Acc1101 Assignment 1

Reflective Journal On Wednesday the 13th of March 2012 in room H102 at 12-1pm Catherine Chinnock from USQ Careers came to talk to the first semester ACC1101 student about career development (ACC1101 2012). I was never one to listen to career expositions or pay attention to any type of career development presentation, because most of the time they would just repeat the same thing over and over again. So when it came to listening to the career development presentation in my first semester (second semester for USQ) I wasn’t too enthused at what Catherine had to offer.Though after listening to the presentation I was actually surprised at what I had learnt and was able to understand why career development learning is beneficial, especially at Uni. I learnt about the skills and attributes involved, and what employers look for as well as how these skills enhance my graduate employability and ways to obtain these skills. Catherine had talked about the 8 skills of employability some of I had already heard of, such as ‘teamwork communication, problem solving, planning and organizing, and self-management’ (Chinnock 2012).However certain ones I hadn’t heard of, such as ‘long-life learning, initiate and enterprise and technology’, which came as a bit of a shock. I guess growing up in a generation where computer skills are almost a natural action I hadn’t put much thought about this skill I had obtained and how it could actually help me throughout my career. The Career development presentation also gave some key attributes to help me as a student prepare for graduating, and those were Aptitude, Attitude and Academic performance (Chinnock 2012).I found that in order to gain these skills; study, employment, volunteer/community work, work experience and extra-curricular activities could help (Chinnock 2012). To which I did some further research and found that USQ offered the Phoenix Award, which is an award given to those who had d one extra-curricular, work experience and community work by accumulating points (The phoenix award 2012). I also gained information on how to get employment and work experience and where to find it, which was online at the CareerHub (Chinnock 2012).USQ also had a career mentoring program which in which I am assigned a mentor for six months to help with any questions, give guidance and provide goal setting for life outside of university in my given field (Chinnock 2012). She had also explained what workshops were intended for in regards to setting up university and life skills (Chinnock 2012). I had also learnt that USQ held events throughout the year such as, speed networking, a careers fair and Industry Experience Program (Chinnock 2012).One main event that had interested me was an Industry Experience Program which is ‘designed to assist student to develop and enhance their skills and knowledge’ (Chinnock 2012) thus allowing me to broaden my understanding of what to ex pect work wise, and give me career opportunities (Chinnock 2012). From what Catherine had taught me I was able to learn the importance of balance between university and personal life. I learnt about what USQ careers has to offer to help me really get a head start in my career as an accountant, the opportunities that can arise and the importance of community both at and after university.I was able to see how different skills, help improve job employability and that it’s not just about the academic results but also the extra mile that I as an individual can do in order to enhance my career. This also helped me identify my own strength and weaknesses in each of the skills to improve, and how I am able to do so to ensure that when I graduate I am able to graduate with all the skills needed to help maximize my employability.Because of this presentation it means that the phoenix award I had enrolled myself in at the start of semester will help me improve my career development skill s as well as still enjoy participating in activities. Because of this presentation it now means I am able to improve my skills and still collect point for my phoenix award, to become a more effective employee and person. Word count: 698 References ACC1101, Study Desk S2 2012, University of Southern Queensland, Toowoomba, viewed 24 August 2012, Chinnock, C 2012, Career Development Presentation, PowerPoint slides, ACC1101, University of Southern Queensland, Toowoomba, viewed August 2012, < http://usqstudydesk. usq. edu. au/m2/pluginfile. php/57316/mod_folder/content/11/Career%20development%20presentation%20Toowoomba. mp4? forcedownload=1> The Phoenix award, 2012, USQ Student Guild, viewed 20 August 2012,

Descartes ; Hume’s Theory on Knowledge

Knowledge is the things that one has taken into itself and made the decision to believe that it is true. This leads to the question, what makes certain obtained pieces of knowledge true? Descartes would doubt everything until he came to an absolute and undeniable truth. If he had any reason to doubt something, it could not be true knowledge. Descartes then discovered one thing that he could not doubt and that is â€Å"I think, therefore I am. † He says that if he can think, then he knows that he exists. I agree and disagree with Rene Descartes theory of how we have knowledge.Just because you have doubt about something does not necessarily mean there is no knowledge of it. What one may doubt, another person may have knowledge of. So is that person’s knowledge false? I say no. There are many situations like that. One may doubt the existence of God, but I do not doubt it. Since we all have our own beliefs, it does not mean one is wrong. So I do not agree with him saying th ere is no knowledge of things that he has the slightest doubt about. I do agree with his famous line â€Å"I think, therefore I am. † If one has the brain activity to think, then yes they do exist and that is certain.Since I am thinking, then I do have knowledge that I certainly exist. On the other hand, if one is in a coma then I still do believe that they exist. If you are living, breathing and your heart is beating then you without doubt exist even though you are not really thinking. One in a coma does have the ability to think once out of the coma so therefore they still exist. Hume was an empiricist and he believed that all knowledge comes through experience. If you want to know anything about what the world is like, you have to go out and explore; you cannot simply sit, think really hard and hope to come up with knowledge.He believed, along with the fact that knowledge is learned through experience, that a person's experiences are nothing more than the subjects of his o r her own perception. The knowledge of anything comes from the way it is observed through the five senses. Hume began to differentiate between feelings and thoughts. Feelings are only impressions made upon the body, and thoughts arrive from impressions; meaning you cannot have feelings on things you have not experienced. I do agree that one can gain knowledge through experiences, but also through being taught what we learn in school.In order for us to be taught things in school one had to experience the scientific study, math equation or whatever the material consisted of. People did not just come up with these facts on his/her own. They spent a lot of time researching and experiencing them to gain knowledge about whatever they learned. We do gain knowledge from things we experience on our own as well. The saying â€Å"People learn from their mistakes† is the perfect example. A child touches a hot stove and burns their hand, in doing so; they learn not to touch it because the y will remember what happened. In this case, they do learn from an experience.

The Hamlet Research Paper Example | Topics and Well Written Essays - 1250 words

The Hamlet - Research Paper Example Imaginative thinking is very important to literature. Of course, the film medium is a form of literature, so, imagination also comes in handy. When William Shakespeare wrote â€Å"Hamlet†, it is very certain that he put a whole lot of imaginative thought into it (Shakespeare & Constance). In both versions of Hamlet’s adaptation—Franco Zeffirellis 1990 film starring Mel Gibson and Michael Almereydas 2000 version, the directors, as well as the actors, have been very creative as far as interpreting the play is concerned. Michael Almereyda’s version is the ‘marriage’ of the past and the contemporary. The question that this version probably raises in the mind of many viewers is whether this ‘marriage’ was worth it after all; whether this union has yielded any positive fruit. Like Shakespeare does in most of his plays, Michael Almereyda makes an attempt to make use of, not only a story that viewers are familiar, but he adopts a setting – in terms of place and time – that they are familiar with. He makes use of the present day New York. Unlike what obtains in Shakespeare’s Hamlet, Michael Almereyda prefers to make Denmark a high profile media corporation, rather than interpreting it to be a country. If he (the director) had not intended to change anything in the play, he would certainly have left Denmark as a country that it is in Shakespeare’s version. Perhaps the only feature of this version by Almereyda that has not changed particularly is the language. The original Shakespearian language that was used by William Shakespeare himself is maintained. The choice of Shakespearian English for a screenplay set in the twenty first century seems to be an anomaly. As with some other features of the screenplay, the author seems to be pleading to the viewers that they suspend every sense of verisimilitude they possess. This is because it is totally illogical for anyone to choose

The impact of e-business on an organisation Dissertation

The impact of e-business on an organisation - Dissertation Example Organizations all over the world have taken the help of various methods to facilitate the operations and expansion of their business. With the development of Information and Communication Technology, firms have chosen to conduct a large part of their business activities through e-commerce. This has generated a new area of interest among financial researchers. Analysts have been curious to know the impact of the introduction of e-commerce on an organization. They have also been interested in comparing the firms’ business functioning in the earlier days with that in the new technological era. The introduction of e-commerce in corporations has brought about significant changes in their operations. The new technologies have enabled firms to undertake a larger volume of business with the help of the same resources.Service organizations are now able to reach out to a wider range of customers. The new ICT methods have facilitated a more efficient functioning of the overall activities of firms. For this reason, it is important to evaluate the impact of e-commerce on an organization. Therefore, this paper has chosen to undertake a research on this subject. The Indian banking sector has been currently been witnessing an ICT revolution. Most of the banks have adopted new technological methods to improve the efficiency of their existing operations and also to expand their business among a larger spectrum of the population. Recently the HDFC Bank has implemented a multichannel integration program across its business operations.... or choosing the project topic area Organizations all over the world have taken the help of various methods to facilitate the operations and expansion of their business. With the development of Information and Communication Technology, firms have chosen to conduct a large part of their business activities through e-commerce. This has generated a new area of interest among financial researchers. Analysts have been curious to know the impact of the introduction of e-commerce on an organization. They have also been interested in comparing the firms’ business functioning in the earlier days with that in the new technological era. These issues have urged analysts to undertake relevant research in this domain. The introduction of e-commerce in corporations has brought about significant changes in their operations. The new technologies have enabled firms to undertake a larger volume of business with the help of the same resources. Service organizations are now able to reach out to a w ider range of customers. The new ICT methods have facilitated a more efficient functioning of the overall activities of firms. For this reason, it is important to evaluate the impact of e-commerce on an organization. Therefore, this paper has chosen to undertake a research on this subject. Reasons for choosing the particular organization-HDFC INDIA The Indian banking sector has been currently been witnessing an ICT revolution. Most of the banks have adopted new technological methods to improve the efficiency of their existing operations and also to expand their business among a larger spectrum of the population. Recently the HDFC Bank has implemented a multichannel integration program across its business operations. Under this project, the bank has integrated its branches, the ATMs, the POS, the

Week 12 Replies Essay Example | Topics and Well Written Essays - 250 words

Week 12 Replies - Essay Example nice post! i can only imagine how difficult it was to implement that kind of change regarding cell phone use. because people seem to be connected at the hip with their cellphones it is really difficult to find a way to keep everyone in tow. the solution your company came up with is great. however, what is going to be the effect on company expenses in the long run? i mean if im the employee and i knew i was going to get a gift, then id always try to fill up my card fast. hi nice post! you are right. unless people do not see the reason why a change is needed, they will not support the move for change. it is important to show them that the need is necessary. this is the only time people can decide whether they will support the change or not. Thats true Antonia. Meeting all members/workers and listening to their concerns shows them that management respects them. This will foster loyalty. However, I think it also depends on the size of the organization. it can be hard to do this for a very large organization. nice post! i think it will always be hard to implement changes especially if the change affects ones lifestyle. this is something personal. like your example, ive seen many places prohibit smoking in their grounds/facility. what the smokers did was move to a parking lot near those buildings and smoke there instead. i think if people want to get around a change, they will find a way. Hi nice post. i agree with your steps you will take as a leader to meet resistance to change. you are right. forcing change on people without open communication will have bad results. being open to all stakeholders will indeed facilitate a smoother

Prostitution Essay Example | Topics and Well Written Essays - 750 words - 2

Prostitution - Essay Example The first main point for evaluation is the point of human rights. Perkins (1991) wrote about human rights in support of prostitution: â€Å"The decriminalisation of the prostitution legislation, therefore, would immediately free prostitutes from the shackles of unjust laws, but it would also be a positive step in removing a punitive threat to all women, especially those who aspire to freedom of sexual choice.† This is a main point because I strongly disagree with prostitution, and yet, Perkins presented an interesting concept that prostitution is a freedom of sexual choice. It is a good example of freedom of autonomy over one’s body that is hard to oppose. I definitely do not see prostitution as a sort of freedom, but prostitutes can claim their bodies as their own, therefore underscoring their human right to their job of choice. Post (2013) opposed Perkins when she said: â€Å"The practice of prostitution brands all women as something that can be bought and sold; and therefore, just like slaves, less than full humans who deserve the complete panoply of human rights.† I agree with her that prostitution is dehumanising, so it means it is not aligned with human rights. To be a prostitute is to be a slave to gender-based sexual desires that is not what humanity should be. I truly think that to have human rights and freedoms, prostitutes should have access to other alternative jobs. Leidholdt (1993) also disagreed with Perkins that prostitution is a human right or freedom: â€Å"[Prostitution] is about the absence of meaningful choices; about having alternative routes to survival cut off or being in a situation where you don’t have options to begin with† (p.136). I chose this as a main point because I agree that prostitution is against human rights because many prostitutes are known to say that they would leave prostitution

