Search results for: Transfer Pricing

Authors: Jasminka Radolović

Abstract:

Countries in recession, among them Croatia, have lower tax revenues as a result of unfavorable economic situation, which is decrease of the economic activities and unemployment. The global tax base has decreased. In order to create larger state revenues, states use the institute of tax authorities. By controlling transfer pricing in the international companies and using certain techniques, tax authorities can create greater tax obligations for the companies in a short period of time.

Keywords: Documentation, Methods, Tax Optimization, Transfer Pricing

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Authors: Tomáš Brabenec

Abstract:

Cost contribution arrangements (CCAs) and Cost sharing agreements (CCAs) belong to the tools of modern finance management. Costs spend by associated enterprises on developing producing or obtaining assets, services or rights (in general - benefits) are used for tax optimizing too. The main purpose of joint research and development, producing or obtaining benefits is to lower these costs as much as possible or to maximize the benefits. In this article is mentioned the problematic of transfer pricing and arm's length principle with connection of CCAs, CSAs. Next, there is mentioned how to settle participation shares of the total cost and benefits contributions with respect to the OECD Transfer pricing for MNEs Guidelines and with respect to other significant regulations.

Keywords: Arm's length principle, Cost contribution arrangements, Cost sharing agreements, Reasonable anticipated benefits, Relevant costs, Transfer prices.

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Authors: Yi-Chang Chen, Shan-Lin Chang, Chia-Chun Wu

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Unlike this study focused extensively on trading behavior of option market, those researches were just taken their attention to model-driven option pricing. For example, Black-Scholes (B-S) model is one of the most famous option pricing models. However, the arguments of B-S model are previously mentioned by some pricing models reviewing. This paper following suggests the importance of the dynamic character for option pricing, which is also the reason why using the genetic algorithm (GA). Because of its natural selection and species evolution, this study proposed a hybrid model, the Genetic-BS model which combining GA and B-S to estimate the price more accurate. As for the final experiments, the result shows that the output estimated price with lower MAE value than the calculated price by either B-S model or its enhanced one, Gram-Charlier garch (G-C garch) model. Finally, this work would conclude that the Genetic-BS pricing model is exactly practical.

Keywords: genetic algorithm, Genetic-BS, option pricing model.

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Authors: Mimi Hafizah Abdullah, Hanani Farhah Harun, Nik Ruzni Nik Idris

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With the implied volatility as an important factor in financial decision-making, in particular in option pricing valuation, and also the given fact that the pricing biases of Leland option pricing models and the implied volatility structure for the options are related, this study considers examining the implied adjusted volatility smile patterns and term structures in the S&P/ASX 200 index options using the different Leland option pricing models. The examination of the implied adjusted volatility smiles and term structures in the Australian index options market covers the global financial crisis in the mid-2007. The implied adjusted volatility was found to escalate approximately triple the rate prior the crisis.

Keywords: Implied adjusted volatility, Financial crisis, Leland option pricing models.

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Authors: J. Zambujal-Oliveira

Abstract:

The relation between taxation states and foreign direct investment has been studied for several perspectives and with states of different levels of development. Usually it's only considered the impact of tax level on the foreign direct investment volume. This paper enhances this view by assuming that multinationals companies (MNC) can use transfer prices systems and have got investment timing flexibility. Thus, it evaluates the impact of the use of international transfer pricing systems on the states- policy and on the investment timing of the multinational companies. In uncertain business environments (with periodical release of news), the investment can increase if MNC detain investment delay options. This paper shows how tax differentials can attract foreign direct investments (FDI) and influence MNC behavior. The equilibrium is set in a global environment where MNC can shift their profits between states depending on the corporate tax rates. Assuming the use of transfer pricing schemes, this paper confirms the relationship between MNC behavior and the release of new business news.

Keywords: Corporate Taxation, International Profit Shifting, Real Options

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Authors: Anthony E. Ohazulike, Georg Still, Walter Kern, Eric C. van Berkum

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A road pricing game is a game where various stakeholders and/or regions with different (and usually conflicting) objectives compete for toll setting in a given transportation network to satisfy their individual objectives. We investigate some classical game theoretical solution concepts for the road pricing game. We establish results for the road pricing game so that stakeholders and/or regions playing such a game will beforehand know what is obtainable. This will save time and argument, and above all, get rid of the feelings of unfairness among the competing actors and road users. Among the classical solution concepts we investigate is Nash equilibrium. In particular, we show that no pure Nash equilibrium exists among the actors, and further illustrate that even “mixed Nash equilibrium" may not be achievable in the road pricing game. The paper also demonstrates the type of coalitions that are not only reachable, but also stable and profitable for the actors involved.

