc is the worlds leading mobile telecomunications , with a significantpresence in Europe, the Middle East, Africa, Asia pacific and the united states through the companys subsiadiary undertakings, joint ventures, associated undertakings and investments. source: http://www.linkedin.com/companies/vodafone Vodeafone is operating as an oligoply because it a market leader and has its dominant place in the market. Oligopoly is one of the four market structures. At one extreme perfect competition, where there are very many firms competing. Each firm is so small relative to the whole industry that it has no power to influence price. It is a price taker. At the otherxtreme is monopoly where there is just one firm in the industry, and hence no competition , which involves a quite a lot of firms competing and where there is freedom for new firms to enter the industry, and oligopoly which involves only a few firms and where entry of new firms is restricted. So, oligopoly is a market structure where there are few enough firs to enable barriers to be erected against the entry of new firms. Product Design And UCD Failures Vodafone the worlds largest mobile operator, is seeking an experienced freelancer to supportin the design and developmentof its exclusive products and specific Vodafone owned devices for all customer target groups. Vodafones aim is to grow revenue and improve its profit margin by adding value to its products and services, i.e. Earning more from each product sold. The ‘Vodafone Live service enables customers to use picture messaging to download polyphonic ringtones, colourgames, images and information, through an icon driver menu. Vodafone offers a product with many different features provides customers with opportunities to chat, play games, send and receive pictures, change ringtones, receive information and soon view video clips and send video messages. Vodafone and other mobile phone industries use different ways in orderto prolongthe maturity stage of their product life cycle and gain more profits. The cell phone life cycle includes design, manufacture, distribution, use and disposal(or alternatively, refurbishment of recycling components). Chapter 2 Swot Analysis The purpose of Swot Analysis is to conduct a general and quick examination of a business current position so that it can identify preffered and likely directions for the future. Swot analysis involves looking at the internal strengths and weaknesses of a business and the external opportunities and threats. (Dave Hall et al, 2006) Strengths: Diversified geographical portfolio with strong mobile telecommunications operations in Europe, the Middle East, Africa, Asia Pacific and to some extent the US Leading presence in emerging markets such as India Big presence in Japan market Strategig alliances with Apple iPhone Weaknesses: US business not nearly as strong as European/rest of the world operations 80% of its business is generated in Europe Opportunities: Focus on costs reductions improving returns Majority stake in Huthcison Essar in India Research and development of new mobile technologies Focus on developing markets ( Africa, Latin America Threats: Highly competitive market Still lags behind major competitors in the US Extremely high penetration rates in key European markets European Union regulation on cross-border cell phone usage by customers Develpment of VOIP communication Source: http://www.wikiswot.com/SWOT/15_Communication_Services/Vodafone.html Pest-G Analysis Pest -G analysis examines the external environment and the global factors that may affect a business. It can provide a quick and visual representation of the external pressuresfacing a business, and their possible constraints on strategy. It is usually divided into five external influences on a business-political, economic, social, technological and green environment. (Dave Hall et al, 2006) Political This is concerned with how political developments, regionally, rationally and internationally might affect Vodafones strategy. It might include a consideration of legislation, such as consumer laws, regulation, political pressures and the goverments view of certain activities. Economic This might involve the analysis of a variety of economic factors and their effects on business. They might include consumers ativity, their willingness to spend. Economic variables sch as inflation, unemployement, trade growth. Th effects ofchanges in product and labour markets. Social One social issue that affects the operations of Vodafone in a positive way is the increased population in India. So Vodafone operating in a market with high population leads to an increase demand for its products. Technological Businesses operate in a world of rapd tehnological change. Organisation sneed to regularly review the impact of new technologies upon their activities. Production may become out of date and increase costs for the business, communication may become inefficient as ICT develops. Thats why Vodafone is investing in RD which is vital in industries where technological change is rapid. Green Enviromental factors can influence the decisions of Vodafone. Taking into account environmental considerations mayraise costs, but might also generate greater sales. Environmental and social issues are very important for Vodafone. They use the monitoring aspect of the entropy system for international data gathering across their operating companies. This information is fed into their corporate Social Responsibility (CSR) and has resulted in significant data qulality improvements. Chapter 3 Global MIS/Risks Vodafone is a multinational company operating in a globalised economy where there is free international trade between different countries. International trade is based on the principle of competitive advantage. This means that businesses that benefit from the international trade are those which can produce their products at the lowest opportunity cost than other countries. According to Peter Jay the ability to produce anywhere in the world, sell your products anywhere in the world and sent your profits anywhere in the world is called globalisation. Vodafone is a very successfull cell phone company, as it is a market leader in the countries that is operating and this it has been achieved by its international competitivness. With international marketing firms have to consider their USP( unic selling point) and their international competitivness in order to increase their global market share. In this effort multinational have to provide greater variety of products better qulity an d at lower price. To improve therefore their USP and improve their international competitivness multinationals should improgve productivity per worker, invest in research and development and experience further economies of scale. (Dave Hall et al, 2006) Vodafone In Ghanaian Mobile Deal Mobile phone firm Vodafone is to expand its presence in Africa which is a less economically developed country by buying a controlling stake in Ghana Telecom for 452 pounds. Rapid uptake in mobile use on the continent has attracted foreign firms. Vodafone is attracted by Ghanas strong economy and political stablity. Ghana is the most attractive markets in Africa. There are currently 2.7 million mobile subscribers executive in Ghana, although overall mobile penetration per head of the population in the west African country reamauins low at 35%. So, as a result of this Vodafone has recently sought to focus on emerging markets with high potential and less established competition, existing more mature mrkets such as Japan. Source: http://news.bbc.co.uk/1/hi/business/7487821.stm The Impact Of Vodafone In The Ldcs As we said previously Vodafone is a multinational company that operates mostly in less economically developed countries that are becoming emerging economies because it can be benefit in a number of ways. However, the operation of Vodafone in those countries is acossiated both with advantages and disadvantages. It can increase the employment and in this way it can increase the income per capita. An increase in domestic competition leads to an improvement in the efficiency of local firms and also decrease inflation. It can improve the balance of payment account of the country if products are sold abroad and also the curency of the country in which a multinational operates in, and also it can introduce new technogy, production processes and management stylkes and techniques. Ethical Issues There are some ethical issues that result from the nature of the operation of different multiationals in the ldcs. One ethical issue is the exploitation of workers. There are long working hours, they impose over time and also child and labour prisoners. They might operate in ldcs with lower environmental standards. Usually they have high orked related accidents and the reason is because it is cheaper for them to have lower safety standards. They usually bring their managers ( mddle andhigh level) for ther headworkers and therefore dont give many opportunties to local managers. Because of the size and financial size of such enterprises, there are concerns about the ability of goverments to control them and in this way they may be able to avoid paying operation tax. Conclusion The above project is an analysis of a global multinational company which is operating in different countries and it is a market leader in the products that it provides. The results that came out of this project are connected to the marketing strategies that Vodafone uses in order to promote effectively its products around the world through the an appropriate marketing Mix. I Also saw how different cocial environmental and technological issues benefit the company and which are the threats that may increase costs of vodafone and maybe decrease profits. Finally I analysed the operations of Vodafonesin the less econimically developed countries andin which way it can affect the economy of these countries and the ethical issues that may arrise through such operation. References Dave Hall, Rob Jones, Carlo Raffo (2006), 3rd edition, Business Studies John Sloman , (2006) sixth edition, Economics, Prentice Hall http://www.scripophily.net/ratepulicoen.html http://www.linkedin.com/companies/vodafone http://www.wikiswot.com/SWOT/15_Communication_Services/Vodafone.html http://news.bbc.co.uk/1/hi/business/7487821.stm The rate of increasing prices per year. When inflation is increasing prices increase faster, when inflation decreases prices keep increasing but in a slower rate. Inflation is bad for firms and for the market. Since the products are becoming more expensive, peoples purchasing power is reduced so they buy less.