The Black Power Mixtape Essay Example | Topics and Well Written Essays - 750 words

The Black Power Mixtape - Essay Example   Ã¢â‚¬Å"The Black Power Mixtape† was directed by Goran Hugo Olsson a Swedish and helps depict a story of black power movement in a neutral eye. A little odd is the fact that the Swedish Journalists were following and recording the efforts and of course frustrations by blacks surviving in America’s back streets.   All the documentation was for long stored in a basement for close to forty years until the making of this Mixtape. Indeed a Mixtape, the film presents the facts as they were, raw in a matter of speaking put together. It is refreshing due to its arbitrariness, not following a style but with the theme of showing the Black power in the 1960’s and early 1970’s. The stylistic approaches used by the director of the film displays the struggles of blacks in 1960’s in a random and virgin, non-fictional memorabilia depicting the atmosphere as it was and benefited the presentation of a cinema of truth. The film is a compilation of interviews from people that championed the Black power movement who after witnessing or experiencing the struggles of their own kind, had to stand up for themselves. Interviews include inter alia; Angela Davis, Stokely Carmichael, Bobby Seale, Eldridge Cleaver, Huey Newton and Dr. Martin Luther King. Their words and voice resonating and evoking such an era-specific picture of what occurred. Fictional movies such as ‘Mississippi Burning’ and Tate Taylor’s ‘The Help’ have often brought this era out in a palatable way.... Angela Davis’s voice interview when in jail reverberates over and over again in my head when she says, â€Å"You ask me if I approve of violence, I just find that incredible.† She struggles to show the misconceptions towards her people, the black people. It shows the irony of the situation where a people violent and racist towards the black people, depict violence as coming from the black people. She evokes so much by her words and silence too just after the short interview that resonates almost half a century later. Stokely Carmichael agrees with the idea of Dr Martin Luther King policy of non-violence as a method for blacks to use to change the hearts of the racial discriminators. In his interview, the impossibility of Dr King’s method is brought out in a humorous and almost seductive way amid the chaotic and dangerous atmosphere. Impossibility in this method is because to be moved to a change of heart required conscience which discriminators seem not to have a s seen by Carmichael. We are reminded of the many failed revolutions and counterrevolutions in a time that shaped the culture that we enjoy today. During an interview with Stokely Carmichael’s mother Mabel, the film takes an awakening turn. In an inspiring and downright courageous act, Stokely takes the microphone from the Swedish journalist and asks his mother why his father, a carpenter was laid off so often. Even without watching more of the film, one can tell the frustration, this fresh graduate feels knowing too well the truth but watching his mother struggle to go around the facts. The lack of freedom of expression or the double standard of it, the fear experienced by the ‘coloured’ people as the mother calls them. The result of the film is sobering making one

Research proposal Assignment Example | Topics and Well Written Essays - 3000 words

Research proposal - Assignment Example Talking about the social networking sites, it can be said that the growth of the social networking sites has been largely augmented by the tremendous favoring of the growth prospects of the United States. Like as witnessed in the case of dotcom bubble of the late 1990’s, the mere presence of the social networking sites in the virtual web space does not help in any way in the process of generating revenue. Every social networking site needs to operate on the basis of a business model, which will help in generating revenue for the online business. It is of significant and utmost importance to mention that the business models that are applicable in the case of social networking sites should not only focus on the process of generating monetary value, but also on the lines value creation, identification of the core competencies of the online business as well as proper value communication to the right target audience. Considerable amount of interest also needs to be given on the lin es of creating competitive edge for the online business. It is of considerable importance to mention that an online business is built on four key model components. The first one is the value creation, which distinguishingly addresses the value that will be provided to the customers. The second factor is the issue of target market, which necessarily takes into account the factor of the desired target audience. The third aspect talks about the factor of core competencies which will help in leveraging maximum advantage in regards to the process of generating the business model’s potential strengths and opportunities in the market. The final aspect talks about the revenue prospects that need to be idealized for the purpose of developing the potential business aspects of the online business model (Albarran, 2013, p. 62- 63). It is important to mention that in most cases, though the online media provides free access and use of its online web 2.0 concepts, yet it can be said that th e revenue is generated through the process of cost per impression (CPI), cost per contact (CPC), advertising, lead generation and even licensing deals. However, it is of considerable importance to mention that the technological devices are riding the wave of innovation and are increasingly transforming themselves in regards to shape and size. The bulky laptop and PC has paved the way for tablets and smart phones, thereby playing a major role in regards to device space and capacity. Business models of the online nature in order to keep their connect with the tech savvy masses increasingly are concentrating on the process of adopting their visual offerings of their online products and services. Due to the changing requirements of today’s technological gadget altering masses, the business models are being designed in the platforms of open source (Hinchcliffe and Kim, 2012, p. 8). It needs to be highlighted that the literature review forms a very essential and vital part of the e ntire research proposal. It can be said that while considering the process of moving ahead with the literature review area, a considerable amount of focus needs to be given on the research work that has been done by the past researchers on the same lines. While discussing about literature review, it can be said that the literature review might have been presented from various perspectives of

Stats18 Essay Example | Topics and Well Written Essays - 1250 words

Stats18 - Essay Example Answer True False   Question 5    Measures of effect size, such as r2 or Cohen's d, are not greatly influenced by sample size. Answer True False Question 6    Measures of effect size, such as r2 or Cohen's d, are not greatly influenced by sample variance. Answer True False   Question 7    Which of the following is a major difference between a hypothesis test with the t statistic formula and the test with a z-score? Answer a. You must calculate the sample variance (or standard deviation) for the t statistic but not for the z-score. b. You must know the population variance (or standard deviation) for the z-score but not for the t statistic. c. You use the unit normal table to find critical values for the z-score test but not for the t test. d. All of the other options are major differences.   Question 8    If two samples are selected from the same population, under what circumstances will the two samples have exactly the same t statistic? Answer a. If the sample size ( n) is the same for both samples. b. If the samples are the same size and have the same mean. c. If the samples are the same size and have the same mean and have the same sample variance d. None of the other options are correct.   Question 9    A sample of n = 4 scores has SS = 48. What is the variance for this sample? Answer a. 12 b. 16 c. 4 d. 2   Question 10    A sample of n = 9 scores has SS = 72. What is the estimated standard error for the sample mean? Answer a. 9 b. 3 c. 1 d. cannot answer without knowing the sample mean   Question 11    Which set of sample characteristics is most likely to produce a significant t statistic? Answer a. a large sample size and a small sample variance b. a large sample size and a large sample variance c. a small sample size and a small sample variance d. a small sample size and a large sample variance   Question 12    A sample of n = 4 scores has SS = 48. What is the estimated standard error for this sample? Answer a. 12 b. 16 c. 4 d. 2   Question 13    When n is small (less than 30), the t distribution ____. Answer a. is almost identical in shape to the normal z distribution b. is flatter and more spread out than the normal z distribution c. is taller and narrower than the normal z distribution d. cannot be specified, making hypothesis tests impossible   Question 14    With ? = .01, the two-tailed critical region for a sample of n = 20 subjects would have boundaries of ____. Answer a. t =  ±2.845 b. t =  ±2.528 c. t =  ±2.539 d. t =  ±2.861   Question 15    As sample size increases ____. Answer a. the value of df also increases b. the t distribution becomes more like a normal distribution c. the critical values of t become smaller d. All of the other options are true as sample size increases.   Question 16    Two samples from the same population both have n = 10 scores with M = 45. If the t statistic is computed for each sample, then ____. Answer a. the two t statistics will be identic al b. the sample with the larger variance will produce the larger t statistic c. the sample with the smaller variance will produce the larger t statistic d. There is no way to predict the relationship between the two t statistics.   Question 17    In a hypothesis test using a t statistic, what is the influence of using a large sample? Answer a. A larger sample tends to lower the likelihood of rejecting the null hypothesis. b. A larger sample

Christopher Columbus Essay Example for Free

Christopher Columbus Essay Christopher Columbus wrote a letter to the king and queen of Spain around 1494. He gave the king a queen a description of what was going on and what he had found. He wrote this letter stating that there was riches and many land for colonies. He was telling them what they can do with this land that he had found. Take it, build a government, and he wanted more ships for his up coming voyages. The question is this document relevant to his voyages, yes, indeed they do. He wrote to the king and queen what they can do in this land that he had found. He was already planing there government, and how they were going to rule the land. He explained how they should have churches and start converting the indians. When the gold rush comes they should have the people who are getting the gold must have a license to retrieve some gold. He talks about governors and how there should be one on every island that he had discovered and how they were going to be in charge. He wanted to start these settlements and let them grow and then that would make Spain the greatest empire in the world because they would have the biggest land mass. He did do the mission for Spain but more for himself and it was his job to do this kind of adventuring. He wanted to make history and this document shows what he had discovered and his proposal to the king and queen of what he thought the colonies should be run and so on. This absolutely has to be apart of a the voyage with Christopher Columbus because it tells a little bit of what he saw, what he knows and what his plans were. He tells about all these riches and gold and how they can make the colonies work and survive and build communities. It gives an idea of what he thought and what he had believed should have happened, which for the most part did happen. He was a very bright man I assume by this letter to the king and queen and he explained his plans very well and the king and queen should have been pleased of Christopher for making all of that happen. With out this it would be like missing a piece of a puzzle. Questions with out full knowledge of what was going on. Christopher started his journey around 1492, I think, and it took him a couple years to discover this land mass and he was eventually a hero to Spain. Without Christopher discovery of the Americas people would have come and settled in the Americas later than they did and he wouldn’t be famous.

