Pricing Agreements Research Articles

MANAGING GLOBAL SUPPLY CHAIN: TRANSFER PRICING ISSUES AND SOLUTIONS

World trade of goods and services is based upon the global supply chain and logistics management, and its flow is determined by the drivers of supply chain management. For a company to be successful in the new millennium where a paradigm shift has taken place it becomes necessary that its supply chain strategy gets fit with its competitive strategy so as to strike an appropriate balance between the supply chain’s efficiency and responsiveness. One of the supply chain management’s drivers, to achieve this fit is known as “Pricing”. In the context of global supply chain management, Transfer Pricing, with its components such as Arm’s Length Pricing (ALP), Advance Pricing Agreement (APA), Safe Harbour Rules (SHRs), etc. play a very important role and, therefore, in this paper an attempt has been made to explain issues relating to transfer pricing vis-à-vis solution for the same, so that MNEs may operate and supply their tangibles and intangibles to their related companies globally without having any disputes / litigations with a the taxation authorities.

Export Policy – Import And Related Parties In Letter Of Credit

International trade policy is carried out to stabilize the economy that occurs between several countries. International Trade with this Letter of Credit is a sale and purchase price agreement carried out before international trade activities. This study aims to find out how policies in export and import activities use a Letter of Credit and parties participating in import export activities. The use of the method in this study is to use the type of analysis method in a qualitative way based on data from several sites such as Emerald, ScienceDirect, and Google Scholar. We find that international trading has a positive impact, namely encouraging manufacturing activities, making economic growth increase, employment rates increasing, financial institutions gaining trust and domestic needs will be met. Based on the concept of national economic strategy, policies in conducting international trade are divided into two types. First, the policy of free trade. This policy explains if the government gives permission to carry out exports and imports without interference from various rules. This import-export activity has an influence on the competition between each country. Second, trade defense policy. This policy explains if there is government interference in export and import activities. This government intervention is to protect various sectors that carry out export and import activities in order to survive in international competition.

Analisis Supply Chain Management (SCM) Perdagangan Ikan Hiun di PPS Lampulo Banda Aceh

This study aims to identify the structure of the Shark supply chain pattern and analyze the additional income margins of fishermen on the shark trade at PPS Lampulo, Banda Aceh. The population in this study were all fishermen and all traders who carried out shark trading activities in the area around PPS Lampulo, Banda Aceh city. The number of samples taken in this study were 13 respondents. The respondents are 5 fishermen and 8 traders who are around the PPS Lampulo area, Banda Aceh city. Sampling using snowball sampling technique. The research method used to support the perfection of the research to be carried out, the research uses qualitative analysis methods. The results showed that the supply chain model for sharks at PPS Lampulo is fishermen who rent boats, who carry out shark fishing activities at sea, wholesalers or Toke who buy sharks to be distributed / resold, or to be processed and then sold in product form. processed. Retailers, consisting of traveling merchants, who buy Sharks from wholesalers on a retail basis. Consumers, namely final buyers who buy Sharks for consumption, either inside or outside. Fishermen do not deal directly with the final consumer in distributing their products, but through traders/bench toke who are direct consumers for fishermen. Fishermen are the main suppliers who supply sharks to wholesalers/toke. Fishermen supply their catch to contractors through PPS Lampulo. The wholesaler/toke must come to PPS to buy/order sharks and must get a price agreement with the fishermen.

E-Procurement System In The Mechanism Of Procurement Of Goods And Services Electronically

In the implementation of State Life, the government is always required to promote public welfare. Because there is no country that does not have a purpose and diverse purposes of that country. To carry out this obligation, the government has an obligation to provide the needs of the people in various forms in the form of goods, services and infrastructure development. on the other hand, the government also needs the goods and services in implementing the government, for that it is necessary to procure goods and services. Procurement of goods and services is essentially an effort by the user to obtain or realize the goods and services he wants by using certain methods and processes in order to achieve an agreement on price, time and other agreements. In order for the nature and essence of the procurement of goods and services can be carried out as well as possible, then both parties, namely the users and providers, must always be based on the philosophy of procurement of goods and services, subject to the ethics and norms of procurement of goods and services that apply, follow the principles, methods and processes of procurement of goods and services that are standard. In the system of procurement of Good Goods and services is a system of procurement of goods and services that are able to apply the principles of good governance and Clean Governance (Good Governance and Clean Governance), encourage the efficiency and effectiveness of public spending, as well as structuring the behavior of the three pillars (government, private and public).