Integration of WLANS, PAN, LAN and GSM in Hmanets

Integration of WLANS, PAN, LAN and GSM in Hmanets INTERWORKING ISSUES IN INTEGRATION OF WLANS, PAN, LAN AND GSM IN HMANETS KEY TO SYMBOLS OR ABBREVIATIONS AP Access Points AMASS Architecture for Mobile Ad-hoc Systems and Services AODV Ad Hoc on Demand Distance Vector Routing BS Base Station BNEP Bluetooth Network Encapsulation Protocol CDMA Code-Division Multiple Access CGSR Cluster-head Gateway Switch Routing CSMA/CA Carrier Sense Multiple Access with Collision Avoidance CTS Clear to Send DBTMA Dual Tone Multiple Access DSDV Destination Sequenced Distance Vector Routing DSR Dynamic Source Routing GEO-TORA Geographical Temporally Ordered Routing Algorithm GPRS General Packet Radio Service GPS Global Positioning System GRDL Grid Resource Description Language GSM Global System for Mobile Communication HF High Frequency HMANET Heterogeneous Mobile Ad Hoc Network HOLSR Hierarchical Optimized Link State Routing IP Internet Protocol LBR Location Based Routing LLC Logical Link Control MAC Medium Access Control MACA Multi Hop Collision Avoidance MACAW Medium Access Protocol for Wireless LAN MAN Metropolitan Area Network MANET Mobile Ad Hoc Network MPR Multipoint Relays NAT Network Address Translation NFS Network File System OLSR Optimized Link State Routing OSI Open Systems Interconnection PDA Personal Digital Assistant QoS Quality of Service RREP Route Reply RREQ Route Request RERR Route Error SCTP Stream Control Transmission Protocol SDR Software-Defined Radio TBRPF Topology Broadcast Based on Reverse Path Forwarding TC Topology Control TCP Transmission Control Protocol TDMA Time Division Multiple Access TORA Temporally Ordered Routing Algorithm VHF Very High Frequency WAN Wide Area Network WLAN Wireless Local Area Networks WPAN Wireless Personal Area Network WSDL Web Services Description Language WSN Wireless Sensor Network ZRP Zone Routing Protocol Chapter 1 1 INTRODUCTION Recent developments in wireless communications have taken possible applications from simple voice services in early cellular networks to newer integrated data applications. IEEE 802.11 family i.e. Wireless Local Area Networks (WLANs) have become popular for allowing low cost data transmissions [1]. The most common and approachable places, such as airports, hotels, shopping places, university campuses and homes have been provided with WLAN Access Points (AP) which provide hotspot connectivity . The future advances in modern radios like Software-Defined Radio (SDR) and cognitive radio technologies will surely facilitate the need of multi-mode, multi-interface and multi-band communication devices. This heterogeneous networking paradigm will certainly enable a user to enjoy better service quality, ease of use and mobility, while keeping in view the application needs and types of available access networks e.g. cellular network, WLAN, wireless personal area network (WPAN) etc. 1.1 Mobile Ad hoc Networks The Mobile Ad hoc Network (MANET) is a network formed by mobile wireless hosts without (necessarily) using a pre-existing infrastructure and the routes between these hosts may potentially contain multiple communication hops [2]. The autonomous nature of participating mobile nodes enables MANETs to have dynamic and frequently changing network topology. The nodes are self-organizing and behave as routers. The ease and speed of deployment and decreased dependence on infrastructure have made ad hoc networks popular within very short span of time. MANET variations include Personal area networking (e.g. cell phone, laptop, ear phone), Military environments (e.g. soldiers, tanks, aircraft), Civilian environments (e.g. cab network, meeting rooms, sports stadiums), and foremost Emergency operations (e.g. search-and-rescue, policing and fire fighting). MANETs rapid deployment, ease of use and subsequent properties make them a hot choice for many important applications. 1.1.1 Resource Sharing One of the intended aspects of MANETs is that it will facilitate the sharing of resources. These include both technical and information resources. Technical resources like bandwidth, Quality of Service (QoS), computational power, storage capacity and information resources include any kind of data from databases. Resource sharing among mobile devices require the devices to agree on communication protocols without the existence of any dedicated servers. 1.1.2 Coordination System Mechanisms that enable the sharing of resources between different mobile devices, i.e. different coordination system is necessary for sharing dissimilar resources. Examples of such mechanisms are Samba, Network File System (NFS) for sharing disk space and the distributed dot net client for sharing processor cycles. 1.1.3 Trust Establishment Before nodes start sharing any resource, they demand a certain amount of trust between them or systems with which they share resources. The level of trust depends on the kind of information or resources that is to be shared. For instance, sharing processor cycles require less trust than the sharing of personal information. Similarly, sharing of profit-making or highly sensitive information can require another level of trust establishment. There are systems currently in operation that can provide a certain amount of trust like the public key infrastructure that makes use of certificates. 1.1.4 Node Discovery Before any node starts communicating with other node, that node must be discovered. When a node enters the network, it has to be capable of communicating to the other nodes about its capabilities e.g. it is a Personal Digital Assistant (PDA) and it has a camera, Global Positioning System (GPS) capabilities and Global System for Mobile Communication (GSM) capabilities etc. When a node is detected, other users can send a query to the new device to find out what it has to offer. Commercial service providers can advertise the resources they have to offer through Internet Protocol (IP) multicasts. There is a myriad of standards that include resource description protocols like Standards Grid Resource Description Language (GRDL), the Web Services Description Language (WSDL) for telling all offer devices a way to describe and publish their specific resources and needs. There are also various different systems currently available that can gather these resource descriptions and structure them for other devices to use. 1.1.5 Resource description For any device to be able to use any resource, a way to identify and describe the resource has to be agreed upon by all available devices. If, for instance, storage capacity is to be shared, it first has to be clear what the capacity of each device is, and, what the storage need is. Although there are techniques to describe certain resources but not one technique that is able to provide this service for all resources. The available techniques combined, however, cover most of what is needed. 1.2 MANET Classifications Mobile Ad hoc Networks are usually categorized as Homogeneous MANETs and Heterogeneous MANETs. 1.2.1 Homogeneous MANETs When MANETs operate in fully Symmetric Environment whereby all nodes posses identical capabilities in terms of battery, processing powers, responsibilities and hardware and software capabilities, thus having no diversity, the network is Homogenous MANET. 1.2.2 Heterogeneous MANETs In certain environments, mobile nodes may have asymmetric capabilities in terms of transmission ranges, Medium Access Control (MAC), battery life, processing powers, speed of movement and software variations etc. Mobility rate may also differ in ad hoc networks due to varying traffic characteristics, transmission ranges, reliability requirements and communication needs. Similarly, addressing and traffic flows like host-based addressing, content-based addressing or capability-based addressing patterns may be defined in certain scenarios; for example, people sitting at an airport lounge, metro taxi cabs, sportsmen playing and military movements etc Homogenous MANETs do not allow for the heterogeneity in the network, which is seriously required in many scenarios, for instance, in a military battlefield network, where soldiers usually carry light portable wireless devices and more powerful equipment like High Frequency (HF) or Very High Frequency (VHF) is installed on vehicles. So, heterogeneous mobile nodes may co-exist in a single ad hoc network making it a Heterogeneous MANET. 1.3 Criterion for Heterogeneous MANETs The integration of different communication networks like cellular networks, WLANs, and MANETs is not straightforward due to various communication scenarios, different interface capabilities and dynamic mobility patterns of mobile nodes. This exhibits many possible application scenarios where devices may unexpectedly interact, create and receive random data streams (video and music etc), or request different network services. The drawback is that each network type typically uses its own protocol stack especially in the case of medium access. In fact, frequency allocation becomes more complicated since different wireless technologies like IEEE 802.11 a and IEEE 802.15.4 may possibly operate in the same frequency band, which makes coexistence mechanisms increasingly important. A heterogeneous MANET paradigm needs to be capable of providing subsequent characteristics. 1.3.1 Transparency The network should be capable of providing seamless end-to-end communication among mobile nodes i.e. the MANET user must not be informed about the route followed or network interfaces traversed by a communication session [3]. 1.3.2 Mobility Integration among dissimilar communication networks must facilitate mobile nodes via some mobility management framework that can manage flow of information through different medium access techniques [4]. 1.3.3 Addressing Most of the IP based networks consider each communication interface as an independent network device running under its own protocol stack [5]. However, this mechanism makes it difficult to remember destinations by IP addresses. So, there must be some mechanism similar to domain name service to recognize mobile nodes with more logical and easy to remember names. 1.3.4 Configuration Various configuration options like network ID, willingness for cooperative communications, desired mobility level and intended services shall be provided to mobile users for their convenience [6]. 1.3.5 End to End security Integration between various networks and data transfer over multiple wireless hops can even expose data to malicious nodes. Security mechanisms must take care of end-to-end data security as well as route security [7]. 1.3.6 Transmission Power and interference of Nodes MANET routing protocols must take care of issues arising due to various communication ranges like communication gray zones [4] and issues arising because of various communication technologies like Bluetooth and WLAN working in same frequency band [1]. 1.3.7 Utilization of Resources In heterogeneous networking paradigm, there may arise situations where some or most of the mobile nodes are installed with different kind of resources. For example, there may be some nodes installed with location monitoring devices like GPS. Now it is the responsibility of routing protocol to benefit from such capabilities in order to facilitate location aided routing and similar services [8]. 1.4 Problem Statement Current research efforts in mobile ad hoc networks are mainly converging towards inclusion of dissimilar communication technologies like IEEE 802.11 [9] and IEEE 802.15.4 [10] to a single mobile ad hoc network. Integrations of different networks like Wide Area Networks WANs (1G, 2G, 2.5G, 3G) and Metropolitan Area Networks MANs (IEEE 802.16) wherein users can access the system through a fixed base station (BS) or AP connected to a wired infrastructure in single hop fashion are also extending towards multihop communication environment using the new and revolutionary paradigm of a mobile ad hoc networks (MANETs), in which nodes constituting MANET serve as routers. Comprehensive research efforts have been done to address the issues related to infrastructure-less multihop communications among nodes installed with dissimilar communication capabilities [3, 11, 12, 13]. However, an investigation needs to be made in order to analyze and address the issues arising from such integrations. Such problems relate to both end users convenience (For example, remembering each destination with its IP address is a cumbersome job specially when every destination may carry multiple IP addresses and any communication interface may optionally be connected or disconnected) as well as networks performance; for example, routing to the best possible interface when there are multiple interfaces installed at destination. Likewise, optimized neighborhood sensing and position based routing can help to improve heterogeneous ad hoc networks performance and scalability. 