Keywords: Road pricing game, Equilibrium problem with equilibrium constraint (EPEC), Nash equilibrium, Game stability.

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Authors: Christopher Reichstein, Ralf-Christian Härting, Martina Häußler

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With a continuously increasing speed of information exchange on the World Wide Web, retailers in the E-Commerce sector are faced with immense possibilities regarding different online purchase processes like dynamic price settings. By use of Dynamic Pricing, retailers are able to set short time price changes in order to optimize producer surplus. The empirical research illustrates the basics of Dynamic Pricing and identifies six influencing factors of Dynamic Pricing. The results of a structural equation modeling approach show five main drivers increasing the potential of dynamic price settings in the E-Commerce. Influencing factors are the knowledge of customers’ individual willingness to pay, rising sales, the possibility of customization, the data volume and the information about competitors’ pricing strategy.

Keywords: E-commerce, empirical research, experts, Dynamic Pricing (DP), influencing factors, potentials.

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Authors: Chei-Chang Chiou, Sen-Wei Wang, Yu-Min Wang

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The purpose of this study is to investigate the relationship between corporate governance and pricing for initial public offerings (IPOs). Empirical result finds that the prediction of pricing of IPOs with corporate governance added can have a rather higher degree of predicting accuracy than that of non governance added during the training and testing samples. Therefore, it can be observed that corporate governance mechanism can affect the pricing of IPOs

Keywords: Artificial neural networks, corporate governance, initial public offerings.

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Authors: Mohammad Modarres, Shirin Aslani

Abstract:

The goal of this paper is to develop a model to integrate “pricing" and “advertisement" for short life cycle products, such as branded fashion clothing products. To achieve this goal, we apply the concept of “Dynamic Pricing". There are two classes of advertisements, for the brand (regardless of product) and for a particular product. Advertising the brand affects the demand and price of all the products. Thus, the model considers all these products in relation with each other. We develop two different methods to integrate both types of advertisement and pricing. The first model is developed within the framework of dynamic programming. However, due to the complexity of the model, this method cannot be applicable for large size problems. Therefore, we develop another method, called hieratical approach, which is capable of handling the real world problems. Finally, we show the accuracy of this method, both theoretically and also by simulation.

Keywords: Advertising, Dynamic programming, Dynamic pricing, Promotion.

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Authors: Saeed Sayyad Hagh Shomar

Abstract:

Traffic congestion pricing – as a strategy in travel demand management in urban areas to reduce traffic congestion, air pollution and noise pollution – has drawn many attentions towards itself. Unlike the satisfying findings in this method, there are still problems in determining the best functional congestion pricing scheme with regard to the situation. The so-called problems in this process will result in further complications and even the scheme failure. That is why having proper knowledge of the significance of congestion pricing schemes and the effective factors in choosing them can lead to the success of this strategy. In this study, first, a variety of traffic congestion pricing schemes and their components are introduced; then, their functional usage is discussed. Next, by analyzing and comparing the barriers, limitations and advantages, the selection criteria of pricing schemes are described. The results, accordingly, show that the selection of the best scheme depends on various parameters. Finally, based on examining the effective parameters, it is concluded that the implementation of area-based schemes (cordon and zonal) has been more successful in non-diversion of traffic. That is considering the topology of the cities and the fact that traffic congestion is often created in the city centers, area-based schemes would be notably functional and appropriate.

Keywords: Congestion pricing, demand management, flat toll, variable toll.

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Authors: Changhong Guo, Shaomei Fang, Yong He

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In this paper, fractional Black-Scholes models for the European option pricing were established based on the fractional G-Brownian motion (fGBm), which generalizes the concepts of the classical Brownian motion, fractional Brownian motion and the G-Brownian motion, and that can be used to be a tool for considering the long range dependence and uncertain volatility for the financial markets simultaneously. A generalized fractional Black-Scholes equation (FBSE) was derived by using the Taylor’s series of fractional order and the theory of absence of arbitrage. Finally, some explicit option pricing formulas for the European call option and put option under the FBSE were also solved, which extended the classical option pricing formulas given by F. Black and M. Scholes.

