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EN
The market of consumer goods requires nowadays quick response to customer needs. As a consequence, this is transferred to the time restrictions that the semi-finished product manufacturer must meet. Therefore the cost of manufacturing cannot determine how production processes are designed, and the main evaluation function of manufacturing processes is the response time to customers’ orders. One of the ideas for implementing this idea is the QRM (Quick Response Manufacturing) production organization system. The purpose of the research undertaken by the authors was to develop an innovative solution in the field of production structure, allowing for the implementation of the QRM concept in a Contract Manufacturer, which realizes its tasks according to engineering-to-order (ETO) system in conditions defined as High Mix, Low Volume, High Complexity. The object of the research was to select appropriate methods for grouping products assuming that certain operations will be carried out in traditional but well-organized technological and/or linear cells. The research was carried out in one of the largest producers of sheet metal components in Europe. Pre-completed groupings for data obtained from the company had indicated that – among the classical methods – the best results had been given by the following methods: King’s Algorithm (otherwise called: Binary Ordering, Rank Order Clustering), k-means, and Kohonen’s neural networks. The results of the tests and preliminary simulations based on the data from the company proved that the implementation of the QRM concept does not have to be associated with the absolute formation of multi-purpose cells. It turned out that the effect of reducing the response time to customer needs can be obtained by using hybrid structures that combine solutions characteristic of cellular systems with traditional systems such as a technological, linear, or mixed structure. However, this requires the application of technological solutions with the highest level of organization.
EN
Modern manufacturing entities often operate in capital groups, and their role is sometimes limited to the function of cost centers. From the legal point of view, however, they are separate entities obliged to apply transfer pricing regulations. Meeting the requirements of the arm's length principle can be very difficult at this time, given the relationships and conflicts of interest in the capital group. Complexity increases in capital groups operating in different countries, due to differences in tax regulations. The main purpose of the paper is to demonstrate that the need to valuate the sale of finished goods to a manufacturing entity, which is a subject to a different tax jurisdiction, may lead to a problem of compliance with the arm's length principle. In addition, the paper proposes a methodology for comparability analysis that may be used by manufacturing entities to defend conditions of setting transfer pricing. The paper presents the different functional profiles of manufacturing entities and points out the difficulties that they may encounter when preparing the comparability analysis. It has also been noted that there are differences in transfer pricing regulations in different countries, for example by analyzing Polish and Czech regulations. The lack of uniform benchmarking legislation can cause inconsistencies in the selection of comparable data, resulting in differences in transfer pricing. The paper uses the method of legal regulation review and analysis of results of published studies concerning the scope of transfer pricing and comparability analysis. The paper also adopts a case study analysis.
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