1.5 Objectives The objective of this thesis is to study the integration of different technologies like WPAN, WLAN and GSM having different capabilities and protocol stacks to mobile ad hoc networks. Performance improvement issues relating to network configuration, human understandable naming mechanism and sophisticated location aided routing mechanisms will also be discussed and evaluated on an actual ad hoc network testbed. 1.6 Thesis Organization Chapter 2 describes the different design and technological challenges arising from integration of multiple communication interfaces. Chapter 3 includes an overview of famous heterogeneous routing protocols architectures, interworking issues encountered, the limitation and solution suggested. Chapter 4 specifically discusses the adopted solution. Chapter 5 presents the details about solution implementation, protocol evaluation testbed, proposed test cases for evaluation of the proposed mechanisms and results obtained, whereas; chapter 6 concludes the research work. Chapter 2 2 LITERATURE REVIEW 2.1 Introduction The literature available on heterogeneous MANETs has suggested different combination of access technologies but no comprehensive solution comprising of maximum access technologies has been suggested yet. Some of the suggested techniques will be discussed in succeeding paragraphs. 2.2 Service Architecture for Heterogeneous IP Networks It was presented by Joe C. Chan and Doan B. [14]. This proposal is presented to resolve two main issues i.e. universal connectivity and MANET location management in heterogeneous networks. The new architecture suggested for Mobile Ad-hoc Systems and Services (AMASS) introduces a new abstraction layer called Mobile P2P overlay in order to cater for the problems such as transparency, dynamic routing, unique addressing, association, and application independence. Mobile users can associate local resources from neighboring devices, build wireless on-demand systems which is independent of location, hardware devices, networking technology and infrastructure availability. Five key design considerations considered were Mobile Peer-to-Peer Overlay, Internet Interworking, Intelligent Overlay Routing, Infrastructure-free Positioning and Application Layer Mobility. Three enhanced mobility models offered in this approach are Personal Mobility (using different IP devices while keeping the same addr ess), Session Mobility (keeping the same session while changing IP devices) and Service Mobility (keeping personal services while moving between networks). The architecture is built on a peer-to-peer communication model to integrate MANETs seamlessly into heterogeneous IP networks. Mobile Peer-to-Peer System(P2P) is a distributed Middleware addresses the demand of direct communication needs by creating spontaneous community. Whenever the Mobile P2P system has global connectivity, it works with its peer system and other applications systems by generic P2P signaling. It consists of Ad-hoc Network layer and Mobile P2P Overlay. The former layer includes wireless hardware and MANET routing software offering homogeneous connectivity among nodes with same wireless interfaces. These nodes act as a router forwarding traffic toward its destination. The later layer includes the following core services: (i) Membership Services offers single sign-on, naming, profile and identity features; (ii) Discovery Services for peer/resource discovery and caching; (iii) Communication Services for Internet interworking, intelligent routing, session control, pres ence and service delivery; (iv) Location Services for infrastructure-free positioning, and user mobility management functions; (v) Adaptation Services for application and network services adaptation. Members of the Mobile P2P system should first sign-in a â€Å"common group† with their exclusive name and password. Some stationary nodes may also join to offer its resources such as Internet connection, printer, video conferencing. Whenever these client devices are within range of each other, they would work together as a team leading to a wireless adhoc service community where local resources could be shared by individual at its will. These members will then be available by intimating their capabilities and location information to the central location server. Information regarding physical location is also essential to offer spatial locality relationships and enable mobile content customization. The results which were achieved through this process can be summarized as first, it maximizes the synergies of MANETs and P2P for building wireless on-demand systems and services. MANETs provide dynamic physical connectivity while P2P offers dynamic associations of entities (users, devices, and services) for direct resources sharing. Second, its Mobile P2P overlay unites mobility, user-centric connectivity, and services for universal communications. This allow dynamic service adaptations pertinent to user location, application requirements, and network environments. Third, it presents a flexible network structure stimulating fixed and wireless networks convergence. The result is an â€Å"Integrated Mobile Internet† which makes our future environment lot better. 2.3 Transparent Heterogeneous Mobile Ad hoc Networks The idea was suggested by Patrick Stuedi and Gustavo Alonso[3]. The paper discussed that performance issues in a personal area network (PAN) or wireless sensor network (WSN) may have less priority than an office network. In contrast, battery life and low cost is vital to PANs and WSN while most probably it is not an issue in an office network. Consider a scenario where in a certain university campus the students carry variety of personal devices like mobile phones, PDA or laptops equipped with different communication technologies tailored to their capabilities. The mobile phones or PDA will be using Bluetooth whereas laptops have 802.11 as well as a Bluetooth interface built in technology. Ubiquitously combining all these devices into one mobile ad hoc network could invite new applications and services such as location based services or VoIP. So there may be an occasion where a personal device of one particular PAN might communicate with a personal device of another PAN in a multi-ho p fashion with the underlying MAC scheme changing per hop. In this scenario two issues needs to be solved i.e. broadcast emulation and handover. Broadcast emulation is not directly supported in Bluetooth (nor on nodes comprising both Bluetooth and 802.11). Handover is an issue because, in the case of heterogeneous MANETs, a handover might include a change in how the medium is accessed. A handover can be caused by node mobility, a change in user preferences (where due to energy constraints the user chooses to use Bluetooth instead of 802.11), or performance reasons. [15] Any device or node supporting multi interface though having different protocol stack will be specific to the interface at lower level. This characteristic will deteriorate the ability of a device to switch from one network to the other. The objective of such network is to provide an end-to-end communication abstraction that hides heterogeneity. The different possible design differs from each other with regard to application transparency, performance and mobility. There is another issue of handover which includes route changes as well as MAC switching. In principle, there are three possible scenarios 2.3.1 Horizontal Handover The horizontal handover between the participating nodes take place when the route changes and underlying MAC technology remains the same. 2.3.2 Vertical Handover The route does not change but the given neighbor is now reached through a new physical interface. 2.3.3 Diagonal Handover The diagonal handover takes when the MAC technology and route between the participating nodes change simultaneously. To address all these issues an IP based heterogeneous mobile ad hoc test bed using Bluetooth and IEEE 802.11 that implements a virtual interface approach as the end-to-end abstraction is presented. 2.4 Stream Control Transmission Protocol Another approach presented by R. Stewart, Q. Xie, and K. Morneault is [16] Stream Control Transmission Protocol, a transport protocol defined by the IETF providing similar services to TCP. It ensures reliable, in-sequence delivery of messages. While TCP is byte-oriented, SCTP deals with framed messages. A major involvement of SCTP is its multi-homing support. One (or both) endpoints of a connection can consist of more than one IP addresses, enabling transparent fail-over between hosts or network cards. Each interface could be separately cond and maintained (AODV-UU [17] e.g., supports multiple interfaces). This solution seems to be quite valuable in terms of performance since SCTP optimizes the transmission over multiple links. In fact, if one particular node can be reached through several interfaces, SCTP switches transmission from one interface to another after a predefined number of missing acknowledgements. Unfortunately, the solution lacks transparency. Applications running traditional unix sockets would have to be changed to use SCTP sockets instead. Another problem arises with the connection oriented nature of Bluetooth. In Bluetooth, interfaces appear and disappear dynamically depending on whether the connection to the specific node is currently up or down. Therefore, this is something that both the ad hoc routing protocol as well as SCTP would have to cope with. 2.5 Global connectivity for IPv6 Mobile Ad Hoc Networks R. Wakikawa, J. T. Malinen, C. E. Perkins, A. Nilsson, and A. J. Tuominen, in 2003 through IETF Internet Draft, 2003 presented Global connectivity for IPv6 Mobile Ad Hoc Networks, suggested one of the solutions for connecting heterogeneous MANETs. Before this work, the issue was solved by the traditional Internet model. But by adopting the approach presented by them the non structured MANETs were made to operate in structured environment, and inevitably limit the extent of flexibility and freedom that an evolving Mobile Internet can offer. Current mobile positioning and network mobility solutions are mainly infrastructure-driven which is contradictory to infrastructure-less MANETs. Without a flexible and user-centric network structure, existing solutions are generally insufficient to handle the dynamic and on-demand requirements of MANETs. 2.6 Conclusion Heterogeneous MANET service architectures and routing protocols have been talked about and it is established that lots of enhancements need to be introduced to the heterogeneous ad hoc networks. First of all, different issues like IP addresses to hostname mapping and seamless communication need to be addressed. Secondly, ad hoc networks must seamlessly utilize all underlying interfaces. Finally, research efforts need to converge towards real-world network deployment as very few MANET service architectures have been evaluated on actual network testbeds. Chapter 3 3 INTEGRATION CHALLENGES 3.1 Introduction The invention of mobile devices like laptops, personal digital assistant (PDA), smart phones and other handheld gadgets having dissimilar communication interfaces smooth the progress of data transmissions without any predetermined infrastructure and centralized administration. [18]. Such data transmissions can only be made on top of infrastructure-less networks composed of fully autonomous mobile nodes. But, these infrastructure-less networks do possess many complexities like dynamic and ever changing topology, heterogeneity in nodes, energy constraints, bandwidth constraints, limited security and scalability. However, there user-friendliness and rapid deployment make them an imperative part of 4th Generation (4G) architecture allowing the mobile users to communicate anytime, anywhere and with the help of any device. 3.2 Technological Challenges The specialized nature of MANETs enforces many challenges for protocol design by incorporating changes in all layers of protocol stack [2]. For instance, all the changes in link characteristics must be dealt with physical layer. MAC Layer should ensure fair channel access and avoidance of packet collision. Calculation of best possible routes among mobile autonomous nodes must be done by the network layer. Transport layer must modify its flow control mechanism to tolerate Packet loss and transmission delays arising because of wireless channel. The continuous making or breaking of connection due to nodes mobility be handled by application layer. These issues at each layer need to be handled effectively in order to smooth the transition from traditional network to advanced MANETs. 