A Case Diagram Of A Club System Information Technology Essay

A Case Diagram Of A Club System Information Technology Essay Use cases: Use case describes a sequence of actions to provide some measurable value to an actor, was drawn into a horizontal oval. Context Diagram of the system: Data Flow Diagram: Create use case diagram I would like to identify as many actors as possible. You should ask how the actors interact with the system to determine the initial setting of a use case. Then, in the chart, you connect the actors and use cases associated with them. If an actor to provide the information, start with the cases, or receive any information, so use case, then the relationship between them should be. I usually wear including the association arrow lines, because my experience is that people put their signs that the flow of information, rather than the initial call. As I began to notice the similarity between the use cases, or actor, I began to simulate the proper relationship between them . The preceding paragraph, I described the general use case modeling style, a Jim actors first Approach. Some people like to first determine an actor, use case, they participation, and then the evolution of the model from there. Both methods work. The most important point is that different people take different approaches, so you need to be flexible when the following morning practice model and others. Actor. Actor is a person, organization or external systems play a role in one or more interaction with your system. Actors come to insist on digital. Community. Associations between the roles and use cases use case diagram is shown in solid lines. As long as there is an association, is an actor involved in a use case interaction descriptions. Society is modeled as a line of cases and participants to connect with each other, the arrow on the line with an optional one end. The direction of the arrow is usually used to indicate the relationship between the initial call, or explain the main actors in the use case. The arrow is usually confused with the data stream, the result I avoid its use. System boundary boxes. You could draw a rectangle around the use cases, called the system boundary box, to show the scope of your system. Function within the box represents what is to what extent and in the outside box is not. System boundary box is rarely used, although sometimes I use this to determine which use cases will be delivered to all major version of the system. Figure 2 shows how to do so. Package (optional). Package is the construction of UML, allowing you to organize model elements group. Package described as folders, can be used in any UML diagram, including use case diagrams and class diagrams. I use the package, I only plan to become clumsy, which often means that they can not print a single page, organized into small, large-scale map. Figure 3 Figure 1 depicts how restructuring and packaging. In this, depicted in 1, the Academy s may enroll in courses to help register. Use case specifications: Use case contains the text to further standardize the description of the use case. The usual text specification also describes the process of all possible error specified, and how to remedy the system will take action. This specification can be customized or extended to address specific issues or organization implementation. Conclusions and commentary: This section should provide any final comments on the system design, or use the system. It should include any known problems, restrictions, or extenuating factors contribute to the decision, or may affect the future of the system. Use Case: orders Main Role: Customer Abstract: This use case allows customers to create a purchase order to use / update existing customer information or data, by creating a new customer. If the customer has begun to purchase orders directly (without having to visit the online catalog), he or she can select items from a product catalog of use cases. Objective: To allow customers to create and submit orders Focus categories: customer, project configuration, purchase orders, standard items Premise: The customer has valid user ID and password of the customer extranet Activity diagrams: Figure 1 Figure 2 Activity diagram shows flow through the systems activities. Read the chart from top to bottom, and has branches and forks to describe the conditions and parallel activities. A fork is used when multiple activities occur at the same time. The following diagram shows a cross after the activity design. This indicates that these two activities are the design and activity3 occurred at the same time. Activities after the design has a branch. The branch describes what activities will be held on the basis of established conditions. After a certain point the branch is a merger that ultimately acts to be qualified by the branch began. After the merger of all the parallel activities must be integrated to the final by a transition to active state. Task 2 Class diagrams: This type of chart, also known as block diagram, class and object distribution components or modules. This is very convenient to design the system, possibly hundreds of thousands of components. Attributes and operations: Can also use the display options at both ends of the association operation pieces displayed inside the definition and parts diagram, internal block diagrams or the definition of UML class Rational Rhapsody Sys ML solution to improve the binding characteristics of the connector parameters of the chart features, so you can set the properties of components. Context is a dialog box to invoke the right-click Properties, then select bound to the context. In addition, the three labels are added to the binding connector: Source Context: the background of the source-side connector binding Target Context: background, objectives at the end of the connector binding Value: the value of sharing the source and target completion Task 3 Sequence diagrams: Sequence diagram is still rather inadequate development in the UML. The biggest difficulty is the stimulus behind the actions. These are purely textual in implementation; there is no way to contact them back to their associated operations or signals. It hides all the communication partners located outside the communication system is not interested in the moment. They can be included in their interests. Included by clicking on the within the system boundaries. You can also use drag and drop or simply click on an object reference to include the object sequence diagram. As you can see a new sequence diagram is very fast. Method calls the hidden outside the system boundary. If a method call appears to become visible and method parameters of the return value will be displayed, if the method returns. Exceptions can also be seen. Sequence diagram of the layout of a complex mechanism, there is no need for time-consuming hand-arranged communication partners. This is a fishing Sequence diagramsà ¢Ã¢â€š ¬Ã‚ ¦ Windows XP/Server 2003/Vista/Server 2008 contain the firewalls that may prevent certain types of this product communications. If these firewalls are enabled, you might not be able to access computerized system remotely. If there are computers in your network that run these operating systems, you need to configure the firewalls to allow for these communications. To use the Windows XP firewalls, you need to configure them to support communications by opening ports or by specifying trusted programs. You can enable communications by permitting rugbyclub.exe on all computers. If you want to install client software remotely, you must permit servers to send traffic from TCP ports 1024-5000 to TCP ports 139 and 445 on clients. Stateful Inspection permits the return traffic automatically. You must also permit clients to receive traffic from server TCP ports 1024-5000 on TCP port 139. And you must permit clients to send traffic from TCP port 139 to TCP ports 1024-5000 on servers. Legacy communications also require that UDP port 2967 be open on all computers State machines: I cannot seem to get over my brain state machine this week, unfortunately is not ità ¢Ã¢â€š ¬Ã‚ ¦ I find I rarely use them so, but I have a nagging feeling that they can be so incredibly useful. I think this is because they finally allow me to separate concerns. Today, for instance, I run the facilities for building, plant ASP.NET wizard form roughly the following steps. The workflow GUI is to achieve a simple online survey, people can submit. I started not even think of a state machine. I just use case document in my desk, and hackers along with a number of ASP.NET pages. This is a fast growing chaos. I really want to use some of the states model. However, a complaint is to achieve national model tend to take so much code to represent the channel state transitions. This article demonstrates my point, I just have no time invested in so many things not trying to Disc the author, and many look very beautiful, I just want a convenient things. Even draw a state diagram need too much time with respect. I would like to dream of a simple way to express this state machine kind of thing in the code, it has been the following. Please note that Run down: Start -> [Introduction || AlreadyDone] Introduction -> Terms -> Scores Nomination Confirm -> Thanks [Terms, Scores, Nomination] -> Saved for Later Communication diagrams: Each complex or major functional requirements will show a sequence diagram or a communication planà ¢Ã¢â€š ¬Ã‚ ¦ A behavioral model is used to define the functional requirements to implement a system. Implementation of each component in the logic model illustrates how interactions to achieve this requirement. Integrated into the technical design of a behavioral model helps to define the responsibilities (functions) and interface in the component level. In the UML, the sequence or communication diagrams to illustrate patterns of behavior. TASK 4 Regulations and best practice: Although a lot of attention is given to protect the company .Electronic assets from outside threats from intrusion prevention system Firewall, vulnerability management organizations must now put their Note that an equally dangerous situation: the problem of data loss from Inside. In fact, many organizations have a big hole in the control .Create a safe environment, to protect electronic assets. This hole is now common business and personal communication with the Other on the Internet. Whether email, instant messaging, e-mail, web site form, or File transfer, electronic communications out of the company continues to a large extent Uncontrolled and unsupervised on the road, their destination and there is always the potential of confidential information falling into the wrong Hand. Should be sensitive information is exposed, it can wreak havoc .Organizations bottom line through fines, bad publicity, loss of strategic Customers, loss of competitive intelligence and legal action. Given todays strict regulatory and super-competitive environment, data loss Protection is one of the most critical issues facing the CIO who, civil society organizations and CISOs. For the establishment and implementation of the DLP strategy, the task can be Seem daunting. Fortunately, effective technology solutions available. This Report on best practices, organizations can use as they seek to prevent leakage of the solution, implementation and observance and protection the companys brand value and reputation. Solution combines the best varieties: Data loss prevention solutions are still developing, not a single offer most organizations need all the depth capacity. For example, In both data management campaigns and static data carrier, is a Challenges and vulnerability, need a different set of features. Recalling the entire data stream, companies need to address data loss. Problem by creating an end-to-end solutions using the best of similar products. The best answer is to use specialized supplier of solutions, from the data Motion and at rest, data obtained the most comprehensive and effective prevention Across the board. the best sign is the same solution can be extended and strengthened By integrating the best of its effectiveness and other similar tools. Companies should avoid selected DLP solution from their inhibition Integration in the future. With the development of the industry, it will be essential to have Full advantage of the flexibility and future third party support Solutions through connectivity and data sharing. B. Computer system being developed: Payment Card Industry Data Security Standard Decision Support System for PCI, a comprehensive set of regulations to enhance payment account data security, is by American Express, Discover Financial Services Card, JCB, MasterCard International and Visa International, to help promote the widespread adoption of consistent data security measures in a global basis. Data loss problems ranging from confidential information about a customer is exposed thousands of source code files Send to a rival companys products. Whether deliberate or accidental data loss occurs any time an employee, consultant or other sensitive data are released on the customer, financial, intellectual property, or Other confidential information (violation of company policy and regulatory requirements). Consider the following two striking examples: the U.S. online job search engine data Contain personal information, members, employees of DuPonts 400 million U.S. dollars leakage of intellectual property, CEO of the whole food industry competition Bashes blog by a former Ceridian employee accident job number and bank account information, 150 people The advertising on the site. The list goes on example. With all of the channels available to employees electronically disclose today Sensitive data, the extent of the data loss problem is an order of magnitude Greater than the protection from outside threats. Consider the level of effort required to cover all losses carrier An organization may experience: à ¢Ã¢â€š ¬Ã‚ ¢ motion data any data, is through the network to the outside via the Internet à ¢Ã¢â€š ¬Ã‚ ¢ Data break the data resides in file systems, databases and Other storage methods à ¢Ã¢â€š ¬Ã‚ ¢ Data in the end the data in the network endpoint (such as data of the USB devices, external drives, MP3 players, notebook computers, and other highly mobile devices) in order to avoid the sake of delayed receipt of a data loss, businesses must assess The vulnerability of each specific carrier, and take appropriate loss. C. Data protection in the new system Access to data at any time, any place, is an integral part of most business Organization. A powerful, user-friendly solutions for personal and corporate data services area for a rest encryption is a must have for companies in many industries. New system to provide tools to organizations of all sizes to fully control and protection of the key as the FileVault for the adequate protection and management of all access to the users home directory, encrypted disk image processing to enable users to sensitive data without any form additional costs often associated with additional encryption solution. Based on the hardware: Time has proven that changes in security solutions, from software to embedded hardware They mature, and its implementation. The same trend is occurring already available from Seagate FDE drive technology, or self-encryption hard drive. In this way change the encryption / decryption process from a software module A real-time, embedded hardware chip hard disk storage module. The organization is considering hardware-based full disk encryption, some solution providers have expanded enterprise management solution was FDE technology management software in addition to providing key technologies emerging FDE hard drive. The FDE technology transition to the hard drive or continue to use the software to split the environment and Hardware FDE technology. This continuity can provide additional assurance, organizations can continue to use familiar solutions. With the critical nature of the data, the protection of the rest, this is not part of the organizations most important philosophical or political quagmire. The best approach is to focus on the appropriate data protection. If the FDE drive technology is the ideal solution, but the current Vendors do not support Apples product line, however, it would be best to take critical look at other players available in this area. If there is no competition, no improvement in security products, they have. Deprive an organization of FDE hard drives on the basis of technology solutions provider may be weakened, if not eliminate, the necessary level solutions, hardware-based solutions may also be an obstacle to the current best practice of two-factor authentication, may adding complexity to the user. Task 5 2.Indiana University and IU Varsity Sports Council is pleased to announce an exciting new tool that allows season ticket holders to choose their own seats, giving them views of online interactive sites to see the two in international units largest music facilities. In the implementation of the new online seat system is to drive the Varsity Club board of directors in collaboration with national and international athletic ticket office units and the Varsity Club staff. In recent years, each group has collected the views of donors on how to make it easier for season ticket renewal process. The results of their research focused on an online system that allows season ticket holders choose their own seats. IU music: IU Memorial Stadium This has traditionally been done in the ticketing office staff based on individual priorities, and asked to write any special ticket for the seat. Companies Seats3D products allow users to see a virtual rendering and line of any section of Memorial Stadium and City Hall. Music fans can rotate the view that in all directions and zoom in and from that location. See Seats3D product by looking at the international unit of Memorial Stadium, City Hall virtual tour or virtual tour. Season ticket holders will be able to use advanced management system, view seating season seats, and to select the seat. According to their priority points, ticket holders will be assigned a specific date and time recorded in the system to choose their own seat selection you want all from the convenience of their home or office. Specially trained staff will provide assistance to season ticket holders without Internet access who are willing to call or personally visit the Memorial Stadium, choose to select their own seats on the specified date. The new honor system, complete seat selection, while giving priority points system ticket holders to better control their designated seat location, Varsity Club presidents left-wing coalition, said director of the National Committee. Indiana fans can view Real-time availability and choose the best seats according to their personal preferences location. . In order to adapt to the new online seat selection system, closing date for applications for 2010 season tickets has been moved to March this year. Select seats will be online in June occurred 5 . Through this new online seat allocation system resulted in two years of hard work by the IU Varsity Club, its Board of Directors and staff of athletic ticket office, said: Fred Glass, vice president and director of intercollegiate athletics . They have done a great job to listen and to seek donations of new technologies, so that our fans first to choose their own seats. online tools, greatly improved customer service and purchasing experience in ticket holders in sports venues and the United States. More than 200 university students and professional venues and facilities have been used online product range. In addition to streamlining our seat allocation process, this online tool to strengthen our commitment to improve the fan experience, added: deputy director of the à ¦- ¯Ãƒ §Ã¢â‚¬ËœÃƒ §Ã¢â‚¬ °Ã‚ ¹Ãƒ ¥Ã‚ ¤Ã… ¡Ãƒ ¥Ã‚ °Ã¢â‚¬ Ãƒ ¦Ã‚ £Ã‚ ® competitive. With this innovative technology, fans will be able to easily select the seat in a similar manner, they choose airline seat today all from the comfort of your computer. Ticket holders and fans encouraged to view the virtual heat Hu visit the Memorial Stadium and City Hall and testing the new international unit of the system before the online seat selection, their choice of time allocation. Technology provides a unique sales and marketing tool for Member, venue owners / operators, and Internet-based ticketing solutions. Seats3D products are market leaders in complex three-dimensional visualization. seat technology to create realistic visual effects to improve the online booking experience, familiar with the potential customers of the facility, creating excitement, sales and customer satisfaction levels. The current site on the use of facilities, including on-site national, NBA, and American football, Major League Baseball, Major League, non-Hodgkins lymphoma, the National Collegiate Athletic Association, and NASCAR. innovative seat relocation management system . print media available for printing: Print a broader audience access to knowledge, so that future generations of intelligence based on the results earlier. Print, according to Acton in his teaching of history (1895), to the guarantee of the Renaissance will continue this work, it will be what is written all access, so occultation of knowledge and ideas suppressed the Middle Ages will never be repeated, this is not a concept will disappear. [8] Print a help change the social nature of reading range. As a Briggs and Bideboke identify five to read, the developed countries on the introduction of printing: 1.Critical read: Because of the fact that the text finally entered into the general population, appear critical reading, because people choose to form their own views on the text. 2.Dangerous reading: reading is seen as a dangerous pursuit, because it was seen as rebellious and withdrawn. This is particularly the case of women, because it may lead to dangerous emotions like love of reading. Some people worry that if women can read, they can read a love letter. 3.Creative read: get people to read printed text and to explain their creativity, in very different ways, more often than not the authors intent. 4.Extensive read: print allows a wide range of text becomes available, therefore, the previous method of intensive reading text, from beginning to end, began to change. With the existing text, people began to read about a specific topic or section, to allow a wider range of reading a wider range of topics. 5.Private read: This is the rise of individualism. Print before, often mass incidents, including one reading to a group of people. With print, the text also provided literacy up to become a solitary pursuit of reading. Although discussions have been invented printing in the spread of traditional values, its greater contribution to promoting the long-term development is that it changes the relationship between space and discourse Wang is the proliferation of the media to discuss the introduction of the printing press, the oral culture of death, and this new culture more seriously, instead of hearing in the visual medium. So press had a more convenient and popular source of knowledge, because it broke the boundaries of knowledge and between the masses. Narrative discourse or what now exists will be indirect, when the global village. The invention of printing has changed the occupational structure of European cities. Printer into a new group of craftsmen for their literacy is necessary, but more labor-intensive occupation of the scribe falls. Proofreading to correct a new career there, and the rise of booksellers and librarians to follow the number of natural explosion of digital books. Stefano graphic anti-counterfeiting (secret) marks . For example, small yellow spots on white paper, producing a color laser printer. Main article: Secret printer Many modern color laser printer to print mark by an almost invisible point grid, for identification purposes. This is yellow, the size of about 0.1 mm, and the grating is about 1 mm. Allegedly, this is the result of a deal between the U.S. government and the printer manufacturer to help track fraud. The point code data, such as printing date, time and printers serial number in binary coded decimal print every piece of paper, allowing pieces of paper, trace the purchase by the manufacturer to determine location, sometimes the buyer. Digital rights advocacy organizations such as the Electronic Frontier Foundation, concerned about the erosion of privacy and anonymity of those who print. Use device Dedicated room for 20 peoples Whiteboard and markers Notepads and pens Projector LAN cables 24 ports 100 MB network switch Computer for demonstration with following specification: Processor Core2Due 2GHz or above RAM 2GB Hard disk 160GB CD ROM drive card reader Task 6 a. A set of fully normalised tables showing the normalisation process for each table First Normalization Member(MemberID, MemberName, MemberAddress, Telephone number, , MemberID) Member(MemberID, MemberName, Description, Captain, Vice-captain, , ) Match(MatchID, MemberID, OpponentMemberID, Date, Venue, OpponentMemberName, MemberScore, OpponentMemberScore) Training(TrainingID, TrainingDate, TrainingTime, Venue, TrainerID, TrainerName) 2nd Normalization . Match(MatchID, MemberID, OpponentMemberID, Date, Venue, MemberScore, OpponentMemberScore) OpponentMember(OpponentMemberID, OpponentMemberName, , ) . Training(TrainingID, TrainingDate, TrainingTime, Venue, TrainerID, TrainerName) 3rd Normalization Training(TrainingID, TrainingDate, TrainingTime, Venue, TrainerID) Trainer(TrainerID, TrainerName) Data Dictionary entries for all items included in the database design Table: Training Attribute: TrainingID: number(10) , the value is unique and cannot be null TrainingDate: Date TrainingTime: Time Venue: Char(20) TrainerID: number(10) cannot be null TrainerID references to Trainer Description: If the trainerID is null, it means that there is a training without any trainer what is the meaning behind the restrictions? TrainingDate, TrainingTime and Venue with the same value cannot appears twice in the Training Table. TrainerID cannot appears twice in Training with the same TrainingDate and TrainingTime. b. database design Customer: Field Name Description Format Typical Value MID Member ID Number(4) 0001-9999 Name Member Name Varchar(40) Peter Law BDate Member Birthday Date String YYYY-MM-DD Gender Gender of member Char(1) M/F ContactNumber Contact Number Varchar(16) 852-68121630 Address Contact Address Varchar(120) EAddress Email Address Varchar(40) [emailprotected] TType Member Type Varchar(2) T1,T2,J1,J2,J3 JDate Member Join Date Date String YYYY-MM-DD Status Member Status Char(1) Active, Suspend BType Blood Type Varchar(3) O+, A+, AB+, B+ MHistory Medical History Varchar(2000) EID Emergency ID refers to Em Table Number(4) 0001-9999 PHistory Field Name Description Format Typical Value MID It refers to Table ClubMember Number(4) PDate Paymemt Date Date String YYYY-MM-DD PAmount Payment Amount Number(3) 20,25,42 Primary Key = MID + PDate Em Field Name Description Format Typical Value EID Emergency ID Number(4) 0001-9999 EmContact Emergency Contact Name Varchar(40) Mary Law EmNumber Emergency Contact Number Varchar(16) 852-23731248 FLList Field Name Description Format Typical Value MID Match ID Number(3) YYS (2 digit year + Session Number) TID1 First Member ID Number(4) 0001-9999 TID2 Second Member ID Number(4) 0001-9999 TType Member Type Varchar(2) T1,T2,J1,J2,J3 MDate Date of the match Date String YYYY-MM-DD Location Place of match Varchar(120) Result1 Result of First Member Number(2) 00-99 Result2 Result of Second Member Number(2) 00-99 Validation Rule Check length of Member name it must not null. Check Contact number numeric only. Check length of address, it must not null. Check validation of birthday value. After finish input birthday of member, system will generate Member type for this member. Medical History can be null. No default value for blood type, so user must select blood type from combo list. Emergency Contact Name can be selected from combo list, or enter new one. Check length of Contact Name must not null. Check Emergency contact number numeric only. Validation Rule Session is selected from combo list, only current session can be selected. System retrieves existing Member ID from database and allows user to select it from combo list. After selected Member ID, system will retrieve Member type from database and display on screen. System retrieves existing Member ID, remove Member ID from other Member type and also remove Member ID on above combo list. It avoids user to select same Member ID. The Member result and VS Member result must positive integer. Task 7 raining Session Events Secretary organise a open training session for non members from th