Advance Pricing Agreement between Multinational Companies and the Government of Indonesia in the perspective of Indonesian Tax Law

APA (Advance Pricing Agreement) is an agreement between the Directorate General of Taxes and Taxpayers and/or other country's tax authorities to agree on the criteria and/or determine the fair price or fair profit in advance of the parties who have a Special Relationship. APA generally occurs between Tax Authorities and Multinational Enterprises. The purpose of APA is to provide facilities for taxpayers to resolve transfer pricing problems. Transfer pricing is a company policy in determining the transfer price of a transaction, be it goods, services, intangible assets, or financial transactions carried out by the company. Transfer pricing is often connoted with something bad, namely a transfer of income from a company in a country with a higher tax rate to another company in a group in a country with a lower tax rate, thereby reducing the total tax burden of the group of companies. One of the challenges faced when transfer pricing occurs in Indonesia is between the Indonesian Tax Authorities and Multinational Companies. For this reason, it is necessary to take legal measures to minimize the occurrence of transfer pricing and also avoid losses to the stateKeywords: Advance Pricing Agreement, transfer pricing, Double-taxation, tax. AbstrakAPA (Advance Pricing Agreement) merupakan perjanjian antara Direktorat Jenderal Pajak dan Wajib Pajak dan/atau otoritas pajak negara lain untuk menyepakati kriteria-kriteria dan/atau menentukan harga wajar atau laba wajar dimuka para pihak yang mempunyai hubungan stimewa. APA pada umumnya terjadi antara Otoritas Pajak dengan Perusahaan Multinasional (Multinational Enterprise). Adapun tujuan dari APA ialah untuk memberikan sarana kepada Wajib Pajak guna menyelesaikan permasalahan transfer pricing. Transfer pricing merupakan kebijakan perusahaan dalam menentukan harga transfer suatu transaksi baik itu barang, jasa, harta tak berwujud, atau pun transaksi finansial yang dilakukan oleh perusahaan. Transfer pricing sering dikonotasikan dengan sesuatu yang buruk yaitu suatu pengalihan penghasilan dari suatu perusahaan dalam suatu negara dengan tarif pajak yang lebih tinggi ke perusahaan lain dalam satu grup di negara dengan tarif pajak yang lebih rendah sehingga mengurangi total beban pajak group perusahaan tersebut. Salah satu tantangan yang dihadapi apabila transfer pricing terjadi di Indonesia antara Otoritas Pajak Indonesia dengan Perusahaan Multinasional. Maka dari itu perlu adanya upaya hukum yang dilakukan untuk meminimalisir terjadinya transfer pricing dan juga menghindari terjadinya kerugian pada negara.Kata Kunci: Advance Pricing Agreement, transfer pricing, pengenaan pajak berganda, pajak

Implementation of Advance Pricing Agreement Regulation as Transfer Pricing Dispute Prevention in Indonesia

In March 2020, the Ministry of Finance issued a PMK-22/2020 which stipulates the Advance Pricing Agreement whilst aligning the Indonesian advance pricing agreement regulation with BEPS Action 14 to provide more legal certainty.

PASAR RAKYAT PONTIANAK TIMUR

The market is a place or area that has existed for a long time as a place to interact in buying and selling to meet needs. The market visually and functionally must be able to provide a sense of comfort and security in the activity. People's Market (public market) has its own characteristics, namely the pattern of interaction between sellers and buyers, such as bargaining between traders and buyers to get a finished price agreement. People's Market (public market) is a common means that must exist in every region. The population of Pontianak city is quite dense, especially in the East Pontianak Subdistrict, Pontianak City. In this region does not have a market that provides complete needs such as Super Market, Public Market and so on. The design of this final task aims to design the concept of a public market area that is easily accessible and can meet the needs of the people in the East Pontianak area and surrounding areas. The scope of the design in this case is to include a fundamental discussion of the design, function of the activities accommodated, supporting facilities and adapted to the design of the public market with current technology. So obtained a concept of The public market area around East Pontianak District that is easily accessible and can meet the needs of the community in the Tanjung Raya 2 road area and surrounding areas.