Keywords: European option pricing, fractional Black-Scholes equations, fractional G-Brownian motion, Taylor’s series of fractional order, uncertain volatility.

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Authors: Hsuan-Ku Liu

Abstract:

In this paper, the American exchange option (AEO) valuation problem is modelled as a free boundary problem. The critical stock price for an AEO is satisfied an integral equation implicitly. When the remaining time is large enough, an asymptotic formula is provided for pricing an AEO. The numerical results reveal that our asymptotic pricing formula is robust and accurate for the long-term AEO.

Keywords: Integral equation, asymptotic solution, free boundary problem, American exchange option.

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Authors: Elif Alaybeyoğlu, Y. Esra Albayrak

Abstract:

Marketing establishes a communication network between producers and consumers. Nowadays, marketing approach is customer-focused and products are directly oriented to meet customer needs. Marketing, which is a long process, needs organization and management. Therefore strategic marketing planning becomes more and more important in today’s competitive conditions. Main focus of this paper is to evaluate pricing strategies and select the best pricing strategy solution while considering internal and external factors influencing the company’s pricing decisions associated with new product development. To reflect the decision maker’s subjective preference information and to determine the weight vector of factors (attributes), the fuzzy linear programming technique for multidimensional analysis of preference (LINMAP) under intuitionistic fuzzy (IF) environments is used.

Keywords: IF Sets, LINMAP, MAGDM, Marketing.

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Authors: Teh Raihana Nazirah Roslan, Siti Zulaiha Ibrahim, Sharmila Karim

Abstract:

A warrant is a financial contract that confers the right but not the obligation, to buy or sell a security at a certain price before expiration. The standard procedure to value equity warrants using call option pricing models such as the Black–Scholes model had been proven to contain many flaws, such as the assumption of constant interest rate and constant volatility. In fact, existing alternative models were found focusing more on demonstrating techniques for pricing, rather than empirical testing. Therefore, a mathematical model for pricing and analyzing equity warrants which comprises stochastic interest rate and stochastic volatility is essential to incorporate the dynamic relationships between the identified variables and illustrate the real market. Here, the aim is to develop dynamic pricing formulations for hybrid equity warrants by incorporating stochastic interest rates from the Cox-Ingersoll-Ross (CIR) model, along with stochastic volatility from the Heston model. The development of the model involves the derivations of stochastic differential equations that govern the model dynamics. The resulting equations which involve Cauchy problem and heat equations are then solved using partial differential equation approaches. The analytical pricing formulas obtained in this study comply with the form of analytical expressions embedded in the Black-Scholes model and other existing pricing models for equity warrants. This facilitates the practicality of this proposed formula for comparison purposes and further empirical study.

Keywords: Cox-Ingersoll-Ross model, equity warrants, Heston model, hybrid models, stochastic.

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Authors: M. Oloomi-Buygi, M. Reza Salehizadeh

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In this paper a new approach for transmission pricing is presented. The main idea is voltage angle allocation, i.e. determining the contribution of each contract on the voltage angle of each bus. DC power flow is used to compute a primary solution for angle decomposition. To consider the impacts of system non-linearity on angle decomposition, the primary solution is corrected in different iterations of decoupled Newton-Raphson power flow. Then, the contribution of each contract on power flow of each transmission line is computed based on angle decomposition. Contract-related flows are used as a measure for “extent of use" of transmission network capacity and consequently transmission pricing. The presented approach is applied to a 4-bus test system and IEEE 30-bus test system.

Keywords: Deregulation, Power electric markets, Transmission pricing methodologies, decoupled Newton-Raphson power flow.