3.2.1 The Physical Layer In heterogeneous MANETs there can be a node which may be able to access multiple networks simultaneously. If a node on one hand, is connected to a cellular network, and on the other hand it exists within the coverage area of an 802.11b AP, the network or the node should be able to switch between them. Moreover, in heterogeneous environment, different wireless technologies may operate in the same frequency band and it is significant that they coexist without degrading each others performance. Therefore, techniques to reduce interference between nodes are important. For example, a node communicating with other nodes via multihop path may have lesser interference than a node communicating directly with AP. This is due to the attachment of increased number of nodes to the AP. Another way of reducing interference is Power control techniques applied in code-division multiple access (CDMA)-based cellular networks and MANET [15]. The research issues range from designing considerations to power control techniques include efficient design of nodes that can efficiently switch between different technologies and ensure higher data rates, development of Interference attenuation techniques between various wireless access technologies, modulation techniques and coding schemes that improve the performance of a given technology and frequency planning schemes for increasing the utilization of frequency spectrum 3.2.2 Link Layer The data link layer can be divided into Logical Link Control (LLC) and Medium Access Control (MAC) layers. When a node needs to communicate to another node having cellular interface, it uses a centralized MAC access like Time Division Multiple Access (TDMA) or CDMA with a data rate upto 2.4 Mb/s. On the other hand, when a node communicates in 802.11 environments, it uses distributed random access scheme like Carrier Sense Multiple Access with Collision Avoidance (CSMA/CA) upto a data rate of 11 Mb/s. So, this difference of data rate is going to be one of the interworking considerations. Due to dissimilar access technologies at intermediate hops, the performance of ad hoc networks deteriorates. The problems such as hidden and exposed terminals also limit the capacity of MANETs. The need of evolving mechanisms such as power control and power aware MAC protocols is mandatory to improve the performance of ad hoc networks. In a heterogeneous network, the cross-layer design may play a significant role in providing useful information to upper layers. Another important issue to be considered at the link/MAC level is Security. Although, end-to-end security is the responsibility in the application layer, some wireless access technologies provide a certain level of security at the lower layers. Although the link and MAC layers in a multi-interface node can operate autonomously, but their operations have to be optimized to provide definite service to the upper layers. Some of the open issues include design of efficient link and MAC layer protocols to support QoS in Heterogonous MANET, channel administration schemes that consider different categories of traffic, and allow call blocking and handoff failure probabilities and security at Link / MAC layer. 3.2.3 Network Layer The network layer needs to integrate all underlying communication interfaces; therefore, it is the most challenging task. The presence of nodes with multiple communication interfaces allow to have different physical and MAC layer technologies which need to be taken into account while dealing with an integrated routing process. But, the problem of MANETs such as frequent route changes due to mobility, higher communication overhead to learn and uphold valid routes, higher end-to-end delay and limited end-to-end capacity due to problems at the lower layers are main contributing factors in designing of routing process [19]. In order to reduce network control traffic, improve throughput and increase the range, the idea of integrating MANETs with infrastructure networks is evolved. Hence, mechanism to find gateways and correctly con IP addresses is required by such nodes in a MANET. The network layer has to find the best route between any source and destination pair. To define the best route, including number of hops, delay, throughput, signal strength, and so on several metrics can be used. Moreover, the network layer has to handle horizontal handoffs between the same technology and vertical handoffs between different technologies in a seamless manner. Several routing protocols have been presented for heterogeneous MANETs but the design of integrated and intelligent routing protocols is largely open for research with issues like development of routing capability in a heterogeneous environment that supports all communication possibilities between nodes forming MANET, scalability in multihop routing withou t significantly escalating the overhead and study of the impact of additional routing constraints (like co-channel interference, load balance, bandwidth), and requirements (services, speed, packet delay) needed by nodes and networks. 3.2.4 Transport Layer In connection oriented transport session, as in case of Transmission Control Protocol (TCP), packet loss is assumed to occur due to congestion in the network. This assumptions leads to the performance degradation of TCP and factors such as channel errors, jitter and handoffs are overlooked. Moreover, in heterogeneous environments, the transport protocol has to handle the high delays involved in vertical hands off (while switching from one interface to another), server migration, and bandwidth aggregation [16]. Sometimes, a node changes its IP address when it needs

Charles Dickens Great Expectations Essay -- Great Expectations Charle

Charles Dickens' Great Expectations Introduction: ‘Great Expectations’ was one of Dickens’ best-known novels and was written in 1860. ‘Great Expectations’ is a Bildungsroman and follows the progression of Pip from child to adult; from humble blacksmith to gentleman; from innocence to experience; from rags to riches and on his journey, Pip meets a range of interesting characters, from the comical Wemmick, to the cruel Estella. This novel reflects parts of Victorian times, with class divide, child labour and improving one’s fortunes. Dickens wrote to entertain the public and the public got a say in how the novel progressed due to the fact that Dickens wrote in monthly instalments in a magazine called ‘Household Words’. Dickens even had to re-write the final chapter so that the public was satisfied. Therefore Dickens needed to make his characters striking and memorable so that they were remembered later in the book. This novel also reflects Dickens’ own life experiences. Dickens was poor as a child and throughout his life, he worked his way up and became rich and this is reflected in the story with Pip going from a poor, lower class boy to a rich, upper class gentleman. In this essay I am going to explore how Dickens made his key characters striking and memorable by using different methods. Section 1- Magwitch =================== Dickens wrote ‘Great Expectations’ in the first person perspective of Pip. By doing this Dickens used a method by which he can create memorable and striking characters because the way that Pip reacts to the characters and the way they treat Pip makes us remember them. At the beginning of the book in chapter 1, Pip meets Magwitch, an escaped convict who threatens P... ...ds striking and memorable through use of physical description, setting and speech. The way that the characters interact with Pip is also important. Dickens makes Magwitch striking and memorable because of the way he is introduced through speech and the way he makes Pip and us feel. Miss Havisham is made particularly memorable to the reader, as she is so bizarre- receiving Pip initially in her dressing room and living her life in a time warp. Wemmick is perhaps the character most people can relate to- he is middle class and lives two separate lives. His individualism, his appearance and choice of home make him striking and memorable. The character who makes the biggest impression on me is Mr Wemmick because I think that his house and his actions are very bizarre and I believe he is a funny character and I think he is the character I can relate to.

Break Free From the Product Life Cycle Essay -- essays research papers

Kotler, P. (2003). Positioning and Differentiating Break Free From the Product Life Cycle Youngme Moon Harvard Business Review Summary A company must differentiate itself from others during the product life cycle by creating an image that demands attention and fosters unique brand awareness. Louis Vuitton is a company that continuously rejuvenates itself and has maintained a highly coveted brand for 150 years. A $1,000 monogrammed Louis Vuitton handbag is in such demand that it has spawned a multi-million dollar market of counterfeit products, most commonly referred to as â€Å"knock-offs.† The demand is so high for these knock-off products that LVMH Moet Hennessy, owner of the brand, has a special team that works with international police organizations. Last year there were 6,000 raids by police, resulting in the arrest of nearly 1,000 counterfeiters (LV, 2005). The LV logo has become an icon in the designer luggage, handbags and accessories market. The words Louis Vuitton are the code for describing an internationally recognized and exclusive fashion empire. LVMH Moet Hennessy’s target market is aimed at women aged between 18-35 who have a love of fine design, and the taste for tradition and luxury. Louis Vuitton has maintained its lead in fashion through clever advertising in magazines like â€Å"Vogue† with print ads that focus on LV logo products as chic. In recent years the company has expanded is product line into ready-to-wear, shoes, watches and jewelry. Since 1998, Marc Jacobs has provided the artistic direction to develop and market these new collections. Tapping actress/singer Jennifer Lopez as a model was another key move in skewing younger and getting some zest in print ads. Clearly LVMH Moet Hennessy’s market strategy is its high-quality and high-priced image which is promoted via elaborate packaging, exclusive distribution, and status symbol advertising. This ability to differentiate themselves from the crowded designer marketing place is why they continue to be highly successful and have significantly extended the product life cycle. Relationship/Reference to the Text Our text discusses the product life cycle and how companies must position and differentiate their market offerings throughout the cycle. Youngme Moon points out â€Å"there’s nothing inevitable about the product life cycle. Marketers are disrupting it by rede... ...o find ways to train the next generation of consumers (2005). Branding is 100% human emotion and everything else is just dressed up as rationality to give people permission to act on their emotions. Women (or their spouses--like me) are not buying a Louis Vuitton hand bag, they are buying prestige and the ability to demonstrate to others they are different and have achieved a certain level of status. Some will call it the snob factor, others just chic taste. Regardless of your social views of designer products, Louis Vuitton continues to differentiate themselves in the designer market. It constantly looks for ways to extend the product life cycle through innovative new products and advertising strategies to keep the brand highly recognized and coveted. References Kotler, P. (2003). Positioning and Differentiating the Market Offering Through the Product Life Cycle, Marketing Management, pp. 307-343 Moon, Y. (2005). Break Free From the Product Life Cycle Marketplace   Ã‚  Ã‚  Ã‚  Ã‚  Harvard Business Review, May 2005, pp. 87-94 Vogue (2003) http://www.vogue.com.au Alexandria: FPC Living Louis Vuitton Magazine Online (2005). http://www.vuitton.com/

Nursing Leadership Paper Essay

They have an open concept design, select menus, and our outside landscaping that allows their residents to enjoy a comfortable setting during either their short or long term stay. Their care is directed by an interdisciplinary team of professionals that includes a Medical Director, attending physicians, 24 hour licensed nurses, a dietary manager, activity director, social worker, and therapist for physical, occupational and speech rehabilitation. At Park Manor, the goal is to provide the care and services to meet the physical, emotional and social needs of each of our residents. I got to work with the MDS nurse, an MDS nurse is the nurse in the long term care facility who schedules and completes the RAI-Resident Assessment Instrument, a detailed assessment done at least quarterly on every nursing home resident. The MDS nurse is also usually responsible to coordinate the completion of the care plans for the resident based on the results of the assessment. We were collecting data from a whole bunch of sources; from the nurses, aides, resident, families, doctors, progress notes, therapy notes, etc. Then we completed the paper/computer MDS form based on our complete assessment (using the data collected). A RUG score (or resource utilization grouper) score is generated based upon our answers which is used to determine medicare/medicaide reimbursement rates for the facility. The MDS is used to create the care plan, determines reimbursement rates and determines quality measures/indicators per federal standards. State Surveyors pull these reports prior to inspection visits and to know who is losing weight and who may have pressure ulcers, etc.