Light and Dark in Joseph Conrads Heart of Darkness Essay -- Heart Dar

Light and Dark in Heart of Darkness  Ã‚      Joseph Conrad's Heart of Darkness is a tragic tale of the white man's journey into the African jungle. When we peel away the layers, however, a different journey is revealed - we venture into the soul of man, complete with the darkness of depravity as well as the wonderful. In this essence Conrad uses this theme of light and darkness to contrast the civilized European world with the savage African world in Heart of Darkness. As aforementioned, within Heart of Darkness, Conrad uses light and dark to symbolize good and evil, respectively. "It is whiteness that is truly sinister and evil, for it symbolizes the immoral scramble for loot by the unscrupulous and unfeeling Belgian traders in ivory and human flesh; the whiteness of ivory is also contrasted with the blackness of the natives whose lives must be destroyed for its sake" (Gillon 25). In other words there is a perversion of light and dark and what they represent.   The characteristic of ivory is its colour of white, but rather then being associated with purity and all that it is good, it re... ... of Darkness. Middlesex, England: Penguin Publishers, 1983. Gillon, Adam. (1982). Joseph Conrad. Twayne's English Author Series: Number 333. Kinley E. Roby, ed. Boston: Twayne. "Joseph Conrad." The Encarta 1998 Encyclopedia Online. Microsoft, 1998. Kunitz, Stanley J. "Joseph Conrad." Twentieth Century Authors: Vol. T. New York: H.W. Wilson Company, 1942. 307-9 Stape, J.H.. The Cambridge Companion to Joseph Conrad. Cambridge: Cambridge University Press. Taylor, Derek. Conrad's Heart of Darkness. The Explicator. No.4 Summer 1998: 195-8.

Spending Power of Children Essay -- Marketing

In present day to day life, kids play a vital role in the purchase behaviour of the family. This paper focuses on the effects of retail communication on the purchase decision of children. The various factors which influence child’s behaviour have been studied. The methodology adopted includes thorough observation of a kid from entry to exit in the store followed by a personal interview of the accompanying person. Further, the kid’s interaction with the accompanying person has been studied and his/her evaluation of the request is noted. After analysing the complete behaviour, a framework has been proposed which depicts the complete process and the various factors which influences child’s behaviour in the store. Introduction Nowadays children’s share in the family expenditure occupies a significant place. It is also believed that this share is spent by the elders to buy necessary things for the children but now the scenario is changing. The children have the major say in deciding what things they want and what they don’t. According to one of the researcher, spending power of children or young consumers is expected to be over  £200m in the UK alone (Nicole Weiner, 2004). So now it can be estimated that how much it would have been risen over the last 7 years. Markets are also influenced by this kind of behaviour and mould themselves accordingly. We can see a large variety of child centric things in the markets, which are making huge profits despite being not much of necessity. This study is done to find out the various factors involved that influence a kid’s behaviour at a retail store and the percentage of accompanying persons that yield to the various types of influence attempts made by the kids at the store. Litera... ... ‘crying’, and ‘hitting’ contributes (33.33%), (50%)& (16.67%) respectively. For those who made simple purchasing attempts, ‘simple requesting for the product’ was their first preference with (86.67%) & ‘pointing towards the product’ was the second with 53.33% and the rest like ‘grabbing it from the shelf’ and ‘naming a product’ were at the back with 40%, 33.33% respectively. Accompanying person initiated demands are defined as those in which the accompanying persons willingly offer the product to their child. This includes voluntarily asking about child’s product preference, suggesting a certain product, inviting them for the product selection. In this ‘voluntarily asking about their product preference’, ‘suggesting a certain product’, ‘inviting them for the product selection’ contributes 44.44%, 55.55% and 44.44% respectively towards the AP initiated dema nd.

Essay --

â€Å"Did you ever hear of the Great Potato Famine?† (Mallon, 2013) The Great Potato Famine was a seven year period of mass starvation in Ireland between 1845 and 1852, which killed between five hundred thousand and one point five million Irish. The Great potato famine killed millions of people from starvation. Additional people died once they migrated from Ireland because they ended up having to live in overcrowded work houses. The cause of the Great Potato Famine was due to an organism called the Phytophthera Infestans (The Free Dictionary, 2013). After reading this paper the reader will know everything there is to know about the Great Potato Famine including the main topics of the Great Potato Famine, which will be covered in detail. The main topics that will be covered are the migration of the potato blight to Ireland and the history of the potato, land consolidation and agriculture laws in Ireland, food exports in Ireland during the time of the famine, the potato dependency to the Irish and the Irish/ English relation at the time of the Great Potato Famine. This paper is being written to prove that the Great Potato Famine was the worst disease to happen to the Irish in the 1800s. The whole potato famine was caused by potato blight, which was stated above. However, the potato blight wasn’t always in Ireland. But, then again, neither was the potato. They both had actually migrated to Ireland. The potato was not native to Ireland. It was believed that Sir Walter Raleigh brought the potato to Ireland from the new world in about 1507. The potato was perfect for the Irish climate. Potatoes grow great in moist climates where it is not too hot. They are also very good at growing in higher elevation like in the mountains... ...Irish thought about the situation. Seeing now that the main topics of the Great Potato Famine have been covered, the reader of this paper should be very well educated on the migration of the Potato Blight to Ireland along with the history of the potato, land consolidation and agriculture laws in Ireland, food exports in Ireland during the time of the famine, the potato dependency to the Irish, and the Irish/ English relationship at the time of the Great Potato Famine. Now that the reader is educated on the topic, did this paper prove the thesis that the Great Potato Famine was the worst disease to happen to the Irish in the 1800s? While the reader is thinking about if this paper proved that the Great Potato Famine was the worst disease to happen to the Irish in the 1800s, also question if this disease could be the worst disease to happen to the Irish of all time?

