This article explains that current practical approaches to the pricing of intra-group financial guarantees attribute economic significance to group affiliation that diverges from common approaches and depends on a refined independence hypothesis that is not universally applied and risks suggesting uncertainties about the wider application of the arm’s length principle. Guidance has not assimilated recent revisions to the OECD guidance on control of risk, advocates complex and unsatisfactory valuation methods, and unconvincingly refers to implicit support that unhelpfully disguises active functions. With the benefit of revised guidance, circumstances similar to those in the General Electric case could be resolved differently. Intra-group financial guarantees epitomize the challenges faced when dealing under the arm’s length principle with how associated enterprises are capitalized. It is inappropriate to subject the arm’s length principle to the contortions and divergence described in this article when the guarantee derives from deliberate choices of the guarantor about how the subsidiary is capitalized. Treating creditworthiness within a multinational group as indivisible and collective is a practical solution, either on principled grounds or as a safe harbour, thereby eliminating the need to consider intra-group guarantee fees for transfer pricing purposes. Financial guarantees, transfer pricing, arm’s length principle, creditworthiness, implicit support
To meet the long-term technology and performance needs of the upstream industry, the present and future market must first be understood and then acted upon. A collaborative knowledge management (KM) system complements other market assessment tools by harnessing the collective capability and experience of an organization's employees to more effectively identify, communicate and act on customer needs, market knowledge and potential solutions. While many companies' KM efforts are focused on technical problem solving and/or employee development, a KM system can also be used to develop better organizational and individual understanding of, and more importantly, adaptation to the market. Any employee can initiate or participate in collaborative communication to actively share and discuss customer needs, competitor activities, new technology applications and successes. Any employee can submit ideas for new or improved products to meet their local market needs. Where appropriate, these ideas are collaboratively reviewed, improved and validated through KM. We use our KM system to better understand the market and drive innovation. Examples demonstrate the use of collaborative discussion to share market intelligence, clarify market assumptions, harness the 'wisdom of the crowd' in collecting and validating new product/service ideas and transfer technology. KM tools and collaborative activity show promising value in improving market understanding and driving technology innovation. Halliburton broadly defines knowledge management as a systematic approach to getting the right information to the right people at the right time. Often the 'right information' pertains to market needs, new ideas or new technology. Knowledge Management Effort Overview There are many definitions for knowledge management. Halliburton prefers "a systematic approach to getting the right information to the right person at the right time." This is an adaptation of the American Productivity & Quality Center's (APQC) definition: "A set of strategies and approaches to create, safeguard and use knowledge assets (including people and information), which allows knowledge to flow to the right people at the right time so they can apply these assets to create more value for the enterprise." The company's KM approach is centered on developing and supporting communities of practice that meet the needs of the organization. While providing access to common portal processes and tools, it is believed each community has unique needs and distinct business objectives. However for the purposes of this discussion, the precise definition of KM adopted by a company is not critical. What matters most is the level and type of collaboration among employees that a KM system enables. At the heart of these communities is the ability to communicate and collaborate around relevant topics. The collaboration tool enables anyone in the organization to:Ask a questionPush knowledge (best practice, idea, etc.) proactively to the communitySee the original question/issue and all replies in one placeReply with an answer or opinionLearn on demand by searching previous discussions and accessing managed content Issues involving one or more communities can be shared to increase collaboration and gain additional perspective. While these discussions typically involve technical or operational problem solving related to the communities, we see an increasing amount of collaboration occurring around planning, innovation and strategy. Dedicated knowledge brokers for each community provide full time administration to facilitate that community's KM effort.
fax 01-972-952-9435. AbstractTo meet the long-term technology and performance needs of the upstream industry, the present and future market must first be understood and then acted upon. A collaborative knowledge management (KM) system complements other market assessment tools by harnessing the collective capability and experience of an organization's employees to more effectively identify, communicate and act on customer needs, market knowledge and potential solutions.