Analyzing Indian Transfer Pricing Regulations: a Case Study

International Research Journal of Finance and Economics ISSN 1450-2887 Issue 40 (2010)  © EuroJournals Publishing, Inc. 2010 http://www. eurojournals. com/finance. htm Analyzing Indian Transfer Pricing Regulations: A Case Study Monica Singhania Associate Professor, Faculty of Management Studies (FMS), University of Delhi, India E-mail: [email  protected] du Abstract The Indian Transfer Pricing regulations have been enacted with a view to provide a statutory framework which can lead to computation of reasonable, fair and equitable profit and tax in India so that the profits chargeable to tax in India do not get diverted elsewhere by altering the prices charged and paid in intra-group transactions leading to erosion of Indian tax revenue. Any income arising from an international transaction shall be computed having regard to the arm’s length price (ALP). The ALP shall be determined by any of the prescribed methods, being the most appropriate method. The present paper illustrates the practical aspects of the law regarding transfer pricing as it exists presently in India with the help of a case study. The relevant rules envisage determination of ALP by applying margins of each comparable company to the appropriate base of the enterprise. The regulations further provide that, where more than one price is determined by the most appropriate method, the ALP shall be taken to be the arithmetical mean of such prices. An alternative practical approach to arrive at such ALP is to compute the arithmetic mean of margins of comparable companies and apply the same to the appropriate base of the tested party to determine the ALP. The analysis shows that the mean GP/Sales of comparable companies is 33. 71% while that of the PQR India (i. e. , the tested party) is 44. 20% during the year ended March 31, 2009 indicating that the prices of international transaction of PQR India conform to the arm’s length standard prescribed under the Indian regulations. Further, under Category B, costs recharged by PQR Group to PQR India are included. All these costs represent actual amounts paid by PQR Group to independent third parties and are recovered from PQR India, on a cost-to-cost basis. Applying the comparable uncontrolled price method, these recharges conform to the arm’s length standard prescribed under the Indian regulations. However, there are some practical problems arising out of the applications of transfer pricing egulations, which need to be addressed by the tax administrators as early as possible. These issues include absence of advance pricing agreements (APA) mechanism in India, data limitations, extremely wide definition of associated enterprises in India, stringent penalties, difficulties encountered while conducting economic analysis/benchmarking and many more. Keywords: Transfer Pricing, Tax laws, International transactions, Arms length price 1. Introduction The Indian Transfer Pricing regulations have been enacted with a view to provide a regulatory framework which is capable of computing reasonable, fair and equitable profit and tax in India so that the profits chargeable to tax in India do not get diverted elsewhere by altering the prices charged and 204 International Research Journal of Finance and Economics – Issue 40 (2010) paid in intra-group transactions leading to erosion of Indian tax revenue. Any income arising from an international transaction shall be computed having regard to the arm’s length price (ALP). The regulations on transfer pricing in India were clearly inevitable and long overdue. The regulations in their present form are a product of the findings of the Expert Group set up by the Government of India in November 1999 to study global transfer pricing practices and examine the need for such legislation in India. The Indian transfer pricing regulations applicable with effect from April 1, 2001 are largely based on the OECD guidelines. By manipulating a few book entries in the accounts books, multinational corporations are able to transfer huge profits with practically no actual change in the business process. For instance, X Ltd. manufactures ipods for $ 500 in China, but its US based subsidiary buys it for $ 599, and then sells it for $ 600. By doing this, the company’s taxable profit in the US is substantially decreased. At a 30 percent tax rate, the company’s tax liability in the US is only 30 cents (i. e. , 30% of $ 1) as compared to $30 (i. . , 30% of $ 100 which should have been the case). The large scale tax avoidance practices used by multinational corporations came into public notice when the drug giant MNE, GlaxoSmithKline, agreed to pay the US government $3. 4 billion to settle a long-running transfer pricing dispute over its tax dealings between the UK parent company and its American subsidiary. This was the largest settlement of a tax dispute in the US. Multinational corporations derive several benefits from transfer pricing. Since each country has different tax rates, they can increase their profits with the help of transfer pricing. By lowering prices in countries where tax rates are high and raising them in countries with a lower tax rate, such organizations can reduce their overall tax burden, thereby boosting their overall profits. Indeed one often finds that corporations located in high tax countries in fact pay very little corporate taxes. Transfer pricing features highly on the agenda of Indian tax authorities. The transfer pricing assessments relating to the first two years since the introduction of the Transfer Pricing regulations have seen incremental tax collections arising from transfer pricing adjustments in excess of US$ 800 million. The first round of transfer pricing audits in India of roughly 800 taxpayers resulted in 25% facing adjustments. The cumulative value of those adjustments aggregated US$ 300 million. In the following year, according to estimates, tax demands in excess of US$ 500 million were imposed as a result of upward adjustments. In this connection, the Indian tax authorities had initially set a very conservative threshold for audit INR 50 million (around USD 1 million) for the first four years. This threshold has been enhanced thrice with effect from the financial year 2005-06. The Indian tax authorities have also set up a specialized group for undertaking transfer pricing audits and have begun using confidential comparable data for audit purposes. Scrutiny of overall profitability as well as transactional level pricing during the course of transfer pricing audits is also frequently done. 2. Theoretical Framework The role of multinational enterprises (MNEs) in world trade has increased dramatically over the last 20 years. This reflects the increased integration of national economies and technological progress. Intercompany transactions across borders are growing rapidly and are becoming much more complex. Compliance with the different requirements of multiple overlapping tax jurisdictions is a complicated and time-consuming task. At the same time, tax authorities from each jurisdiction impose stricter penalties, new documentation requirements, increased information exchange and increased audit or inspection activity. With a view to provide a detailed statutory framework which can lead to computation of reasonable, fair and equitable profits and tax in India, in the case of such multinational enterprises, the Finance Act, 2001 substituted the then existing section 92 with sections 92A to 92F in the Income-tax Act, 1961, relating to computation of income from an international transaction having regard to the arm's length price, meaning of associated enterprise, meaning of information and documents by persons entering into international transactions and definitions of certain expressions occurring in the said section (see Appendix I for summary of Indian Transfer Pricing Regulations). The essential International Research Journal of Finance and Economics – Issue 40 (2010) 205 documentation which needs to be maintained for complying with these provisions as also the penalties for default in compliance are given in Appendix I. As per the Indian Regulations, the comparable data to be used in anal yzing the comparability of an uncontrolled transaction with an international transaction should be the data relating to the financial year in which the international transaction has been entered into. However, data relating to a period not being more than two years prior to such financial year may also be considered if such data reveals facts, which could have an influence on the determination of the transfer price in relation to the transactions being compared. The Arm's length principle (ALP) aims at determining whether the parties to a transaction are independent and are on an equal footing. The OECD framework as per Article 9 of the OECD Model Tax Convention ensures that the transfer prices between companies of multinational enterprises are established on a market value basis, avoiding profits being systematically deviated to lowest tax countries. It provides the legal framework for governments to have their fair share of taxes, and for enterprises to avoid double taxation on their profits. The primary onus of proving the arm’s length character of a transaction lies with the taxpayer. If during assessment proceedings, the tax authorities, on the basis of material or information or documents in their possession, are of the opinion that the arm’s length price was not applied, or adequate and correct documents/ information/ data were not maintained/ produced, the total income may be recomputed accordingly after giving the taxpayer an opportunity of being heard. 3. Literature Review There are numerous studies relating to transfer pricing in transactions taking place in developed countries1. This is primarily due to, the detailed statistical information relating to intra-firm trade made available in most of the developed countries, stringent laws requiring greater transparency, etc. In comparison, the availability of intra-firm trade data in developing countries is highly inadequate2. In addition, there is no systematic attempt in developing countries, to collect and analyze relevant data in one information repository database leading to multiple uses of such or ganized information. This is the case even though such information may in many cases exist with different government organizations, legal and administrative authorities and private business organizations engaged in creation of such databases for commercial reasons. This disjointed effort to data collection leads to multiple problems in undertaking quality research studies. It also highlights complete lack of coordination between policies, procedures and their practical application. Also the lack of any government sponsored studies, like those in Colombo, Greece and Sri Lanka, may be the reason why not many transfer pricing studies are undertaken in such countries. In United Kingdom, the transfer pricing rules were formulated as early as in 1915 [(Payan and Wilkie (19933)]. However, there was little pressure on such rules until mid 1960s when the revival of international trade and investment following World War II began. As far as United States is concerned, even before the non-traditional methods of transfer pricing were added to section 482, Schindler and Henderson (1985)4 pointed out, â€Å"Inter-corporate transfer pricing under the scope of code section 482 is one of the most complex areas of international taxation. † The non-traditional methods further added to complexity. The OECD’s Transfer Pricing Guidelines (1995)5, based on guidelines first issued in 1979, 1. Lall S. 1973), â€Å"Transfer Pricing by Multinational Manufacturing Firms†, Oxford Bulletin of Economics & Statistics, Vol. 35(3), pp. 173-95. 