Stable allocations for choice-based collaborative price setting

Horizontal price agreements can fall within the scope of exemptions to antitrust competition if they are expected to create pro-consumer benefits. Inspired by such horizontal agreements, we introduce a cooperative game in which a set of transport operators can collectively decide at what price to offer sustainable urban mobility services to a pool of travelers. The travelers choose amongst the mobility services according to a multinomial logit model, and the operators aim at maximizing their joint profit under a constant market share constraint. After showing that various well-known allocation rules (i.e., proportional rules and the Shapley value) do not always generate core allocations, we present a core-guaranteeing allocation rule, the market share exchange rule. This rule first allocates to each transport operator the profit he or she generates under collaboration, and then subsequently compensates those transport operators that lose part of their market share, which is paid by the ones that receive some extra market share. This exchange of market share is facilitated by a unique price, which can be expressed as the additional return by cooperating per unit of market share. Finally, we show that, under some natural conditions, the market share exchange rule still sustains the collaboration when the transport operators need to pay back part of the joint profit to society.

Exclusive Dealing with Price Agreements When Buyers Compete

Exclusive Dealing with Price Agreements When Buyers Compete

POSC99 Comparator Pricing Confidentiality and Transparency in HTA Decision Making: A Comparative Analysis of the Nordic Markets

Confidential price agreements are becoming increasingly common for pharmaceuticals. As a result, when new treatments enter the market, the clinically relevant comparators may thus be drugs with confidential prices. This creates challenges when conducting health economic analyses. Reimbursement agencies have introduced procedures to handle these situations while maintaining the confidentiality of the comparators. The aim of this study was to explore and contrast the procedures used to handle situations with comparator pricing confidentiality in the Nordic markets excluding Iceland, especially with respect to transparency. Reimbursement agency guidelines were reviewed, and surveys were sent to the relevant agencies in the Denmark, Finland, Norway and Sweden. The agencies were asked to describe the procedures used in case of comparator pricing confidentiality. A targeted search of assessment reports provided recent examples to illustrate the procedure. Responses and examples were reviewed qualitatively. In Denmark and Norway, the confidential price is in some cases applied in the health economic analysis by the reimbursement agency, and the outcome is masked to the applicant. In Sweden, a proxy comparator is often requested, and the cost effectiveness of the new drug relative to the clinically relevant comparator is assessed indirectly using the proxy comparator as an anchor. In Finland, the applicant is requested to provide multiple scenarios with hypothetical discounts for the comparator. In the increasingly common situation with comparator pricing confidentiality, Nordic reimbursement agencies have adopted different approaches to handle the challenges in the health economic analyses. The most transparent approach is the one used in Sweden, with the request of a comparator that differs from the clinically relevant comparator. However, this is done at the expense of clinical relevance. The Danish and Norwegian processes are the least transparent, which may obstruct the predictability of the reimbursement decisions.

Tax Compliance as an Element of the Corporate Compliance Management System

The aim of the paper was to identify areas of the compliance management system and assess the advisability of including tax compliance within the compliance management system. The methodology involved an analysis of relevant literature, legal acts and compliance standards. The empirical part presents the results obtained, having analysed areas of compliance management systems in a sample of ten entities listed on the WSE and included in the WIG20 index. The studied entities were found to present a variety of information on compliance management systems without taking into account the area of tax compliance. According to the author, the implementation of a coherent overall compliance management system would bring many benefits regarding the fulfillment of tax obligations – e.g. in the field of Mandatory Disclosure Rules (MDR) or transfer pricing – and also facilitate the conclusion of the so-called cooperation agreements in the area of taxes and the Advanced Pricing Agreements (APA).

Uprzednie porozumienia cenowe w Polsce i innych państwach członkowskich Unii Europejskiej

Purpose – Indicating the Advance Pricing Agreement (APA) as a tool to help taxpayers in reducing tax risk and assessing the functioning of APAs in Poland compared to other European Union Member States through the prism of the time of negotiations. Research method – The analysis of empirical data (from the period 2015–2019), the analysis of legal acts in economic terms, studies of the literature on the subject. Results – Advance Pricing Agreements, as a tax risk minimization tool, have been in force in Poland for a relatively short period of time. The analysis covered data from 5 years. This enabled the formulation of a positive assessment of the functioning of APAs in Poland in comparison to other Member States of the European Union. On the basis of the analysis, the suggested change in operation should be shortening the average time of negotiating APAs, e.g. by considering the introducion of a simplified procedure for requesting Advance Pricing Agreements. Originality /value / implications /recommendations – Research on advance pricing agreements is not developed, neither in Poland nor in other Member States of the European Union, therefore the results presented in this article can be considered innovative and implying the in-depth analyses.