Transfer Pricing

Chapter 1 Introduction of the Topic TRANSFER PRICING TRANSFER PRICING is a term used to describe all aspects of inter Company pricing arrangements between related business entities, and commonly applies to inter Company transfers of tangible and intangible property. Inter Company transactions across borders are growing rapidly and are becoming much more complex. Transfer pricing refers to the internal pricing system that is used when divisions in the same firm deliver products or services to each other. The transfer price is a cost for the receiving division and revenue for the supplying division, so it affects the financial result of both divisions involved. Transfer prices can be based on market prices, but for various reasons a market-based transfer price might not be appropriate: transactions taking place between the divisions of the same firm are often unique and would not be offered stand-alone on the market. In practice, therefore, cost-based and negotiated transfer prices are used apart from market-based prices. Transfer pricing, for tax purposes, is the pricing of inter Company transactions that take place between affiliated businesses. The transfer pricing process determines the amount of income that each party earns from that transaction. Taxpayers and the taxing authorities focus exclusively on related-party transactions, which are termed controlled transactions, and have no direct impact on independent-party transactions, which are termed uncontrolled transactions. Transactions, in this context, are determined broadly, and include sales, licensing, leasing, services, and interest In India also, considering the importance of Transfer Pricing, Section 92 of the Income-tax Act, 1961 (‘the Act’) empowered tax authorities to make adjustments to income on arm’s length basis in case of transactions between residents and nonresidents having ‘close connection’. Also, section 40A (2) (a) was introduced in the Statute, giving powers to the assessing officer to disallow the expenditure incurred in respect of which payment is made to related parties, if assessing officer is of the opinion that such expenditure is excessive or unreasonable. However, these sections were limited in scope and had certain inadequacies viz. the term ‘close connection’ was not defined, there were no rules concerning documentation, the burden of proof was on the assessing officer, no rules were prescribed for determining arm’s length prices etc. On the Customs side, under the Customs Valuation (Determination of Price of Imported Goods) Rules, 1988, there were provisions for rejecting the transaction value when the buyer and seller were related persons or when they had interest in one another’s businesses. Corporate the world over are expanding their wings in an effort to gain a share of the global pie. There is talk of the world fast turning into a global village with economies increasingly becoming inter-connected. But with cross-border trade comes a whole new set of problems, Transfer pricing is one of them. When a company opens a branch in another country, gets its products manufactured there and then imports it, there is a question mark over what price should the parent pay for buying the product from the subsidiary. This price till now has been subject to the parent’s discretion and has been used by many corporate the world over to control the tax outgo to their Government. In effect, the price at which goods are transferred from one arm of the company to another is known as transfer pricing. The Finance Act 2001 introduced the detailed Transfer Pricing Regulations (T. P. R. ) in India from 1stApril 2001 APPROACHES TO TRANSFER PRICING Taxation that is based on transfer pricing is becoming an important issue for many companies, whether U. S. based or foreign based. The regulations have sought to impose extensive general principles and guidelines that apply when the taxpayer selects the transfer pricing method. These methods impose penalties on an inappropriate choice of a transfer pricing method. In addition, the administrative cost of complying with the regulations can be extensive. As a result, implementation of the transfer pricing regulations may impose significant costs on the taxpayer above and beyond the taxes themselves. Faced with this transfer pricing onslaught, businesses have chosen different approaches to the tax aspects of transfer pricing. At the outset, the selection of a transfer pricing strategy is determined by three factors: 1. Taxes imposed on the transfer pricing decision 2. Administrative time and expense incurred 3. Potential penalties (which are discussed next) Over the past decades, the topic of ‘transfer pricing’ has continuously attracted attention in the literature. The reasons for this intensive degree of attention are diverse. Lots of managers, in particular CFOs and controllers, can elaborate on the number of hours spent in order to reach a transfer pricing policy that is satisfactory and acceptable for all organizational members involved. Tax managers in multinational enterprises (MNEs), from their side, will explain the difficulties they encounter when fulfilling the transfer pricing tax rules in the different countries in which they operate. This article focuses on the dual role of transfer pricing – managerial versus tax compliance and sheds insights by approaching these issues from a corporate governance perspective. [pic] It is a well known fact that Multi-National Enterprises (MNEs) have found India conducive to set up their operations, largely because of the availability of a skilled work force at reasonable costs. Investments into India result in transactions between the Indian and the parent company as also between the Indian company and other foreign group companies. Such transactions could encompass sale of goods, provision of services, licensing of intangibles, to give a few examples. These transactions give rise to transfer pricing issues. Transfer prices are important for both tax payers and tax authorities because they determine, in large part, the income, expense and taxable profits of the associated (group) enterprises in different tax jurisdictions. Effective April1, 2001, India introduced a comprehensive TP legislation as an anti-avoidance measure. The Indian TP regulations are broadly based on the transfer pricing guidelines issued by the Organization for Economic Co-operation and Development (OECD), but are unique in some respects. The Indian TP regulations mandate that international transactions with related parties shall be determined having regard to the arm's length price, i. e. the price that would be charged by enterprises in an uncontrolled transaction. In India, not only are taxpayers selected for compulsory audits based on quantitative parameters i. . international transactions in excess of INR 50 million in a fiscal year (proposed to be increased to INR 150 million), but further, Indian tax authorities are seen as adopting an increasingly aggressive approach on TP related issues. In several cases, in the recent past, taxpayers faced significant challenges in defending their transfer prices. Taxpayers typically defen d their transfer prices as being at arm's length by conducting a transfer pricing study and comparing their net margins with those earned by comparable uncontrolled enterprises. Therefore, whether a particular transfer price is accepted as being at arm's length or not depends to a large extent on the process of selecting comparable data for the analysis. The lack of quality comparable data in public domain is a challenge faced by the taxpayers while preparing their documentation. This challenge is further compounded by the approach adopted the Transfer Pricing Officers (TPOs) during audits. In addition to using comparable data which was not available at the time of preparing the documentation, TPOs have also resorted to â€Å"cherry-picking† of comparables (especially y eliminating loss making/ low turnover comparables) rather than adopting an objective approach to identifying and screening the comparable companies. This approach creates a bias in favor of profitable companies in the comparable data, resulting in transfer pricing adjustments for the taxpayers. The worst affected were captive service providers, which bear little or no risks as they dea l with parent or group companies as compared to comparable uncontrolled transactions undertaken by other companies which cater to third parties and bear a range of risks including recovery of the price from the third party customers. or captive service providers. It is a fundamental economic principle that entities which However, in a number of instances, TPOs have largely ignored the importance of risk in a transfer pricing analysis and determined high mark ups on costs, to be the arm's length margin do not undertake risks can expect to earn a lower rate of return. Recently, The Delhi Income Tax Appellate Tribunal (ITAT) has revived the hopes of tax payers in India. This decision was given in the case of a captive service provider, Mentor Graphics (Noida) Private Limited, engaged in rendering software services to its US parent. The decision has laid down certain broad principles that could have a significant influence on transfer pricing in India. Steps of Transfer Pricing The scope for Transfer Pricing in such transactions also increases in cases with ‘tie-in’ clauses in licensing agreements or technical/financial collaborations which require the purchase of goods from the licensor or party designated by the licenser. There are three aspects of Transfer Pricing which are:- i) Motivational and Operational Aspect, ii) Regulation of Transfer Pricing, iii) Estimation and control. i) Motivational and Operational Aspect:- Operational and financial manipulations for transfer pricing take the form of false invoicing. This is defined by the OECD Committee on Fiscal Affairs (1976), as- â€Å"A transaction intended to evade tax by putting taxable objects outside the reach of national tax authorities by means of an invoice that does not accord with economic facts† This object is achieved through bo th under and over invoicing (of imports and exports), often by the same company. Policy induced motivation for transfer pricing manipulations may arise because of both tax and non-tax factors. Corporate tax rates and fiscal provisions, exchange rate fluctuations and import duties as also labor laws, policies restricting monopolies International tax avoidance to achieve these and other objectives may occur through general manipulations, as well as through specific items in the balance sheet and the profit and loss account. In BS loans to foreign affiliates may represent the repatriation of foreign profits in an attempt to avoid domestic payment of dividends, as also may excessive balances with affiliates. Write-off of inter company debt may be attempted to reduce balances that may have resulted from non arms length transaction. Omissions in the balance sheet of expected assets or liabilities may indicate transfer or sale of intangible assets like patents, know-how etc to tax affiliates. In P&L A/c, R and D expenditures may be hidden, pooled or distributed to avoid taxes; royalties may be excessive and may go to unlikely recipient affiliates; patents and trademarks may be charged for at monopolistic rates, or involve reciprocal benefits and may be prices even after their expiry. In case of payments, for both royalties and patents and trademarks, to affiliates the charges may not meet with the arm’s length criterion. Payments for home-office administrative support, R and D etc. , may be excessive and may contain hidden profits which are not assessed in the country of receipt. Sales of partly finished goods, third party commissions or discounts to foreign affiliates, unexpected purchases or sales, rentals, office and travel expenses, changes in the pattern of accounts, liquidation and sales of foreign affiliates etc. also provide ample opportunity for transfer pricing and consequently tax avoidance. (ii) Regulation of Transfer Pricing:- In a mixed economy like ours this could mean a misallocation of resources, accompanied by an adverse redistribution of incomes away from national entities and the related BOP effects. Before dealing with transfer pricing before it can occur and after it has occurred, policy regulation is therefore also required, to deal with its macro economic consequences. The adverse impact on host government foreign exchange; revenue losses and the consequent implications for internal resources mobilization; distortion in the functioning of specific policy instruments resulting in the non-achievement of plan targets; all call for an active role of the state. Similarly, at the micro level the proliferation of market concentration and oligopolistic practices require state intervention. (iii) Estimation and Control:- 1). Any proper appraisal of the scope of transfer pricing manipulations on the part of transnational corporations, and of their actual practice must be assessed within the framework of the specific set of government measures and structural factors endemic to TNCs which tend to be the motivational forces behind such practices. 2). Abandon the free market model and allow for a changed role of the state, from one of trying to restore some traditional version of market relations to that of an active intervener in the struggle over international distribution of surplus. Keeping in mind these approaches, we would like to focus on the problem of estimation the extent of pricing manipulations by TNCs, in various sectors and industries in developing countries, in the context of relevant government policies and regulations. Exemption for Bankers Bankers have sought an exemption from the provisions of transfer pricing regulations. When banks extend loans and guarantees by way of investment in equity, this may lead to the specified shareholding limits being exceeded. Though the banks may not have any control over the company, such transactions are subjected to transfer pricing rules of the Income Tax Act. In their meeting with the finance minister earlier this month, public sector banks had said banks should be excluded from the purview of the transfer pricing provisions under the income tax law. Current regulations also cover loans advanced for not less than 51% of the book value of the total assets of the borrower and guarantees granted for more than 10% of the total borrowings of the guarantor. But experts feel that banks do not usually have so much exposure to a single borrower. Banks provide financial assistance to various corporate and non-corporate clients by way of investment in equity or preference shares, subscription to debentures, loans and guarantees. Under section 40A(2) of the Income Tax Act, any expenditure incurred between related parties treated as unreasonable by the assessing officer is not allowed as a deduction. This section empowers an assessing officer to disallow deduction of any expenditure incurred between related parties and considered by the officer as excessive or unreasonable having regard to the fair market value of the goods, services or facilities. Similar restrictions are applicable to banks according to the transfer pricing provisions under sections 92 A to 92F. The scope of related person under section 40A(2) for a banking company includes a person in whom it has a substantial interest in the business, where ownership of shares is not less than 20% of the voting power. However, according to Reserve Bank of India regulations, voting powers are limited to 10%, irrespective of the ownership of shares. The transfer pricing provisions (sections 92 to 92F) only apply to transactions between two non-residents or between a resident and a non-resident and not to transactions between Indian banks and Indian counterparties. â€Å"While the transfer pricing provisions can be applied to transactions between the foreign subsidiaries of Indian banks and Indian counterparties, only under very rare exceptions do such foreign subsidiary banks have an exposure to unrelated borrowers to bring their transactions within the transfer pricing rules. â€Å"Also, it is unlikely that transactions between Indian branches of foreign banks and Indian counterparties would result in a loan greater than 51% of the book value of assets of the borrower for the transfer pricing rules being made applicable to genuine third party transactions. The objective of transfer pricing is that the correct amount of profits should be retained within the country and thus the transfer pricing provisions should be made inappl icable to transactions between Indian branches of foreign banks and the group’s related Indian companies,† Mr Wadhwani added. While lending, banks may grant loans at fluctuating rates compared with market rates after factoring in risk factors, creditability and type of industry. Given that the pricing adopted is within the framework of norms outlined by banks that are regulated by RBI, the Indian Banks Association is of the view that banks should be removed from the purview of such sections TYPICAL CASH FLOW The question arises that how the transfer price can be used as a mechanism to evade tax, especially between countries that have a treaty against double taxation. To explain this let’s take an example. Suppose there is an MNC shoe corporation with a subsidiary in India. The Indian subsidiary manufactures shoes at a cost price of Rs 50 per unit and supplies it to the MNC. The MNC sells the same shoes in its own country at Rs 200. To be fair, the transfer price, which the Indian subsidiary should get, is cost plus a reasonable rate of return (i. e. Rs 50 plus). This is where the MNC company calls the shots. In India, the corporate tax on profits is at 35%. Suppose for the MNC country the rate of tax is 45%. Case 1. The MNC decides that Rs 100 is the correct transfer price. Then the scenario looks like this: Transfer Price at Rs 100 |Indian subsidiary |MNC |Grand Total | |Cost price |50 |100 |   | |Selling price |100 |200 |   | |Profit |50 |100 |150 | |Tax |17. 