Jane Frecknall Hughes

Corporate Strategy Formulation and Taxation: Evidence from UK Firms*

This paper considers the relationship between corporate strategy formulation and taxation. Drawing on prior literature we briefly review the important influence that international taxation has on an array of corporate strategy decisions. We then consider issues in strategy formulation and taxation planning in order to develop an understanding of when and how taxation factors impinge on strategic decision-making. We draw out the apparent paradox between the nature of strategic decision-making and financial decision-making and look for areas of reconciliation. In order to shed light on some of these issues we present findings from the qualitative analysis of a set of personal interviews undertaken with senior tax practitioners in seven UK-based multinational enterprises and then consider quantitative responses from the tax practitioners working in 145 UK firms.

Electronic Commerce and International Taxation:: A Square Peg in a Round Hole?

This paper examines the concept of the electronic commerce company (e-company) from a tax strategy perspective. E-company development is examined alongside traditional models of company growth and global expansion. The e-company is potentially multinational from genesis, operating without geographical constraints or even a physical presence. When transactions are grounded in different tax jurisdictions, however, this business form conflicts with regulations designed to deal with other forms of business. The paper considers whether this conflict can be resolved by integrating tax strategy more fully into e-company business operations to ensure conformity with existing tax regulations, or whether the new form needs new regulations.

King John's Tax Innovations - Extortion, Resistance, and the Establishment of the Principle of Taxation by Consent

The purpose of this paper is to present a re-evaluation of the reign of Englands King John (1199–1216) from a fiscal perspective. The paper seeks to explain Johns innovations in terms of widening the scope and severity of tax assessment and revenue collection. In particular, the paper seeks to highlight the significance of Hubert Walter as the kings financial adviser. He exercised a moderating influence in the first half of Johns reign and was the guiding hand in the successful introduction of innovative measures designed to increase revenues. These became extreme after his death in 1205, when John lacked his counsel. It is further suggested that the Magna Carta was a direct reaction to such financial severity. Many of the clauses in Magna Carta refer specifically to Johns tax innovations and severity. Linked to this, the paper argues that these events were critical to the establishment of the principle of taxation by consent. As a result of the innovative and extreme nature of Johns fiscal measures...

Transfer pricing and economic functions analysis: the Japanese paradigm

This paper examines the difficulties facing tax authorities in valuing cross-border flows from a transactions based analysis, in conditions where intangibles and services are important and where the multinational firm concerned is operating a system in which group-wide economic functions dominate decision making. Its key contention is that the economic functions of any entity should be examined in order to determine whether transactions analysis can be used to produce an acceptable value. This is done in the particular context of Japanese multinational enterprises and uses two hypothetical situations to demonstrate the inadequacy of transactions based analysis as a panacea for transfer pricing problems, especially for transfers of value involving intangibles and services, which it redefines into two categories, perceptible and imperceptible.

Incentives to Transfer Profits: a Japanese Perspective

This paper forms one of a series examining aspects of transfer pricing from a Japanese perspective. In earlier work the authors examined prevalent allegations that global companies, especially Japanese multinationals, operated transfer pricing policies to the deliberate disadvantage of host countries by artificially locating profits in jurisdictions where a tax advantage could be obtained. There would appear to be considerable evidence to suggest that obtaining a tax advantage is not the primary reason for adopting any particular transfer pricing policy. This is especially true in the case of certain Japanese companies, the transfer pricing policies of which result in effective transfers of profits back to their home base in Japan, where tax rates are relatively high. In earlier work it was initially suggested that this homeward transfer of profits was a consequence of following different costing principles and operating within a different business culture. This paper will explore further these reasons and attempt to analyse why such companies actively seek to undertake foreign direct investment, yet do not exploit transfer pricing opportunities in ways which have been open to them.

The impact of surgery for vulval cancer upon health-related quality of life and pelvic floor outcomes during the first year of treatment: a longitudinal, mixed methods study.

To measure the long‐term impact of surgical treatment for vulval cancer upon health‐related quality of life and pelvic floor outcomes during the first year of therapy.