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Authors: Salah Alrabeei, Mohammad Yousuf

Abstract:

The goal of option pricing theory is to help the investors to manage their money, enhance returns and control their financial future by theoretically valuing their options. Modeling option pricing by Black-School models with jumps guarantees to consider the market movement. However, only numerical methods can solve this model. Furthermore, not all the numerical methods are efficient to solve these models because they have nonsmoothing payoffs or discontinuous derivatives at the exercise price. In this paper, the exponential time differencing (ETD) method is applied for solving partial integrodifferential equations arising in pricing European options under Merton’s and Kou’s jump-diffusion models. Fast Fourier Transform (FFT) algorithm is used as a matrix-vector multiplication solver, which reduces the complexity from O(M2) into O(M logM). A partial fraction form of Pad`e schemes is used to overcome the complexity of inverting polynomial of matrices. These two tools guarantee to get efficient and accurate numerical solutions. We construct a parallel and easy to implement a version of the numerical scheme. Numerical experiments are given to show how fast and accurate is our scheme.

Keywords: Integral differential equations, L-stable methods, pricing European options, Jump–diffusion model.

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Authors: Ashish Saini, A.K. Saxena

Abstract:

In competitive electricity markets all over the world, an adoption of suitable transmission pricing model is a problem as transmission segment still operates as a monopoly. Transmission pricing is an important tool to promote investment for various transmission services in order to provide economic, secure and reliable electricity to bulk and retail customers. The nodal pricing based on SRMC (Short Run Marginal Cost) is found extremely useful by researchers for sending correct economic signals. The marginal prices must be determined as a part of solution to optimization problem i.e. to maximize the social welfare. The need to maximize the social welfare subject to number of system operational constraints is a major challenge from computation and societal point of views. The purpose of this paper is to present a nodal transmission pricing model based on SRMC by developing new mathematical expressions of real and reactive power marginal prices using GA-Fuzzy based optimal power flow framework. The impacts of selecting different social welfare functions on power marginal prices are analyzed and verified with results reported in literature. Network revenues for two different power systems are determined using expressions derived for real and reactive power marginal prices in this paper.

Keywords: Deregulation, electricity markets, nodal pricing, social welfare function, short run marginal cost.

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Authors: Ali Safdari-Vaighani

Abstract:

Pricing financial contracts on several underlying assets received more and more interest as a demand for complex derivatives. The option pricing under asset price involving jump diffusion processes leads to the partial integral differential equation (PIDEs), which is an extension of the Black-Scholes PDE with a new integral term. The aim of this paper is to show how basket option prices in the jump diffusion models, mainly on the Merton model, can be computed using RBF based approximation methods. For a test problem, the RBF-PU method is applied for numerical solution of partial integral differential equation arising from the two-asset European vanilla put options. The numerical result shows the accuracy and efficiency of the presented method.

Keywords: Radial basis function, basket option, jump diffusion, RBF-PUM.

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Authors: Saeed Sayyad Hagh Shomar

Abstract:

Traffic congestion pricing in urban streets is one of the most suitable options for solving the traffic problems and environment pollutions in the cities of the country. Unlike its acceptable outcomes, there are problems concerning the necessity to pay by the mass. Regarding the fact that public response in order to succeed in this strategy is so influential, studying their response and behavior to get the feedback and improve the strategies is of great importance. In this study, a questionnaire was used to examine the public reactions to the traffic congestion pricing schemes at the center of Tehran metropolis and the factors involved in people’s decision making in accepting or rejecting the congestion pricing schemes were assessed based on the data obtained from the questionnaire as well as the international experiences. Then, by analyzing and comparing the schemes, guidelines to reduce public objections to them are discussed. The results of reviewing and evaluating the public reactions show that all the pros and cons must be considered to guarantee the success of these projects. Consequently, with targeted public education and consciousness-raising advertisements, prior to initiating a scheme and ensuring the mechanism of the implementation after the start of the project, the initial opposition is reduced and, with the gradual emergence of the real and tangible benefits of its implementation, users’ satisfaction will increase.

Keywords: Demand management, international experiences, traffic congestion pricing, public acceptance, public objection.

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Authors: Siliang Wang, Minghui Wang

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This work proposes a novel market-based air traffic flow control model considering competitive airlines in air traffic network. In the flow model, an agent based framework for resources (link/time pair) pricing is described. Resource agent and auctioneer for groups of resources are also introduced to simulate the flow management in Air Traffic Control (ATC). Secondly, the distributed group pricing algorithm is introduced, which efficiently reflect the competitive nature of the airline industry. Resources in the system are grouped according to the degree of interaction, and each auctioneer adjust s the price of one group of resources respectively until the excess demand of resources becomes zero when the demand and supply of resources of the system changes. Numerical simulation results show the feasibility of solving the air traffic flow control problem using market mechanism and pricing algorithms on the air traffic network.