5 |45 |62. 5 | |Net Profit |32. 5 |55 |87. 5 | The transfer price becomes the cost price for the MNC and thus it earns a profit of Rs 100 per unit. Post tax, its profit is whittled down to Rs 55. Overall, the total profit after tax earned by the MNC (including the subsidiary’s profit) is Rs 87. per unit. Case 2. The MNC decides that Rs 150 is the correct transfer price. Then the scenario looks like this: Transfer Price at Rs 150 |Indian subsidiary |MNC |Grand Total | |Cost price |50 |150 |   | |Selling price |150 |200 |   | |Profit |100 |50 |150 | |Tax |35 |22. 5 |57. 5 | |Net Profit |65 |27. 5 |92. 5 | The MNC’s profits post tax in its own country comes down to Rs 27. 5. But overall the profit surges to Rs 92. 5 per unit. Case 3. The MNC decides that Rs 200 is the correct transfer price. In such a case, the MNC earns zero profits in its own country, but its subsidiary pays a 35% tax on its profit of Rs 150 and thus overall net profit surges to Rs 97. 5. Transfer Price at Rs 200 |Indian subsidiary |MNC |Grand Total | |Cost price |50 |200 |   | |Selling price |200 |200 |   | |Profit |150 |0 |150 | |Tax |52. 5 |0 |52. 5 | |Net Profit |97. 5 |0 |97. 5 | Case 4. The MNC decides that Rs 300 is the correct transfer price. In this case, the MNC earns a loss of Rs 100 per unit of shoe sold in the home country. Meanwhile, its subsidiary earns Rs 162. 5 as profit, after paying Rs 87. 5 as tax. But the clever MNC gets a tax write off at home worth Rs 45 m. Transfer Price at Rs 300 |Indian subsidiary |MNC |Grand Total | |Cost price |50 |300 |   | |Selling price |300 |200 |   | |Profit |250 |-100 |150 | |Tax |87. 5 |-45 |42. | |Net Profit |162. 5 |0 |192. 5 | Please remember, these are just a few hypothetical simple situations. In reality, these dealings are much more complex with conglomerates having more than 50 subsidiaries in just as many countries. Transfer pricing became a subject of much debate in the western countries as government’s felt that corporates are down paying their fair share of tax. As a result, these countries spearheaded awareness regarding transfer pricing. Case Study High Court Rules Against Coca-Cola in Tra nsfer Pricing Case M Padmakshan Economic Times January 6, 2009 MUMBAI: The Punjab & Haryana High Court has ruled against Coca-Cola India's contention that the proof of profit transfer outside India is a precondition for applying transfer pricing rules. Coca-Cola had approached the high court after it was served a notice on transfer pricing. The soft drink company had an agreement to offer advisory services to Britco at the rate of cost plus 5%. Coca-Cola's main contention was that transfer pricing rules cannot be applied in the absence of prima facie evidence of profit transfer outside India. The high court said that India's transfer pricing rules can be applied to any cross-border transaction between associated enterprises, irrespective of profit transfer outside India. The court said the only requirement is income generation in a cross-border transaction and income has been computed at arms length. Coca-Cola told the court that transfer pricing rules were meant to check profit erosion outside India and therefore could not be applied in cases where there is no prima facie evidence of profit transfer outside the country. The high court did not accept this view. It held that existence of a cross-border transaction and computation of the resultant income at arm's length price are sufficient grounds for applying transfer pricing rules. According to Coca-Cola, the transfer pricing provisions have been incorporated in the Income-tax Act by the Finance Act 2001 and the applicability of these provisions has been limited to situations involving profit diversion outside India. There is no material evidence to show that profits have been diverted outside India, the company said. The court said that it is the prerogative of the income-tax department to issue such a notice and expressed its inability to intervene in the matter. Coca-Cola was assessed under I-T Act in 2004 for the year 1998-99. The dispute arose after the income-tax department concluded that the income had escaped assessment under the Income-Tax Act. FAIR USE NOTICE: – This document contains copyrighted material whose use has not been specifically authorized by the copyright owner. India Resource Center is making this article available in our efforts to advance the understanding of corporate accountability, human rights, labor rights, social and environmental justice issues. We believe that this constitutes a ‘fair use' of the copyrighted material as provided for in section 107 of the U. S. Copyright Law. If you wish to use this copyrighted material for purposes of your own that go beyond ‘fair use,' you must obtain permission from the copyright owner. Arm’s Length Method Arm’s length, as the term indicates, means keeping a neutral balance between inter-corporate arms. The idea is that companies should treat each subsidiary as a separate entity and deal with them on purely commercial terms, as they would have if they transacted with any other market player. Arm’s length methodologies are of two types:- a) Transactional Methods b) Profit Methods Transactional Methods – Where focus is on the product or the technology to ascertain the correct transfer price. Transaction methods can be further divided into three broad sub-groups. ) Comparable Uncontrolled Price Method 2) Resale Price Method 3) Cost Plus Method (1) Comparable Uncontrolled Price (CUP) Method: The price charged or paid in a comparable uncontrolled transaction or a number of such transactions shall be identified. Such price shall be adjusted to account for differences, if any, between the related party transaction and the comparable uncontrolled transactions or between th e enterprises entering into such transactions, which could materially affect the price in the open market. The adjusted price shall be taken as arm’s length price. The uncontrolled transaction means a transaction between independent enterprises other than related parties and shall cover goods or services of a similar type, quality and quantity as those between the related parties and relate to transactions taking place at a similar time and stage in the production/distribution chain with similar terms and conditions applying. (2) Resale Price Method: The price at which the goods purchased or services obtained from a related party is resold or is provided to an unrelated entity shall be identified. Such resale price shall be reduced by the amount of a normal gross profit margin accruing to the enterprise or to an unrelated enterprise from the purchase and resale of the same or similar goods or services in a comparable uncontrolled transaction or a number of such transactions. The price so arrived at shall be further reduced by the expenses incurred by the enterprise in connection with the purchase of goods or services. Such price shall be further adjusted to take into account the functional and other differences including differences in accounting practices, if any, between the related party transaction and the comparable uncontrolled transactions or between the enterprises entering into such transactions, which could materially affect the amount of gross profit margin in the open market. The adjusted price shall be taken as arm’s length price in respect of goods purchased or services obtained from the related party. The resale price method would normally be adopted where the seller adds relatively little or no value to the product or where there is little or no value addition by the reseller prior to the resale of the finished products or other goods acquired from related parties. This method is often used when goods are transferred between related parties before sale to an independent party. (3) Cost Plus Method: The total cost of production incurred by the enterprise in respect of goods transferred or services provided to a related party shall be determined. The amount of a normal gross profit mark-up to such costs arising from the transfer of same or similar goods or services by the enterprise or by an unrelated enterprise in a comparable uncontrolled transaction or a number of such transactions shall be determined. The amount of a normal gross profit mark-up shall be adjusted to take into account the functional and other differences, if any, between the related party transaction and the comparable uncontrolled transactions or between the enterprises entering into such transactions, which could materially affect such profit mark-up in the open market. The total cost of production referred to above increase by the adjusted profit mark-up shall be taken as arm’s length price. It is also important here to ensure that the cost base to which mark-up is applied is comparable to the cost base of the third party transaction which serves as comparable. For example, it may be necessary to make an adjustment to cost where one person leases its business assets while other owns its business assets. The cost plus method would normally be adopted if CUP method or resale price method cannot be applied to a specific transaction or where goods are sold between associates at such stage where uncontrolled price is not available or where there are long term buy and supply arrangements or in the case of provision of services or contract manufacturing. Profit method- It has been further sub-divided into three sub-groups i) Profit Split Method ii) Transactional Net Margin Method iii) Authentication of Documents Provided by the Company (1) Profit Split Method: The combined net profit of the related parties arising from a transaction in which they are engaged shall be determined. This combined net profit shall be partially allocated to each enterprise so as to provide it with a basic return appropriate for the type of transaction in which it is engaged with reference to market returns achieved for similar type transactions by independent enterprises. The residual net profit, thereafter, shall be split amongst the related parties in proportion to their relative contribution to the combined net profit. This relative contribution of the related parties shall be evaluated on the basis of the function performed, assets employed or to be employed and risks assumed by each enterprise and on the basis of reliable market data which indicates how such contribution would be evaluated by unrelated enterprises performing comparable functions in similar circumstances. The combined net profit will then be split amongst the enterprises in proportion to their relative contributions. The profit so apportioned shall be taken into account to arrive at an arm’s length price This method would normally be adopted in those transactions where integrated services are provided by more than one enterprise or in the case multiple inter-related transactions which cannot be separately evaluated. 1) Transactional Net Margin Method : The net profit margin realized by the enterprise from a related party transaction shall be computed in relation to costs incurred or sales affected or assets employed or to be employed by the enterprise or having regard to any other relevant base. The net profit margin realized by the enterprise or by an unrelated enterprise from a comparable uncontrolled transaction or a number of such transactions, shall also be computed having regard to the same base. This net profit margin shall be adjusted to take into account the differences, if any, between the related party transaction and the comparable uncontrolled transactions or between the enterprises entering into such transactions, which could materially affect such net profit margin in the open market. The cost of production referred to above increase by the adjusted profit mark-up shall be taken as arm’s length price. The adjusted net profit margin shall be taken as arm’s length price. This method would normally be adopted in the case of transfer of semi finished goods; distribution of finished products where resale price method cannot be adequately applied; and transaction involving provision of services. (3) Authentication of the documents provided by the company The information/documents provided by the company to the auditor for certification as provided in clause 7 hereof shall be signed on behalf of the Board by the Company Secretary and at least one Director of the company. In the absence of Company Secretary in the company, the same shall be signed by at least two Directors of the company on behalf of the Board. [pic] The most appropriate method referred to in sub-section (1) shall be applied, for determination of arms length price, in the manner as may be prescribed: Provided that where more than one price is determined by the most appropriate method, the arms length price shall be taken to be the arithmetical mean of such prices, or, at the option of the assessee, a price which may vary from the arithmetical mean by an amount not exceeding five per cent of such arithmetical mean. ] Where during the course of any proceeding for the assessment of income, the Assessing Officer is, on the basis of material or information or document in hi s possession, of the opinion that:- (a)The price charged or paid in an international transaction has not been determined in accordance with sub-sections (1) and (2); or b)any information and document relating to an international transaction have not been kept and maintained by the assessee in accordance with the provisions contained in sub-section (1) of section 92D and the rules made in this behalf; or (c)The information or data used in computation of the arms length price is not reliable or correct; or (d)the assessee has failed to furnish, within the specified time, any information or document which he was required to furnish by a notice issued under