Prices vs. quantities for self-enforcing agreements

We study the optimal self-enforcing agreement based on quantity mandates and price instruments in a repeated game between countries, whose domestic firms invest in green technology before consumers emit. We find that technology must be regulated in addition to emissions, even in the absence of technological spillovers. Under a quantity agreement, emission is capped and countries must either overinvest in technology—to weaken the temptation to emit—or they must be punished unless they invest less—to maintain their willingness to retaliate on others. Under a price agreement, emission is taxed and investments subsidized. The price agreement dominates the quantity agreement because when firms are free to modify investment levels if another government defects, the punishment for defection is stronger.

A multi-perspective approach to support collaborative cost management in supplier-buyer dyads

Joint cost management is a decisive factor for sustainable collaboration in supplier-buyer dyads. For both parties the establishment of an accurate cost estimation (CE) framework supports managing suppliers' costs as well as manufacturer's quotation costing. Grounded on resource dependence theory and following a design science research approach, this study introduces a multi-perspective CE system inspired by statistical learning, deep learning, decision making, and multi-agent theory. We evaluate our system by a single case and computer simulation study, using empirical data coming from observations and archives at a large Bavarian original equipment manufacturer (OEM). The results indicate that our CE approach allows to select the most significant cost-drivers and predict total costs of parts and assemblies with high accuracy. This supports the supplier in efficiently managing its costs. In making the CE blackbox model transparent using a combination of model agnostic post-hoc explainable artificial intelligence approaches we foster user acceptance for both suppliers and OEMs. All CE artifacts are ensembled in a multi-agent system to automatically manage costs with suppliers and furthermore, as a model extension, can lead to a collaborative price agreement. Our system supports supply chain managers on both sides in entering into a sustainable long partnership.

President Biden’s Antitrust Counterrevolution: Implications for Business

The proposed changes to the way the United States handle antitrust policy enshrined in the July 2021 Executive Order (EO) issued by President Biden implies significant financial and strategic implications for corporates and their executives not seen since the 1980s. Changes to merger control policy, actions against price agreements as well measures to raise wage growth are all part of the EO and will likely be a legacy of the Biden Presidency for years to come. Among the more than seventy policy changes initiated by the EO, this article evaluates the probability of policy implementation of these policy initiatives and provides a series of options as to how companies could respond. Non-market strategy, public policy, Antitrust, corporate political activity, strategic posture

Timing the Price Agreement in High‐Tech Component Procurement

We consider a high‐technology supply chain wherein a manufacturer is sourcing a new component from a monopolistic supplier who has limited production capacity. We focus on a setting wherein the manufacturer has decided to adopt the component but has not introduced the end product to the market and the manufacturer's task is to negotiate with the supplier for the procurement price before a deadline. The only uncertainty is the number of manufacturers adopting this component, which determines the supplier's outside option. With this uncertainty, delaying the agreement could be preferable because the manufacturer may receive a price cut if the supplier's outside option turns out to be weak. However, delay could also be costly as the supplier may refuse to sell or ask for a high price if many adopters show up. Thus, the timing of agreement for the manufacturer is a trade‐off between the benefit of collecting more information and the risk of losing the limited supply (or paying a high price). Given that the firms are rational, information is symmetric, and the manufacturer's outside option is to use older technologies, we derive the manufacturer's optimal timing strategy—how to set the deadline and whether to delay the agreement. Interestingly, we find that the manufacturer can benefit more from waiting when there is a greater chance that other higher‐value buyers exist. Furthermore, in certain circumstances, we find that the manufacturer should commit to a tighter deadline, even though it is optimal to delay the agreement.