2 Bhagwati J. N. (1974), â€Å"On the Under Invoicing of Imports, Fiscal Polices of the Faking of Foreign Trade De clarations of the Balance of Payments†, in Bhagwati (ed. ), Illegal Transactions in International Trade, North Holland Publishing Co. 3 Pagan, Jill C. and J. Scott Wilkie, (1993) â€Å"Transfer Pricing Strategy in a Global Economy†, Amsterdam: IBFD Publications. 4 Schindler, Geunter and David Henderson (1985),â€Å" Intercorporate Transfer Pricing: 1985 Survey of Section 482 Audits,† Tax Notes, Vol. 29, pp. 1171-77. 5 OECD (1995, as updated). Transfer Pricing Guidelines (Paris: OECD). 206 International Research Journal of Finance and Economics – Issue 40 (2010) largely influence international practice with regard to transfer pricing. The Indian transfer pricing regulations, introduced in 2001, are to an extent modeled on the OECD guidelines. Li (2003)6 describes the methods of transfer pricing by way of an international comparison involving six countries namely, China, Hong Kong, Japan, Canada, United States and Singapore. Ring (2000)7 explains the methodology of undertaking Advance Pricing mechanisms whereby both the tax payers as well as tax administrators agree in advance on the methodology to be used to determine transfer prices in order to avoid unnecessary litigation. Lall (1979)8 highlights the need of a laid back attitude towards transfer pricing in developing countries so as to remain an attractive investment destination in the form of foreign direct investment. R. Murray [1981]9 studied the mechanism by which international tax avoidance is achieved. These mechanisms include general manipulations as well as specific manipulations to items in the profit and loss account and balance sheet. Baistrocchi (2004)10 explains the administrative inexperience of developing countries in implementing transfer pricing rules. Mo (2003)11 gives instances of manipulation of transfer prices and steps taken to combat it in China, India, Brazil and Mexico. UN Survey (1999)12 reveals that in developing countries about 61 per cent respondents felt that the domestic multinational enterprises were engaged in income shifting and 84 per cent believed that foreign enterprises were doing so. In addition, 70 per cent and 87 per cent, respectively, of these countries thought the problem to be significant. Newlon (2000)13 notes the tendency of MNCs to over report income in jurisdictions that impose heavy penalties. Mitchell (2004)14 treats worldwide taxation as a form of tax harmonization. According to his view, tax harmonization is categorically undesirable because â€Å"taxpayers are unable to benefit from better tax policy in other nations and governments are insulated from market discipline†. 4. PQR India: Case Study Design and Analysis Global Tax Consultants Pvt. Ltd. ave been engaged by PQR India to review the transfer pricing arrangements for international transactions with its associated enterprises during the year ended March 31, 2009 on the terms set out in the engagement letter. The objective of this paper is to establish whether the international transactions between PQR India and its associated enterprises adhere to the arm’s length principle, embodied in the Indian Transfer Pricing Regulations of the Indian Income-Tax Act, 1961(see Appendix I) and in addition look to the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations published by the Organization for Economic Cooperation and Development for further guidance in applying the arm’s length standard. 6 Li, Jinyan (2003), â€Å" International Taxation in the Age of Electronic Commerce†: A Comparative Study (Toronto: Canadian tax Foundation). 7 Ring, Diane M. (2000). â€Å"On the Frontier of Procedural Innovation: Advance Pricing Agreements and the Struggle to Allocate Income for Cross Border Taxation,† Michigan Journal of International Law, Vol. 21 (winter) pp. 143-234. 8 Lall, Sanjaya. (1979). â€Å"Transfer Pricing and Developing Countries: Some Problems of Investigation,† World Development, Vol. 7 Issue 1 (January), pp. 59-71. 9 Murray R. Editor (1981), â€Å"Multinationals Beyond the Market: Intra-firm Trade and the Control of Transfer Pricing†, London: Harvester Press Brighton, pp. 119-32. 10 Baistrocchi, Eduardo. (2004). The Arm's Length Standard in the 21st Century: A Proposal for both Developed and Developing Countries. † Tax Notes International, Vol. 36 No. 3 (October 18), pp. 241-255. 11 Mo, Phyllis Lai Lan. (2003); â€Å"Tax Avoidance an d Anti-avoidance Measures in Major Developing Economies† (Westport, Conn. : Praeger), pp. 207. 12 United Nations Conference on Trade and Development (1999), Transfer Pricing. (New York). 13 Newlon, T. Scott. (2000). â€Å"Transfer Pricing and Income Shifting in Integrating Economies,† in Sijbren Cnossen, editor, Taxing Capital Income in the European Union: Issues and Options for Reform (Oxford: Oxford University Press), pp. 214-42. 14 Mitchell, Daniel J. (2004). â€Å"The Economics of Tax Competition: Harmonization vs. Liberalization,† in 2004 Index of Economic Freedom, Marc Miles, et al. , editors, (Washington: Heritage Foundation), Chapter 2. International Research Journal of Finance and Economics – Issue 40 (2010) 4. 1. Company Profile 207 PQR Group, USA deals in design, manufacture and marketing of the state of the art photocopier machines. In addition, it also offers document management solutions, one-to-one marketing expertise and efficiency management services for various organizations in the United States and internationally. PQR India is a wholly-owned subsidiary of PQR Group, USA. PQR India commences business of import and resale of photocopier machines imported from PQR Group during the financial year 200809. The development of the arm's length price in this analysis recognizes that PQR India is a distributor of photocopier machines in India and is exposed to ordinary risk profile associated with such class of businesses. PQR India, leverages on all the valuable intellectual property rights (knowhow, copyrights etc. ) and other commercial or marketing related intangibles (brand names, trademarks etc. ) owned by PQR Group. Based on the functional analysis, PQR India has relatively less complicated operations and as such bears relatively lesser share of risks and is accordingly selected as the tested party for the purpose of carrying out the economic analysis as part of determination of transfer price on the basis of arms length principle. 4. 2. Industry Overview As per the Indian Regulations (see Appendix 1), every person who has entered into an international transaction shall keep and maintain interalia, the information and documents giving a broad description of the industry in which the assessee operates. The Indian Regulations also prescribe that the comparability of an international transaction with an uncontrolled transaction shall be judged with reference to the conditions prevailing in the markets in which the respective parties to the transactions operate. Hence, for the purposes of the transfer pricing analysis a comprehensive overview of the industry is essential. Industry overview essentially consists of industry background, evolution of industry, characteristics of marketing, emerging industry trends, key drivers, key inhibitors and future outlook for the industry. 4. 3. Functional Analysis As per the Indian Regulations, every person who has entered into an international transaction shall keep and maintain inter alia, a description of the functions performed, risks assumed and assets employed or to be employed by the assessee and by the associated enterprises involved in the international transaction. A functional analysis enables mapping of the economically relevant facts and characteristics of transactions between associated enterprises with regard to their functions, assets and risks. Hence a functional analysis facilitates characterization of the associated enterprises and assists in establishing a degree of comparability with similar transactions in uncontrolled conditions. 4. 3. 1. Functions performed by PQR Group PQR Group, USA deals in design, manufacture and marketing of the state of the art photocopier machines. In addition, it also offers document management solutions, one-to-one marketing expertise and efficiency management services for various organizations in the United States and internationally. In addition, it has a massive research and development center. 4. 3. 2. Functions performed by PQR India PQR India is engaged in the business of import and resale of photocopier machines imported from PQR Group. To understand the functions performed by PQR India, it is important to have an overview of the transactions taking place, which are depicted below: Transactions classified as Category A: Import of finished goods by PQR India and thereafter wholesale distribution by PQR India 208 International Research Journal of Finance and Economics – Issue 40 (2010) Transactions classified as Category B: Cos recharges are PQR Group from PQR India Functions performed by PQR India under Category A: PQR India, as a wholesale distributor performs a variety of functions including sales, marketing, after sales support, etc. Category B – Cost recharges: Under Category B transactions, cost-to-cost recharges on account of certain expenses incurred by PQR Group on behalf of PQR India are included. Assets employed: Any business requires assets (tangible or intangible) without which it cannot carry out its activities. Intangibles play a significant role in the functioning of a business and are accordingly more important. An understanding of the assets employed and owned by PQR India provides an insight into the resources deployed by PQR India and their contribution to the business processes/economic activities of PQR India. Tangibles owned by PQR India: It includes electrical installations, furniture and fixture, office equipments and computer hardware. Intangibles: PQR India being a relatively new company does not own any significant intangibles and does not undertake any significant research and development on its own account that leads to the development of non-routine intangibles. PQR India uses the trademarks, process, know-how, technical data, software, operating/quality standards etc. developed/owned by PQR Group. All companies of the group leverage from these intangibles for continued growth in revenues and profits. . 