Keywords: Air traffic control, Nonlinear programming, Marketmechanism, Route policy.

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Authors: Mansour A. Al Qubeissi

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The current paper presents a numerical approach in solving the conjugate heat transfer problems. A heat conduction code is coupled internally with a computational fluid dynamics solver for developing a couple conjugate heat transfer solver. Methodology of treating non-matching meshes at interface has also been proposed. The validation results of 1D and 2D cases for the developed conjugate heat transfer code have shown close agreement with the solutions given by analysis.

Keywords: Computational Fluid Dynamics, Conjugate Heat transfer, Heat Conduction, Heat Transfer

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Authors: José Carlos Rodríguez, Mario Gómez

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The aim of this paper is to get insight on the nature of university-industry technology transfer (UITT) and technology transfer offices (TTOs) activity at universities in the case of emerging economies. In relation to the process of transferring knowledge/technology in the case of emerging economies, knowledge/technology transfer in these economies are more reactive than in developed economies due to differences in maturity of technologies. It is assumed in this paper that knowledge/technology transfer is a complex phenomenon, and thus the paper contributes to get insight on the nature of UITT and TTOs creation in the case of emerging economies by using a system dynamics model of knowledge/technology transfer in these countries. The paper recognizes the differences between industrialized countries and emerging economies on these phenomena.

Keywords: University-industry technology transfer, technology transfer offices, technology transfer models, emerging economies.

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Authors: M. Kito, M. Takezaki, T. Shakouchi, K. Tsujimoto, T. Ando

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Impinging jets are widely used in industrial cooling systems for their high heat transfer characteristics at stagnation points. However, the heat transfer characteristics are low in the downstream direction. In order to improve the heat transfer coefficient further downstream, investigations introducing ribs on jet-cooled flat plates have been conducted. Most studies regarding the heat-transfer enhancement using a rib-roughened wall have dealt with the rib pitch. In this paper, we focused on the rib spacing and demonstrated that the rib spacing must be more than 6 times the nozzle width to improve heat transfer at Reynolds number Re=5.0×103 because it is necessary to have enough space to allow reattachment of flow behind the first rib.

Keywords: Forced convection, heat transfer, impinging jet cooling, rib roughened wall

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Authors: G. Schuh, S. Aghassi

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In order to bridge the gap between research and industry, promoting technology and knowledge transfer becomes increasingly important. Especially small- and medium-sized enterprises, having only little R&D resources themselves, depend on external technology development activities for remaining innovative. Academia research on the other hand needs potential industrial partners, who are capable and willing to commercialize their technologies as most public funding programs require some sort of technology transfer or dissemination activities. Modern web technologies offer more and more “social” functionalities and open up new ways of user interaction. In the past years several technology transfer platforms were developed, making use of modern web technologies in order to enable and support technology transfer. In this paper we report on the results of a state-of-the art analyses of existing technology transfer platforms, point out their advantages and deficits and give a perspective to the development of an improved technology transfer platform.

Keywords: Knowledge transfer, social software, technology management, technology transfer.

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Authors: Daniela Elena Marinescu, Ioana Manafi, Dumitru Marin

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We consider a Principal-Agent model with the Principal being a seller who does not know perfectly how much the buyer (the Agent) is willing to pay for the good. The buyer-s preferences are hence his private information. The model corresponds to the nonlinear pricing problem of Maskin and Riley. We assume there are three types of Agents. The model is solved using “informational rents" as variables. In the last section we present the main characteristics of the optimal contracts in asymmetric information and some possible extensions of the model.

Keywords: Adverse selection, asymmetric information, informational rent, nonlinear pricing, optimal contract

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Authors: Zeynep İltüzer Samur, Gül Tekin Temur

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Due to the increasing and varying risks that economic units face with, derivative instruments gain substantial importance, and trading volumes of derivatives have reached very significant level. Parallel with these high trading volumes, researchers have developed many different models. Some are parametric, some are nonparametric. In this study, the aim is to analyse the success of artificial neural network in pricing of options with S&P 100 index options data. Generally, the previous studies cover the data of European type call options. This study includes not only European call option but also American call and put options and European put options. Three data sets are used to perform three different ANN models. One only includes data that are directly observed from the economic environment, i.e. strike price, spot price, interest rate, maturity, type of the contract. The others include an extra input that is not an observable data but a parameter, i.e. volatility. With these detail data, the performance of ANN in put/call dimension, American/European dimension, moneyness dimension is analyzed and whether the contribution of the volatility in neural network analysis make improvement in prediction performance or not is examined. The most striking results revealed by the study is that ANN shows better performance when pricing call options compared to put options; and the use of volatility parameter as an input does not improve the performance.