Research on Financial Hedging Decision Based on Exchange Rate Risk in Transnational Supply Chain

This paper considers a three-echelon manufacturer-retailer-supplier supply chain, the purpose of which is to investigate the influence of the bilateral exchange rate risks of import and export and the leading company’s financial hedging on the decision-makers of the supply chain. Firstly, it constructs the profit function and the financial hedging decision-making model of each member in the decentralized supply chain. Secondly, it introduces the incentive mechanism of exchange rate risk hedging in the centralized supply chain. Thirdly, from the perspective of wholesale price agreements and revenue-sharing contracts, it discusses the impact of financial hedging behavior and bilateral exchange rate risks on the decision-making process of each member through mathematical modeling. Finally, it explores the relationships of decision variables through simulation analysis. The results illustrate that (i) for decentralized and centralized decision-making, the manufacturer’s expected profit and profit variance decrease with the increase of the fluctuations of import and export exchange rates under the hedging strategy for exchange rate risks; (ii) compared with the decentralized supply chain, the manufacturer’s expected profit in the centralized supply chain decreases slightly under the revenue-sharing contract; (iii) in the centralized supply chain, if the manufacturer’s risk hedging ratio is high, its profit variance is smaller than that of the decentralized supply chain and the expected profits of the retailer and the supplier will increase significantly; and (iv) for the members of the transnational supply chain, centralized decision-making is better than decentralized decision-making.

Public investments in the development of GeneXpert molecular diagnostic technology.

The GeneXpert diagnostic platform from the US based company Cepheid is an automated molecular diagnostic device that performs sample preparation and pathogen detection within a single cartridge-based assay. GeneXpert devices can enable diagnosis at the district level without the need for fully equipped clinical laboratories, are simple to use, and offer rapid results. Due to these characteristics, the platform is now widely used in low- and middle-income countries for diagnosis of diseases such as TB and HIV. Assays for SARS-CoV-2 are also being rolled out. We aimed to quantify public sector investments in the development of the GeneXpert platform and Cepheid's suite of cartridge-based assays. Public funding data were collected from the proprietor company's financial filings, grant databases, review of historical literature concerning key laboratories and researchers, and contacting key public sector entities involved in the technology's development. The value of research and development (R&D) tax credits was estimated based on financial filings. Total public investments in the development of the GeneXpert technology were estimated to be $252 million, including >$11 million in funding for work in public laboratories leading to the first commercial product, $56 million in grants from the National Institutes of Health, $73 million from other U.S. government departments, $67 million in R&D tax credits, $38 million in funding from non-profit and philanthropic organizations, and $9.6 million in small business 'springboard' grants. The public sector has invested over $250 million in the development of both the underlying technologies and the GeneXpert diagnostic platform and assays, and has made additional investments in rolling out the technology in countries with high burdens of TB. The key role played by the public sector in R&D and roll-out stands in contrast to the lack of public sector ability to secure affordable pricing and maintenance agreements.

Ethnomathematics study of Minangkabau tribe: formulation of mathematical representation in the Marosok traditional trading

ABSTRACT This research aims to explore the use of ethnomathematics in revealing mathematical representations and in the formulation of a calculation system used in the Marosok trading tradition by the Minangkabau tribe in West Sumatra. Ethnomathematics studies ideas in various cultural activities practiced by ethnic, social, or professional groups. The tradition involves nonverbal communication, such as shaking hands with ‘Marosok’ or touching covered fingers to obtain price agreements in trading livestock. Therefore, this study was conducted using qualitative approaches and the ethnographic method via field notes, unstructured interviews, and documentation studies. The findings showed that mathematical representations of finger symbols and gestures in the Marosok Tradition contain basic numbers. These include half, one, two, two and a half, three, four, five, etc. with functions, such as addition and subtraction, which are used to obtain other numbers needed in livestock trading transactions using specific formulas.

A Multi-Perspective Approach to Support Collaborative Cost Management in Supplier-Buyer Dyads

Joint cost management is a decisive factor for sustainable collaboration in supplier-buyer dyads. For both parties the establishment of an accurate cost estimation (CE) framework supports managing suppliers’ costs as well as manufacturer’s quotation costing. Grounded on resource dependence theory and following a design science research approach, this study aims to develop a multi-perspective CE system inspired by statistical learning , deep learning- decision-making and multi-agent theory. We evaluate our system in a single case and computer simulation study using empirical data coming from observations and archives at a large Bavarian original equipment manufacturer (OEM). The results indicate that our CE approach can select the most significant cost-drivers and predict total costs of parts and assemblies with high accuracy to support the supplier in efficiently managing its costs. In making the CE blackbox model transparent using a combination of model agnostic post-hoc explainable artificial intelligence approaches we create user acceptance for both suppliers and OEMs. All CE-artifacts are ensembled in a multi-agent system being able to automatically manage costs with suppliers and furthermore, as a model extension, can lead to a collaborative price agreement. Our system supports supply chain managers on both sides in entering into a sustainable long partnership.