sub-section (3) of section 92D, The Assessing Officer may proceed to determine the arms length price in relation to the said international transaction in accordance with sub-sections (1) and (2), on the basis of such material or information or document available with him: Provided that an opportunity shall be given by the Assessing Officer by serving a notice calling upon the assessee to show cause, on a date and time to be specified in the notice, why the arms length price should not be so determined on the basis of material or information or document in the possession of the Assessing Officer. Where an arms length price is determined by the Assessing Officer under sub-section (3), the Assessing Officer may compute the total income of the assessee having regard to the arms length price so determined: Provided that no deduction under section 10A 82[or section 10AA] or section 10B or under Chapter VI-A shall be allowed in respect of the amount of income by which the total income of the assessee is enhanced after computation of income under this sub-section : Provided further that where the total income of an associated enterprise is computed under this sub-section on determination of the arms length price paid to another associated enterprise from which tax has been deducted 83[or was deductible] under the provisions of Chapter XVIIB, the income of the other associated enterprise shall not be recomputed by reason of such determination of arms length price in the case of the first mentioned enterprise. While going through each of these methods, it becomes clear that all these methods are not definitive methods for ascertaining transfer prices. Being a complex subject, more fine-tuning is needed to finally get a definitive benchmark method for calculating the transfer price. As business between countries is likely to only increase in future, transfer-pricing issues would be subject of even more scrutiny not only by government and legal bodies, but also the companies’ respective shareholders. But there is a lot of ground still to be done in this area. Speaking on the sidelines of a budget analysis session organized by Confederation of Indian Industry, Rohan K Phatarphekar, executive director nd national head, global transfer pricing services KPMG India Private Limited said, â€Å"The Budget was not bad, there was too much of expectations from the market. What the Budget lacked was clarity, the government failed to lay down a concrete roadmap to bridge the fiscal deficit. † But significant changes were announced in the tax structure like removal of FBT, removal of 10 per cent surcharge on the higher bracket of i ncome tax, commitment to introducing GST. [pic] Difficulties in applying Arm’s Length Principle . Multinational Enterprises groups are dealing in the integrated production of highly specialized goods, in unique intangibles, and in the provision of specialized services. 2. Associated Enterprises may engage in transactions that independent would not undertake, example sale or license of intangibles. 3. Arm’s Length Price may result in an administrative burden for both the tax administrations of evaluating significant numbers and types of cross-border transactions. 4. Far placed geographical locations and confidentiality etc. may cause difficulty in obtaining comparable data. Transfer Pricing in IT Department Commercial transactions between the different parts of the multinational groups may not be subject to the same market forces shaping relations between the two independent firms. One party transfers to another goods or services, for a price. That price is known as transfer price. This may be arbitrary and dictated, with no relation to cost and added value, diverge from the market forces. Transfer price is, thus, a price which represents the value of good; or services between independently operating units of an organization. But, the expression transfer pricing generally refers to prices of transactions between associated enterprises which may take place under conditions differing from those taking place between independent enterprises. It refers to the value attached to transfers of goods, services and technology between related entities. It also refers to the value attached to transfers between unrelated parties which are controlled by a common entity. Example of using Transfer Pricing Suppose a company A purchases goods for 100 rupees and sells it to its associated company B in another country for 200 rupees, who in turn sells in the open market for 400 rupees. Had A sold it direct, it would have made a profit of 300 rupees. But by routing it through B, it restricted it to 100 rupees, permitting B to appropriate the balance. The transaction between A and B is arranged and not governed by market forces. The profit of 200 rupees is, thereby, shifted to the country of B. The goods is transferred on a price (transfer price) which is arbitrary or dictated (200 hundred rupees), but not on the market price (400 rupees). Thus, the effect of transfer pricing is that the parent company or a specific subsidiary tends to produce insufficient taxable income or excessive loss on a transaction. For instance, profits accruing to the parent can be increased by setting high transfer prices to siphon profits from subsidiaries domiciled in high tax countries, and low transfer prices to move profits to subsidiaries located in low tax jurisdiction. As an example of this a group which manufactures products in high tax countries may decide to sell them at a low profit to its affiliate sales company based in a tax haven country. That company would in turn sell the product at an arm's length price and the resulting (inflated) profit would be subject to little or no tax in that country. The result is revenue loss and also a drain on foreign exchange reserves Reference to Transfer Pricing Officer. 92CA. (1) Where any person, being the assessee, has entered into an international transaction in any previous year, and the Assessing Officer onsiders it necessary or expedient so to do, he may, with the previous approval of the Commissioner, refer the computation of the arm’s length price in relation to the said international transaction under section 92C to the Transfer Pricing Officer. (2) Where a reference is made under sub-section (1), the Transfer Pricing Officer shall serve a notice on the assessee requiring him to produce or cause to be produced on a date to be specified therein, any evidence on which the assessee may rely in support of the computation made by him of the arm’s length price in relation to the international transaction referred to in sub-section (1). 3) On the date specified in the notice under sub-section (2), or as soon thereafter as may be, after hearing such evidence as the assessee may produce, including any information or documents referred to in sub-section (3) of section 92D and after considering such evidence as the Transfer Pricing Officer may require on any specified points and after taking into account all relevant materials which he has gathered, the Transfer Pricing Officer shall, by order in writing, determine the arm’s length price in relation to the international transaction in accordance with sub-section (3) of section 92C and send a copy of his order to the Assessing Officer and to the assessee. 4a[(3A) Where a reference was made under sub-section (1) befo re the 1st day of June, 2007 but the order under sub-section (3) has not been made by the Transfer Pricing Officer before the said date, or a reference under sub-section (1) is made on or after the 1st day of June, 2007, an order under sub-section (3) may be made at any time before sixty days prior to the date on which the period of limitation referred to in section 153, or as the case may be, in section 153B for making the order of assessment or reassessment or re computation or fresh assessment, as the case may be, expires. ] 84b[(4) On receipt of the order under sub-section (3), the Assessing Officer hall proceed to compute the total income of the assessee under sub-section (4) of section 92C in conformity with the arm’s length price as so determined by the Transfer Pricing Officer. ] (5) With a view to rectifying any mistake apparent from the record, the Transfer Pricing Officer may amend any order passed by him under sub-section (3), and the provisions of section 154 sha ll, so far as may be, apply accordingly. (6) Where any amendment is made by the Transfer Pricing Officer under sub-section (5), he shall send a copy of his order to the Assessing Officer who shall thereafter proceed to amend the order of assessment in conformity with such order of the Transfer Pricing Officer. 7) The Transfer Pricing Officer may, for the purposes of determining the arm’s length price under this section, exercise all or any of the powers specified in clauses (a) to (d) of sub-section (1) of section 131 or sub-section (6) of section 133. Undesirable Corporate Practices Related to Transfer Pricing Some of the related party transactions, which are usually resorted to for diversion of funds are detailed below. (a)  Ã‚  Ã‚   Purchase of goods or services from a related party at little or no cost or at inflated prices to the entity. (b)  Ã‚   Payments for services never rendered or at inflated prices. (c)  Ã‚  Ã‚   Sales at below market rates to an unnecessary â€Å"middle man† related party, who in turn sells to the ultimate customer at a higher price with the related party (and ultimately its principals) retaining the difference. (d)  Ã‚   Purchases of assets at prices in excess of fair market value. e)  Ã‚  Ã‚   Use of trade names or patent rights at exorbitant rates even after their expiry or at a price much higher than the price, which can not be described as reasonable. (f)  Ã‚  Ã‚  Ã‚   Borrowing or lending on an interest-free basis or at a rate of interest significantly above or below market rates prevailing at the time of the transaction. (g)  Ã‚  Ã‚   Exchanging property for similar property in a non monetary transaction. (h)  Ã‚  Ã‚   Selling real estate at a price that differs significantly from its appraised value. (i)  Ã‚  Ã‚  Ã‚  Ã‚   Accruing interest at above market rates on loans. Associated Enterprise. 92A. (1) For the purposes of this section and sections 92, 92B, 92C, 92D, 92E and 92F, associated e nterprise, in relation to another enterprise, means an enterprise a)Which participates, directly or indirectly, or through one or more intermediaries, in the management or control or capital of the other enterprise; or (b)In respect of which one or more persons who participate, directly or indirectly, or through one or more intermediaries, in its management or control or capital, are the same persons who participate, directly or indirectly, or through one or more intermediaries, in the management or control or capital of the other enterprise. (2) 77[For the purposes of sub-section (1), two enterprises shall be deemed to be associated enterprises if, at any time during the previous year,] (a)one enterprise holds, directly or indirectly, shares carrying not less than twenty-six per cent of the voting power in the other enterprise; or b)any person or enterprise holds, directly or indirectly, shares carrying not less than twenty-six per cent of the voting power in each of such enterpris es; or (c)a loan advanced by one enterprise to the other enterprise constitutes not less than fifty-one per cent of the book value of the total assets of the other enterprise; or (d)One enterprise guarantees not less than ten per cent of the total borrowings of the other enterprise; or (e)more than half of the board of directors or members of the governing board, or one or more executive directors or executive members of the governing board of one enterprise, are appointed by the other enterprise; or f)more than half of the directors or members of the governing board, or one or more of the executive directors or members of the governing board, of each of the two enterprises are appointed by the same person or persons; or (g)the manufacture or processing of goods or articles or business carried out by one enterprise is wholly dependent on the use of know-how, patents, copyrights, trade-marks, licenses, franchises or any other business or commercial rights of similar nature, or any da ta, documentation, drawing or specification relating to any patent, invention, model, design, secret formula or process, of which the other enterprise is the owner or in respect of which the other enterprise has exclusive rights; or h)ninety per cent or more of the raw materials and consumables  required for the manufacture or processing of goods or articles carried out by one enterprise, are supplied by the other enterprise, or by persons specified by the other enterprise, and the prices and other conditions relating to the supply are influenced by such other enterprise; or (i)the goods or articles manufactured or processed by one enterprise, are sold to the other enterprise or to persons specified by the other enterprise, and the prices and other conditions relating thereto are influenced by such other enterprise; or (j)Where one enterprise is controlled by an individual, the other enterprise is also controlled by such individual or his relative or jointly by such individual and relative of such individual; or k)Where one enterprise is controlled by a Hindu undivided family, the other enterprise is controlled by a member of such Hindu undivided family or by a relative of a member of such Hindu undivided family or jointly by such member and his relative; or Chapter 2 Objectives of the Study Objectives of the Study:- Primary Objectives: 1) To study the acceptability of different methods of Transfer Pricing in the companies. 2) To find out the ways of applying Arm’s Length Method and the results of it. 3) To study the different terms like Associated Enterprises, Transfer pricing officer, International Transaction & Subsidiary company etc. Secondary Objectives 1) To identify various other ways of managing the profit of the company. 