4. Overview of Inter-Company Transactions PQR India engages in the following inter-company transactions with its associated enterprises: Import of finished goods, import of spar e parts and consumables and cost recharges. The above transactions have been grouped together in two classes namely Category A and Category B which have been separately analyzed from a transfer pricing perspective. 4. 5. Selection of Tested Party The tested party is the participant in the controlled transaction whose profit attributable to the controlled transaction can be verified using the most reliable data and requiring the fewest and most reliable adjustments. In ost cases, the tested party is the least complex of the controlled taxpayers, that is, the taxpayer with the least amount of risk associated with its operations and without valuable intangibles or unique assets that may distinguish it from potential uncontrolled comparable companies. Based on the above, PQR India is clearly the tested party for purposes of this analysis. It does not own an interest in any of the valuable know-how, patents, brand names and trademarks owned by the PQR Group. PQR Group, on the other hand, may own valuable intellectual property rights including commercial and marketing intangibles. Therefore, the comparability adjustments that would be required if independent organizations were to be selected as tested parties, would be both substantial and unreliable. 4. 6. The Most Appropriate Method The ‘most appropriate method’ is that method which, under the facts and circumstances of the transaction under review, provides the most reliable measure of an arm’s length result. In determining the reliability of a method, the two most important factors that need to be taken into consideration are: (i) the degree of comparability between the controlled and uncontrolled transactions and (ii) the coverage and reliability of the available data. Because the selection of the â€Å"most appropriate method† involves a test of relative merit, a method that may not be perfect is not rejected unless some other method can be shown to be more reliable or clearly indicating to provide a better estimate of an arm's length result. International Research Journal of Finance and Economics – Issue 40 (2010) 209 Selection of the Most Appropriate Method Comparable Uncontrolled Price Method (CUP): In practice, there are two types of comparable uncontrolled transactions. The first, known as an â€Å"internal comparable,† is a transaction between one of the parties to the controlled transaction and an unrelated third party. The second, known as an â€Å"external comparable,† is a transaction between two unrelated third parties. There are no internal CUPs available for all products imported by PQR India to benchmark its transactions under Category A. PQR India is engaged in import of finished goods and spares consumables for resale in India under Category A (all related to photocopier machines). However, PQR India does not purchase same/similar products from entities other than associated enterprises. Further, during the year, until the commencement of commercial operations by PQR India, overseas gr oup entities sold some similar products to a third party in India. The third party was a Tier-II distributor of PQR Group whereas PQR India acts as a Tier-I distributor. In this way due to unavailability of adequate data to make suitable adjustments to account for the aforesaid differences, it was considered inappropriate to use the third party as an internal comparable in the present case. Therefore, CUP method was not considered for the purpose of ascertaining an arm’s length price for the international transactions of PQR India under Category A. As for external comparables, it may be highlighted that the arm's length price as far as uncontrolled enterprises are concerned, is substantially dependent upon factors such as volume, contractual terms, location differences, etc. It may not be possible to estimate with reasonable reliability and accuracy, the combined effect of such factors on per unit prices in case of external comparables. Further, abstract factors such as use of intangibles make the use of CUP method difficult for benchmarking purposes. In view of the above, there are no external comparables available, which may be considered sufficiently appropriate to warrant the use of the CUP method for Category A transactions of PQR India. However, in case of transactions in the nature of costs recharges by PQR Group to PQR India, included under Category B, the third party cost reimbursed is a CUP for the reimbursement. Keeping in view the nature of transaction and the degree of comparability, CUP was considered as the most appropriate method for this class of transactions. Consequently other methods were not considered. Cost Plus Method (CPM) PQR India is a distributor. It imports the finished products, spares and consumables from the Group companies (all related to photocopier machines) and resells them in the domestic market. In this way, in this case PQR India carries out the function of a pure reseller. Since RPM is most appropriate in cases involving the purchase and resale of tangible goods, this method was considered as the most appropriate method for deriving the arm’s length price of PQR India under Category A. The application of CPM is ordinarily appropriate in two situations, the provision of services to a related party and the manufacture of tangible goods that are sold to a related party. PQR India on the other hand, operates as a distributor under Category A. Accordingly, CPM was not considered as the most appropriate method for deriving the arm’s length price for Category A transactions of PQR India. Profit Split Method (PSM): PSM is typically applied where each party to the transaction under evaluation has significant intangible assets and/or the operations of the parties to the transaction are highly integrated and cannot be evaluated on a separate basis. Also, in general, the PSM relies primarily on the internal data and assumptions pertaining to each party to the controlled transaction instead of relying on comparable uncontrolled transactions as market benchmarks, thus making the use of the PSM ordinarily less reliable than the other methods. PQR India does not own any non-routine intangibles and further the operations of PQR India can be independently evaluated. Therefore, PSM was not considered as the most appropriate method for deriving the arm’s length price of PQR India’s international transactions under Category A. Transactional Net Margin Method (TNMM) Net profits may however, be influenced by some factors that either do not have an effect or have less substantial or direct effect on gross margins. Such factors in the case of PQR India include several 210 International Research Journal of Finance and Economics – Issue 40 (2010) extraneous factors which have been in the later write up. The losses made by the Company at the operating level, in the current financial year, is a result of these factors. The reasons for loss at operating level under Category A were: a) First year of operations and b) Acquisition of mailing business. These additional expenses incurred by the company during the year adversely impacted its profitability at the operating level. However, these expenses were necessary business expenses which had to be incurred in the first year of operations. Given the aforementioned state of affairs, in order to ensure fair comparison of the operating profitability of the company with comparable companies in the industry, one would need to make suitable economic adjustments to appropriately take into account the impact of the aforesaid acquisition of new business by the company. Conclusions of the Most Appropriate Method After reviewing all of the transfer pricing methods, we recommend given the fact and circumstances, the RPM provides the most reliable measure of an arm’s length result for Category A transactions of PQR India. CUP has been selected as the most appropriate method for the international transactions undertaken by PQR India under Category B. 4. 7. Search for Uncontrolled Comparables Databases: The two most popular and widely recognized corporate databases (i. e. , Powers & Capitaline) to identify potential uncontrolled comparables for PQR India transactions under Category A. The primarily focus was on Prowess and additional companies were considered Capitaline Plus, i. e. , companies for which data was not available in the Prowess database. Selection of time period: As per the Indian Regulations, the data to be used in analyzing the comparability of an uncontrolled transaction with an international transaction shall be the data relating to the financial year in which the international transaction has been entered into. However, data relating to a period not being more than two years prior to such financial year may also be considered if such data reveals facts which could have an influence on the determination of the transfer price in relation to the transactions being compared. The present analysis involves data analysis of companies from both databases only if they had relevant financial data for at least two out of the three financial years ending during the period April 1, 2006 and March 31, 2009. This has been done in order to eliminate, to the maximum extent possible, any variance in results caused by short-term differences in business cycles, product life cycles or business strategies of individual companies. Search Process Our comparable search strategy identified Indian independent distributors whose functions, assets and risks were broadly comparable to those of PQR India under Category A. International Research Journal of Finance and Economics – Issue 40 (2010) Search from Prowess Criteria for selection Total number of companies whose information is available on Prowess as on March 31, 2009 Number of companies having positive sales and ratio of sales trading to sales of more than 40% over the relevant time period under consideration were selected so as to capture all possible traders available in Prowess Number of companies herein sales trading as a percentage of sales was higher than 75% were short listed, in order to eliminate companies that were primarily not engaged in trading activity Selection of only those companies with a positive net worth Qualitative Analysis, to eliminate companies operating in industries other than electronics, electrical machinery and miscellaneous distributors and to eliminate controlled/controlling companies 211 No. of Companies achieving the criterion 12,994 1,050 565 496 5 Search from Capitaline Plus Criteria for selection Total number of companies whose information is available on Capitaline Plus as on March 31, 2009 Identified additional companies with positive sales over the time period under consideration were selected i. e. companies for which information was primarily not available in Prowess database Selected companies classified in the ‘Electronics’, ‘Miscellaneous Manufactured Articles’, ‘Electrical machinery other than electronics’ and ‘Non-electrical machinery’ industries Selection of only those companies with a positive net worth Qualitative An alysis, to eliminate companies not engaged in trading activities in the same/ similar industry segment and to eliminate controlled/controlling companies. No. of companies achieving the criterion 8,160 1,650 228 86 2 Finally, at the end of the above described search process from both the databases, we were left with 7 comparable companies for benchmarking Category A transactions of PQR India. 