To meet the challenges to the industry of increasing hydrocarbon demand, increasing well complexity, reduced employee experience levels and the large physical distances between operational centers, advances in digital technologies are being increasingly leveraged by both operator initiatives and service company initiatives such as Halliburton's Digital Asset. Terms such as "smart wells" and "real time" have become more commonplace. Data is being generated faster than ever. The ability to interpret this data, model the data and implement optimized solutions in real time is critical to operational success. The demands placed on operating in a cost efficient manner, with greater returns on investment are ever present.The use of a Knowledge Management collaboration tool, a key component of the Digital Asset, helps to meet these challenges by providing a real time collaborative environment which spans global operations, supports and develops synergies between multiple disciplines and transcends geographical and language barriers. Through its use an intentional shift in focus has taken place from centrally located sources of expertise to virtual ones. Virtual centers of collaboration empower users to collaborate, problem solve and share knowledge on demand. Any user, i.e. employee, can rapidly access the global expertise needed to put well challenges, potential solutions and increasing volumes of data and information in appropriate context. Through access to these extended resources employees can solve problems more efficiently and offer better solutions. Technical experts can cover more ground. Collaboration is facilitated by dedicated personnel who maintain a vital link with local, regional, and global technology leaders.Examples from Canada, where the use of this approach contributed to an HTHP well being saved, along with an estimated cost of $15 million, from China where urgent advice was delivered to a rig experiencing an underground blowout and from Brazil where global experts collaboratively contributed to solving a wellbore stability problem will demonstrate how real time collaborative solutions are developed and moved from the virtual to real world environment to improve operational service delivery to external clients in the global market place. Lessons learned, best practices and strategies employed to engage users in the use of this collaborative environment are outlined.
Simply retaining knowledge within an organization is not enough to ensure its survival unless talented employees are ready to leverage that knowledge. Changing demographics within the petroleum industry raises many concerns for the coming decade including the identification, development and retention of an organization's future leaders. An existing, advanced knowledge management (KM) community gives an organization's upper management a unique view into key employees' ability and willingness to solve technical problems, communicate, innovate, influence peers and lead group consensus. Disciplined review of collaborative efforts captures peer recognition and provides a more impartial means of generating a list of talented personnel who exhibit leadership qualities and technical ability. This informal list can be used to complement formal succession planning, generating a wider base of candidates and enhancing the selection process. Examples demonstrate how this application of KM identifies ‘natural thought leaders’, evaluates candidates for key positions, and develops succession plans for future leaders who will drive the direction of the organization. Introduction Knowledge management (KM) has been the subject of many industry papers and articles, but we suspect there are as many or more untold examples of failed implementation of KM efforts in corporations as there are successful implementations. In our observations, one primary reason for failed KM initiatives is the nearsightedness of companies to realize the additional benefits that can be derived from collaborative KM systems above and beyond providing a more efficient means for employees to solve problems. The papers depicting successes generally focus on using a KM system to develop better technical solutions, connect geographically or hierarchically disconnected experts, and improve processes, generating value chains and/or decreasing time to competence for newer employees. This paper looks at KM from an alternative perspective - using a KM system to identify, evaluate and develop emerging leaders. The industry's challenge of recruiting, developing and retaining a global workforce is well documented[1,2,3,4,5,6,7] and frequently discussed. Charts showing the age distribution of professional organizations such as SPE (Figure 1) are often used to illustrate that the majority of the industry population is approaching retirement age, and either an insufficient inflow of younger professionals is available and/or there is too little time to develop younger workers to fill the void left by outgoing personnel. These eventual retirees frequently are the most experienced, knowledgeable employees in the organization and will leave with irreplaceable expertise in the form of tacit or undocumented knowledge, unless there is a system in place that combines organizational ability to learn, retain key staff and make a knowledge-sharing culture a reality.[8]
TX 75083-3836, U.S.A., fax 01-972-952-9435. AbstractSimply retaining knowledge within an organization is not enough to ensure its survival unless talented employees are ready to leverage that knowledge. Changing demographics within the petroleum industry raises many concerns for the coming decade including the identification, development and retention of an organization's future leaders.An existing, advanced knowledge management (KM) community gives an organization's upper management a unique view into key employees' ability and willingness to solve technical problems, communicate, innovate, influence peers and lead group consensus. Disciplined review of collaborative efforts captures peer recognition and provides a more impartial means of generating a list of talented personnel who exhibit leadership qualities and technical ability. This informal list can be used to complement formal succession planning, generating a wider base of candidates and enhancing the selection process.Examples demonstrate how this application of KM identifies 'natural thought leaders', evaluates candidates for key positions, and develops succession plans for future leaders who will drive the direction of the organization.
The author discusses specific concerns about the efficacy of the application of transfer pricing rules to aspects of business models that have been addressed in the revisions to the Organisation for Economic Co-operation and Development (OECD) Transfer Pricing Guidelines contained in the 2015 base erosion and profit shifting (BEPS) Report, Aligning Transfer Pricing with Value Creation. Distinctions are made between business models and transfer pricing business models that risk constraining the business to convenient explanations. Transfer pricing business models involving transfer of contractual risk and of legal ownership of intangibles are examined. Finally, the author predicts interest in single entity cross-border business models and the need to develop consistent guidance on attribution of profits to permanent establishments.
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