2) To analyse different ways of applying extra cash flow. ) To find different ways of Transfer Pricing which are applicable under Income Tax Act 1961. Chapter 3 Company Profile COMPANY PROFILE PARAMOUNT Established in 1993, P aramount Surgimed Ltd. manufactures wide range of Surgical Blades, Scalpels which cover General Surgery and other Surgical Area viz: Gastroentrology, Urology, Orthopedic & General Surgery etc. Paramount Surgimed Ltd. is exporting their products in more than 50 countries. Paramount Surgimed Ltd. is first Company who has been approved by ISI, ISO 9001 & FDA registered company and their products are CE marked. A guiding sense of concern for mankind and a mission to realize richer human life led to the birth of PARAMOUNT SURGIMED LTD. Paramount has grown with a reputation of specializing in manufacturing of a wide range of single use medical and surgical devices such as Surgical Blades, Disposable Scalpels, Stitch Cutters and Skin Graft Blades. Paramount has its corporate head office in New Delhi, the capital of India & operates its major production activities from Bhiwadi in Rajasthan. This has a floor space of 30000 sq. ft. on 10000 sq. meter. plot and a mere 60 km from the Capital City. The facilities comprise of latest state – of – the – art – manufacturing unit comparable to international standards. Paramount is committed to exceed it’s customer's expectations. All aspects of manufacturing and packaging is done in a clean & controlled environment. We adhere to the policy of strict quality control without mercy by making use of in – house test laboratory, for competitive quality assurance at all times. Blades are sterilized through Gamma Radiation in New Delhi. We are an ISO 9000: 2000 company and the products are CE marked. Our products are also registered with various health ministries around the world. Vision Statement Today India is at the down of the millennium’s exciting future with the liberalization and the opening up of its economy. The world is taking a look at India, her products, and her enterprises. With a vision of being a global leader in Medical Disposables, Paramount Surgimed Ltd. dedicates itself to the crucial sector. Mission Statement We at  Paramount Surgicals, Inc are committed to  design, manufacture and distribute finest spinal implant and instruments. Since its beginning, Paramount Surgical, Inc has stood for one capability above all others – the ability to Innovate. Innovate  is a sense of possibility that allows for freedom beyond mere innovation. We strive without reserve for the greatest possible reliability and quality of our products and to be recognized in the market for our dedication, honesty and services. Paramount Surgimed Limited has created this privacy statement in order to demonstrate our firm commitment to privacy. The following discloses the information gathering and dissemination practices for our Corporate Web site: www. paramountblades. com. . R & D Technology Mission We fully understand the grave implications of technology and are constantly on the move to keeping abreast with rapid technological development towards the quest for excellence in the field of Medical & Surgical disposables. The R & D department not only helps in developing new products and their manufacturing technologies but also in improving existing ones. Quality Commitment Paramount has kept alive quality as a legacy in which quality is not an end but a vehicle for seeking excellence & perfection at all stages. We are committed to exceed our customer's expectations. All aspects of manufacturing and packaging is done in a clean & controlled environment. We adhere to the policy of strict quality control without mercy by making use of in – house test laboratory, for competitive quality assurance at all times. Blades are sterilized through Gamma Radiation in New Delhi. We are an ISO 9000 : 2000 company and the products are CE marked. Our products are also registered with various health ministries around the world Step in to the Future Encouraged with the continued impressive performance, Paramount has decided to expand & diversify in to the other related areas, targeting the year leading into 21st century. Paramount will build additional new manufacturing facilities equipped with latest technologies in the field of healthier business. The responsibility and obligation to the customer to supply the best products in every way is the power of its efforts. Like the tip of an iceberg, only a small part of its work is visible. The significant strength however is the use of most progressive and modern technologies, and the untiring efforts of its employees, who continue to strive for more efficient and better solutions. Response by placing repeat orders for years together, Paramount has a sustained and consistent growth. OSIM Delhi based Paramount Surgimed Ltd. has signed a Master Franchisee Agreement with OSIM International Ltd. , over $ 300 million company and Singapore's largest manufacturer of lifestyle products to import and trade OSIM products in India and Nepal through OSIM India, a division of Paramount Surgimed Ltd. Established in 1980, OSIM is the No. brand in lifestyle products in Singapore, Hong Kong, Taiwan, and Malaysia, UK & USA, Australia, Canada and over 22 franchisee all over the world. OSIM produces superior designs focusing and following ergonomic guidelines along with quality features. OSIM India has opened 23 outlets in the country in just one year. These include outlets in Delhi, Gurgaon, Ludhiana, Kolkata Bangalore, Chennai, Mumbai, Hyderabad, Pune and Indore. By the end of this year it plans to expand and set up a total of 25 more outlets. Quality As we offer lifestyle products related to health, quality is the most important factor that, we take special care of. Our products are completely flawless and stand at par even with the international standards. All our products are checked and tested under strict supervision of experts and doctors, so that they do not cause any adverse health effects. Specially equipped with quality experts who individually examine the products themselves so that our clients can use it in a comfortable way. Fully guaranteed our products have been manufactured with complete care, perfection and precision by world class procedures. Believing in the motto â€Å"quality begins with us†, we have earned enormous accolades. Operations 1. Human Resource:- The Company is having a manpower of around 530 employees all over India. To maintain the proper management on this vast manpower, the company uses the Master Software, â€Å"Portal Data Management†. The turnover ratio of manpower is around 110 employees in a year. Process of Recruitment- To do the recruitment firstly the Manpower assessment is done, then approval is taken from the Heads, HOD’s and then permission is taken from COO’s Basically the company tries to fill the gap internally, by posting the existing employee at the new post, personal sources of employees, their relatives and friends and then if necessary it uses the job portals available on-line and scrutinize the resumes available there. Then the company conduct interview (no G. D. is done), firstly with HR personals then with concern HODs. This process ends for the post of a Front line officer. If a higher person is to be recruited then the interview with COO is also conducted. Then the final result is taken regarding that candidate. Documents to be carried on the date of joining and everything else except the salary (salary is included because many person negotiate other companies on the basis of this LOC) Probationary Period for the new employee remains for 6 months and after that, if he/she (if found suitable), is given permanent employee certificate. Training and Development- Generally the training is provided in the concerning departments only by the employees already working over there. Basically two types of training is provided. i. Product/Technical Training- In this, the training is provided regarding the products of the company and also the work which the new employee is to be done. This includes the hard core training. ii. Soft skills/Non-technical Training- In this training, the soft skills are taught to the candidate, like the behavior of the employees, working conditions, organizational culture etc. Time to time the employees development programs are also conducted to motivate the employees i. e. to understand their personal problem, solving it out, developing their career path, etc 2. I. T. The company is having one single IT department to control all the data base management and all the networking facilities. This department is in head office. The company uses its own made OSIM Software to keep the data and all of its branches are using the same software, which is downloaded by the head office personals with the SQL information. The company is also engaged in on line merchandizing, it makes online sales also with the help of its website. It uses OSIM India as the selling website which is fully organized by the Head Office only. 3. Accounts The Company’s Accounts Department is near to Head Office. The Accounts Department is having a workflow of 25 members who are handling the accounts of the different branches of the Company. The Company is using Tally 9 Software along with MS Office to maintain the records of the customers 4. Marketing:- The Company is having a highly powerful Marketing activity which is the biggest strength of the company. The products of Paramount are traded in both domestic and international markets. Our medical products are being exported to more than 40 Countries across the world like USA, Asia, and South Africa etc. Moreover, OSIM is declared as Asia No. 1 healthy lifestyle brand in consumers’ minds It basically having two types of Sale i. e. a) Corporate- The Company is having almost 35% of its total sales in the Corporates. Its Corporate clients includes ONGC, Japee Hotels, Indian Oil, Hyath Group of Hotels, Apollo Tyres, Apollo Hospitals, Heritage Hospitals, Fortis Hotels etc. The Company is having a big ratio of its sales in Indian Army and other PSU’s b) Retails- The Company’s Retailing is very strong. Almost 65-70% of its sales is based on Retailing. Its Retailing is very wide, which is divided in three modes i. Showrooms- The Company has opened its own Showrooms in different parts of the country, including Chandigarh, Delhi, Ludhiana, Ahemdabad, Kerla, Hyderabad, and many other places. The Showrooms are exclusively defined, and highly modernized, with all the facilities for the visitors. ii Shop in Shops- At many places the Company is having its shops in different shops. This is a very new concept which provide the firm to save money and also having more attention form the visitors along with standing with other different renowned Brands. iii Road Shows- The company has a mode of selling through Road Shows. Road Shows are very popular in Metro Cities and a large amount of sales of the Company is dependent on that. The Company is having its all time Road Show in Delhi, Bangalore, Kolkata, Chennai etc. Products iMedic Chair Revolutionary chair designed for precise massage The new OSIM iMedic Chair is the first of its kind to cater to the specific needs of every individual by detecting the precise location of acupressure points along the back. With more than 300 acupressure points in the body, every person’s body shape is as different as the shape of our face. Determining the exact body shape of the use allows a more sensitive massage to be applied effectively to just the right spot, helping to relieve fatigue and neuralgia, promote blood circulation, ease muscle strain and stiffness, leaving you feeling relaxed all over. Sit back, close your eyes and sink into the luxuriousness of the OSIM iMedic Chair as you relinquish your body to the ultimate massage experience. Detecting Acupressure Points: While seated deeply into the OSIM iMedic Chair with your head resting comfortably on the headrest pad, select any of the 8 comprehensive massage programmes. Before commencement of any programme, the massage rollers automatically glide along the length of your back to detect the acupressure points via 2 infrared sensors. Once detected, you can look forward to a massage experience unlike any other. Shoulder Position Adjustment: You can further personalize the massage programmed by adjusting the position of the rollers at your shoulder area, so you can pinpoint the massage precisely where you want it. Well-being Programmes: These 3 relaxing programmed are designed to enhance your health by adapting massage treatment to your daily routine. Morning Programme: For those who feel an ongoing tiredness and a lack of energy during the day, giving you the extra perk you need Night-time Programme: Use at the end of the day to fully relax your body and prepare you for a good rest. Useful if you suffer from insomnia. Seat Programme: Massages the hip area using a combination of vibration action and seat message. Useful for relief of constipation discomfort. Luxurious Comfort Versatile Design The OSIM iMedic Chair has been designed with features to raise the level of comfort to unparalleled heights. Fully Automatic Reclining System: Recline the backrest and/or the footrest independently at the siple touch of the Remote Controller to find the position that suits you best. Adjustable Angle: The backrest can be reclined up to 170 degree for greater comfort. Extendable Footrest: The footrest can be easily extended to cater to the height of the user. Auto-Timer: Whichever programme you chose, it will automatically run for a maximum of 15 minutes, allowing you to relax your mind while the OSIM iMedic Chair relaxes your body. However, you can turn the programme off or switch to a different programme at any point and the timer will reset automatically. Total Remote Control: A comprehensive Remote Controller with two LCD display screens controls all programmes and functions for an uninterrupted massage session. Anti-bacterial Upholstery Covers: The upholstery covers are specially coated with an anti-bacterial treatment, keeping bacteria like Staphylococcus, Yellow Coliform Bacilli and MRSA at bay. They are completely removable for easy cleaning. Available in white, black, latte and olive. Foldable Backrest and Castors: For easy storage and transportation. Paramount Surgimed Ltd, New Delhi has been chosen as Master Franchise to represent OSIM in India. OSIM India A Division of Paramount Surgimed Ltd shall be promoting a wide range of OSIM products through our exclusive showroom to start with in New Delhi and followed by in other cities. OSIM International Ltd, Singapore came in to existence in the year 1980 with the aim to provide a healthy lifestyle to the mankind. From a humble start to $287. 4 million company, today OSIM is promoting its products through is Master Franchise in over 20 countries. OSIM INDIA is coming up with a top of the line massage chair in India Millennium Chair OS – 747iv: The Master Of Relaxation. Equipped with a specially designed roller system, which moves in a wavelike motion along your spine to effectively massage muscoes relieve aches and stiffness. Bliss Chair NR-90: Complete Relaxation from Top to toe. Full body massage with a unique reversible footrest, which gives you a choice of resting your legs, or treating your feet and calves to a stimulating massage. Apart from the above products we have a Reflexologist, i Twin, Foot Reivitalizer 2, Tappie (Handy Massager), Warm Air Turbo, eHuman-logic BPM, Pro Therapist, Massuer Chair, Hair Brush, Ear Scan, Health Sole, Eye Care Massager, Large Gel Pad, Samll Gel Pad, VF scan, e-Body fat Scale, Fever Band, Handy Neb, Ultrasonic Neb, Instant Heat Pad (small), Slim Belt (Aerobics), Slim Belt (Body Shaping), Slim Belt (back support), Slim Belt (Extra Support), Spare Wire, Upholstery for OS777, Music CD for OS777, I. Sense Upholstery for OS757 to add to the big range of products. Chapter 4 Research Methodology RESEARCH METHODOLOGY Methodology is the bone of a project. It has also an important place as regards to cash management system project. It helps us in Collection and analysis of data in preparing the project. My Research is purely a Descriptive Research, which includes understanding and analyzing Transfer Pricing and its different Method. My sources of collection of data must be very much reli able, so secondary data collection method is used for the purpose of the project for the Price Management System. I have gone very deeply in preparing the project & I devoted my full attention to get the accurate & real data collection. For this purpose I became in close contact with sources of data collection by personally & through Internet. The Methodology contains the following things:- †¢ Methods of Data Collection :- For the project report, methods of data collection has an important role in connection with accuracy & exact information. So, I adopted both the methods primary as well as secondary method of data collection. A) Primary Data : Throughout the preparation of the project report, I was in the contact of CFO & other staff of finance department of Paramount Surgimed Ltd. o get the information in connection with the practical working of transaction between the company & banks. B) Secondary Data: I have also collected the information, figures & data in connection with the preparation of project report from Balance-sheet & annual report of Paramount Surgimed Ltd. I have also colle cted the information about cash management, services & Latter of Credit provided by the bank to the company. Along with it I have collected information about the topic from the Internet and also form many of my friends and colleagues who have worked over on the similar kind of projects or who are having a good command over the subject. Sources of Data :- Sources of collection of data for a project report has a very