Keywords: Option Pricing, Neural Network, S&P 100 Index, American/European options

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Authors: Hyung-Nam Kim, Won-Yong Chae, Dong-Sul Shin, Ho-Sung Kim, Hee-Je Kim

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A wireless power transfer system can attribute to the fields in robot, aviation and space in which lightening the weight of device and improving the movement play an important role. A wireless power transfer system was investigated to overcome the inconvenience of using power cable. Especially a wireless power transfer technology is important element for mobile robots. We proposed the wireless power transfer system of the half-bridge resonant converter with the frequency tracking and optimized power transfer control unit. And the possibility of the application and development system was verified through the experiment with LED loads.

Keywords: Wireless Power Transmission (WPT), resonancefrequency, protection circuit. LED.

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Authors: P.Kumar

Abstract:

Fluids are used for heat transfer in many engineering equipments. Water, ethylene glycol and propylene glycol are some of the common heat transfer fluids. Over the years, in an attempt to reduce the size of the equipment and/or efficiency of the process, various techniques have been employed to improve the heat transfer rate of these fluids. Surface modification, use of inserts and increased fluid velocity are some examples of heat transfer enhancement techniques. Addition of milli or micro sized particles to the heat transfer fluid is another way of improving heat transfer rate. Though this looks simple, this method has practical problems such as high pressure loss, clogging and erosion of the material of construction. These problems can be overcome by using nanofluids, which is a dispersion of nanosized particles in a base fluid. Nanoparticles increase the thermal conductivity of the base fluid manifold which in turn increases the heat transfer rate. In this work, the heat transfer enhancement using aluminium oxide nanofluid has been studied by computational fluid dynamic modeling of the nanofluid flow adopting the single phase approach.

Keywords: Heat transfer intensification, nanofluid, CFD, friction factor

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Authors: Salah Alrabeei, Mohammad Yousuf

Abstract:

The goal of option pricing theory is to help the investors to manage their money, enhance returns and control their financial future by theoretically valuing their options. However, most of the option pricing models have no analytical solution. Furthermore, not all the numerical methods are efficient to solve these models because they have nonsmoothing payoffs or discontinuous derivatives at the exercise price. In this paper, we solve the American option under jump diffusion models by using efficient time-dependent numerical methods. several techniques are integrated to reduced the overcome the computational complexity. Fast Fourier Transform (FFT) algorithm is used as a matrix-vector multiplication solver, which reduces the complexity from O(M2) into O(M logM). Partial fraction decomposition technique is applied to rational approximation schemes to overcome the complexity of inverting polynomial of matrices. The proposed method is easy to implement on serial or parallel versions. Numerical results are presented to prove the accuracy and efficiency of the proposed method.

Keywords: Integral differential equations, American options, jump–diffusion model, rational approximation.

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Authors: Yoke-Mui Lim, Yahaya Ahmad

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Conservation works in Malaysia that is procured by public organisation usually follow the traditional approach where the works are tendered based on Bills of Quantities (BQ). One of the purposes of tendering is to enable the selection of a competent contractor that offers a competitive price. While competency of the contractors are assessed by their technical knowledge, experience and track records, the assessment of pricing will be dependent on the tender amount. However, the issue currently faced by the conservation works sector is the difficulty in assessing the competitiveness and reasonableness of the tender amount due to the high variance between the tenders amount. Thus, this paper discusses the factors that cause difficulty to the tenderers in pricing competitively in a bidding exercise for conservation tenders. Data on tendering is collected from interviews with conservation works contractors to gain in-depth understanding of the barriers faced in pricing tenders of conservation works. Findings from the study lent support to the contention that the variance of tender amount is very high amongst tenderers. The factors identified in the survey are the format of BQ, hidden works, experience and labour and material costs.

Keywords: Building Conservation, Malaysia, Bill of Quantities, Tender.

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