4. 8. Choice of a Profit Level Indicator (PLI) The application of RPM requires the selection of an appropriate Profit Level Indicator (PLI). The PLI measures the relationship between (i) profits and (ii) either costs incurred, revenues earned, or assets employed. A variety of PLIs can be used. Factors relevant to the selection of the appropriate profit level indicator include the reliability of the available data and the extent to which the profit level indictor takes into account costs that would be considered by independent parties. Gross Profit Margin is the ratio of Gross Profit to Sales (GP/Sales) and was selected to reliably measure the income of PQR India that it would have earned had it dealt with uncontrolled parties at arm’s length under Category A. 4. 9. Determination of Arm’s Length Results The Indian Regulations require that the Arm’s Length Price (ALP) in relation to an international transaction shall be determined by any of the prescribed methods (CUP, RPM, CPM, TNMM and PSM), being the most appropriate method. All methods other than CUP are methods that enable determination of ALP on the basis of respective margins earned by comparable uncontrolled companies. The relevant rules envisage determination of ALP by applying margins of each comparable company to the appropriate base of the enterprise. The regulations further provide that, where more than one price is determined by the most 212 International Research Journal of Finance and Economics – Issue 40 (2010) ppropriate method, the ALP shall be taken to be the arithmetical mean of such prices. An alternative practical approach to arrive at such ALP could be to compute the arithmetic mean of margins of comparable companies and apply the same to the appropria te base of PQR India to determine the ALP. Arm’s Length Results S. No. 1 2 3 4. 5. 6. 7. 8. 9. 10. 11. Name of the Company X1 India Ltd. X2 India Ltd. X3 India Ltd. X4 India Ltd. X5 India Ltd. X6 India Ltd. X7 India Ltd. Mean Median Upper Quartile Lower Quartile Data Source Prowess Prowess Prowess Prowess Prowess Capitaline Plus Capitaline Plus GP/Sales (%) 30. 00 40. 00 35. 00 28. 00 22. 00 45. 0 36. 00 33. 71 35 38. 00 29. 00 The above analysis shows that the mean GP/Sales of comparable companies under Category A is 33. 71%. Hence, prices of international transactions of PQR India under Category A, that achieve GP/Sales of 33. 71% or more would conform to the arm’s length standard prescribed under the Indian regulations. The financial results of PQR India indicate that the company has GP/Sales of 44. 20% during the year ended March 31, 2009. For Category A transactions, GP/Sales of PQR India are higher than the mean GP/Sales of comparable companies. Further, under Ca tegory B, costs recharged by PQR Group to PQR India are included. All these costs represent actual amounts paid by PQR Group to independent third parties and are recovered from PQR India, on a cost-to-cost basis. Applying the CUP method, these recharges conform to the arm’s length standard prescribed under the Indian regulations. The above analysis provides evidence that both the pricing basis itself of international transactions of PQR India during the financial year 2008-09 and the outcome of the pricing i. e. , the profitability were in accordance with the ‘Arm’s Length’ standard prescribed under the Indian Transfer Pricing Regulations. 5. Summary and Recommendations The regulations on transfer pricing in India were indeed inevitable and long overdue. The case study of PQR India clearly demonstrates the computation procedure required to be followed for scientifically determining the arm’s length price as per the provisions of transfer pricing in India. The analysis shows that the mean GP/Sales of comparable companies is 33. 71% while that of the PQR India (i. e. , the tested party) is 44. 20% during the year ended March 31, 2009 indicating that the prices of international transaction of PQR India conform to the arm’s length standard prescribed under the Indian regulations. Further, under Category B, costs recharged by PQR Group to PQR India are included. All these costs represent actual amounts paid by PQR Group to independent third parties and are recovered from PQR India, on a cost-to-cost basis. Applying the comparable uncontrolled price method, these recharges conform to the arm’s length standard prescribed under the Indian regulations. However, there are some practical problems arising out of the applications of transfer pricing regulations, which need to be addressed by the tax administrators as early as possible. These issues include absence of advance pricing agreements (APA) mechanism in India, data limitations, extremely wide definition of associated enterprises in India, stringent penalties, difficulties encountered while conducting economic analysis/benchmarking and many more. International Research Journal of Finance and Economics – Issue 40 (2010) 213 References [1] Baistrocchi, Eduardo. (2004). The Arm's Length Standard in the 21st Century: A Proposal for both Developed and Developing Countries. † Tax Notes International, Vol. 36 No. 3 (October 18), pp. 241-255. Bhagwati J. N. (1974), â€Å"On the Under Invoicing of Imports, Fiscal Polices of the Faking of Foreign Trade Declarations of the Balance of Payments†, in Bhagwati (ed. ), Illegal Transactions in International Trade, North Holland Publishing Co. Lall S. (1973), â€Å"Transfer Pricing by Multinational Manufacturing Firms†, Oxford Bulletin of Economics & Statistics, Vol. 35(3) pp. 173-95. Lall, Sanjaya. (1979). â€Å"Transfer Pricing and Developing Countries: Some Problems of Investigation,† World Development, Vol. Issue 1 (January), pp. 59-71. Li, Jinyan (2003), â€Å"International Taxation in the Age of Electronic Commerce†: A Comparative Study, Toronto: Canadian tax Foundation. Mo, Phyllis Lai Lan. (2003), â€Å"Tax Avoidance and Anti-avoidance Measures in Major Developing Economies†, Westport, Conn. : Praeger, pp. 207. Mitchell, Daniel J. (2004), â€Å"The Economics of Tax Competition: Harmonization vs. Liberalization,† in 2004 Index of Economic Freedom, Marc Miles, et al. , editors, Washington: Heritage Foundation, Cha pter 2. Murray R. Editor (1981), â€Å"Multinationals Beyond the Market: Intra-firm Trade and the Control of Transfer Pricing†, London: Harvester Press Brighton, pp. 119-32. Newlon, T. Scott. (2000), â€Å"Transfer Pricing and Income Shifting in Integrating Economies,† in Sijbren Cnossen, editor, Taxing Capital Income in the European Union: Issues and Options for Reform (Oxford: Oxford University Press), pp. 214-42. OECD (1995, as updated). Transfer Pricing Guidelines (Paris: OECD). Pagan, Jill C. and J. Scott Wilkie (1993), â€Å"Transfer Pricing Strategy in a Global Economy†, Amsterdam: IBFD Publications. Ring, Diane M. (2000). â€Å"On the Frontier of Procedural Innovation: Advance Pricing Agreements and the struggle to allocate Income for Cross Border Taxation†, Michigan Journal of International Law, Vol. 21 (winter), pp. 143-234. Schindler, Geunter and David Henderson (1985), â€Å"Inter corporate Transfer Pricing: 1985 Survey of Section 482 Audits,† Tax Notes, Vol. 29, pp. 1171-77. United Nations Conference on Trade and Development (1999). Transfer Pricing (New York). [2] [3] [4] [5] [6] [7] [8] [9] [10] [11] [12] [13] [14] 214 International Research Journal of Finance and Economics – Issue 40 (2010) Appendix I Indian Transfer Pricing Regulations Legal Position: The Finance Act 2001 introduced with effect from assessment year 2002-2003, detailed Transfer Pricing regulations vide section 92 to 92F of the Income Tax Act, 1961. The Central Board of Direct Taxes (CBDT) has come out with Transfer Pricing Rules – Rule 10A to Rule 10E. Applicability: Transfer pricing provisions are applicable based on fulfillment of two conditions: Firstly, there must be an international transaction. Secondly, such an international transaction must be between two or more associated enterprises, either or both of whom are non-residents. Pricing Method permitted: Arm's Length Price is to be determined by adopting any one of the following methods, being the most appropriate method: Comparable Uncontrolled Price method, Resale Price Method, Cost Plus Method, Profit Split Method, Transaction Net Margin Method, or any other method prescribed by the Central Board of Direct Taxes (CBDT). Documentation/Return: 13 different types of documents are required to be maintained. These include – 1) Enterprise-wise documents:-Description of the enterprise, relationship with other associated enterprises, nature of business carried out. 2) Transaction-specific documents:-Information regarding each transaction, description of the functions performed, assets employed and risks assumed by each party to the transaction, Economic & Market Analysis etc. 3) Computation related documents:-Describe in details the method considered, actual working assumptions, policies etc. , adjustment made to transfer price, any other relevant information, data, documents relied for determination of arm's Length price etc. A report from a Chartered Accountant in the prescribed form giving details of transactions is required to be submitted within a specific time limit. Penalty: Penalty for concealment of income or furnishing inaccurate particulars thereof100% to 300% of the tax sought to be evaded. Penalty for failure to keep and maintain information and documents in respect of International transaction2% of the value of each international transaction Penalty for failure to furnish report under section 92E- Rs. 1,00,000. OECD Guideline: No reference to OECD guidelines under Indian Transfer Pricing regulations No provisions regarding Advance Pricing Agreements Advance Pricing Agreement: under Indian law as of now Government web-link: www. incometaxindia. gov. in Source: OECD Transfer Pricing Country Profilehttp://www. oecd. org/dataoecd/9/4/42236399. pdf