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The concept of associated persons as a key and potentially problematic aspect in transfer pricing 关联人的概念是转让定价中的一个关键和潜在的问题
Pub Date : 2023-03-01 DOI: 10.2478/fiqf-2023-0003
K. Brychta, Matheus Chebli de Abreu, J. Hudenko, Lucas Scheremetta Santos, Lucas Poubel
Abstract Transfer pricing (TP) is based on many principles – the essential one is the Arm´s Length Principle (ALP). In this respect, the term “associated persons” is of crucial importance: associated persons must be involved in transactions in order for the ALP to be applied. The aim of the paper is to contribute to existing comparative analysis of TP rules – specifically, to provide a critical analysis of the term “associated persons” as prescribed by domestic law in Brazil, the Czech Republic, and Latvia. The key goals of the research conducted were to provide a comprehensive picture of the variety of definitions, to indicate relationships between international law and domestic law, and last, but not least, to highlight various concepts of the term “associated persons” and to identify problematic aspects connected with the interpretation of the definitions and the applications of the related rules. The study, which is based on qualitative research, is exploratory and interpretative in its nature. Its results present a background for further research and point to the fragmentation of law on TP with respect to the investigated issue. On the basis of the results of the comparative study one can conclude significant differences among, and fragmentation in, the definitions of the term “associated persons” both in respect of the number of categories established and in respect of the absence of the autonomy of the definitions of the term “associated persons” as provided by public law (especially by income tax acts). At the same time one can conclude the same position regarding the application of double tax treaties in all the countries for which the study was carried out.
摘要转让定价是建立在许多原则的基础上的,其中最基本的是公平原则。在这方面,“有关联的人”一词至关重要:有关联的人必须参与交易,才能适用公平竞争法。本文的目的是对现有的税收抵销规则进行比较分析,特别是对巴西、捷克共和国和拉脱维亚的国内法规定的“关联人”一词进行批判性分析。所进行的研究的主要目标是提供各种定义的全面情况,指出国际法和国内法之间的关系,最后但并非最不重要的是,突出“有关人士”一词的各种概念,并查明与解释定义和适用有关规则有关的问题方面。本研究以质性研究为基础,具有探索性和解释性。其结果为进一步研究提供了背景,并指出就所调查的问题而言,TP法律的碎片化。在比较研究结果的基础上,人们可以得出结论,在“关联人”一词的定义之间存在显著差异和分裂,这两个方面是既定类别的数量,以及公法(特别是所得税法)规定的“关联人”一词的定义缺乏自主性。与此同时,我们可以得出结论,对于在进行这项研究的所有国家中适用双重征税条约的问题,我们持同样的立场。
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引用次数: 0
Forex market as the best possible way of investing money during an economic boom and recession 在经济繁荣和衰退期间,外汇市场是最好的投资方式
Pub Date : 2023-03-01 DOI: 10.2478/fiqf-2023-0002
Wojciech Zembura
Abstract Since the beginning of the 1980s, a continuous process of integration of national and regional markets into one global market for goods, services and capital can be noticed. Both economic theory and market practice indicate that the level of the exchange rate primarily depends on macroeconomic variables (such as interest rates or the number of new jobs in the non-agricultural sector). The results of the research presented in the article regard the importance of US macroeconomic data publications for the short-term volatility of EUR/USD exchange rate. The main purpose of the study was to show whether macroeconomic data from the United States affects the short-term development of the EUR/USD exchange rate and whether the Forex market is a good way to multiply capital. The following research questions have been posed: does the EUR/USD exchange rate react to the published macroeconomic data from the American economy? Second, is whether investing in the Forex market could be a way to multiply capital in times of economic boom and recession. This paper presents the effects of my own research and observations in terms of the impact of US macroeconomic data, on shaping exchange rates of the Forex market. Based on my own investment experience my goal is to prove, that Forex market is a perfect way to multiply capital. My investment decisions regarding future exchange rate fluctuations, were based on the presented macroeconomic data from the US economy, as well as on the basis of important leading economic indicators. The position was opened and closed on the same day. The trading contracts have been made throughout 7 working days. The underlying financial instruments were EUR/USD and OIL. The conclusions of this study are as follows. The USD/PLN exchange rate reacted to the published macroeconomic data from USA. The strongest exchange rate reaction was noticed after publications of data regarding US Non-farm Payrolls (NFP), Initial Jobless Claims and ISM Services PMI. Strong exchange rate reaction was recorded after ADP US Private Sector Jobs and Factory orders report. When taking described investment examples into account, it can be clearly stated that investing in the Forex market is an excellent alternative to stock investments.
自20世纪80年代初以来,可以注意到国家和区域市场不断整合为一个全球商品、服务和资本市场的过程。经济理论和市场实践都表明,汇率水平主要取决于宏观经济变量(如利率或非农业部门的新就业人数)。本文提出的研究结果考虑了美国宏观经济数据出版物对欧元/美元汇率短期波动的重要性。研究的主要目的是为了证明来自美国的宏观经济数据是否会影响欧元/美元汇率的短期发展,以及外汇市场是否是资本倍增的好方法。研究人员提出了以下问题:欧元兑美元汇率是否会对公布的美国经济宏观经济数据做出反应?其次,在经济繁荣和衰退时期,投资外汇市场是否可以成为一种使资本倍增的方式。本文介绍了我自己的研究和观察对美国宏观经济数据影响的影响,对外汇市场汇率的影响。根据我自己的投资经验,我的目标是证明,外汇市场是一个完美的方式来增加资本。我对未来汇率波动的投资决策是基于美国经济的宏观经济数据,以及重要的领先经济指标。该头寸在同一天开仓和平仓。交易合同在7个工作日内完成。基础金融工具是欧元兑美元和石油。本研究的结论如下:美元兑兹罗提汇率对美国公布的宏观经济数据做出了反应。在美国非农就业数据(NFP)、首次申请失业救济人数和ISM服务业PMI数据公布后,人们注意到汇率反应最为强烈。ADP美国私营部门就业和工厂订单报告公布后,汇率反应强劲。当考虑到所描述的投资例子时,可以清楚地说明,投资外汇市场是股票投资的绝佳选择。
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引用次数: 0
Cryptocurrency as a method of payment in the tourism sector 加密货币作为旅游部门的一种支付方式
Pub Date : 2023-03-01 DOI: 10.2478/fiqf-2023-0006
Azamat Aiazbekov
Abstract The purpose of this study is to look into the capability of cryptocurrencies as a viable alternative to traditional payment methods in the travel and tourism industry. Given the increasing popularity of digital currencies, the tourism industry must consider alternative payment methods. The study's goal is to determine whether cryptocurrencies can be a safe and practical payment option for the travel and tourism industry. The benefits and drawbacks of cryptocurrency adoption in the travel and tourism industry were examined using a case study method. The study focused on customer preferences, security, and regulatory compliance. In-depth research was conducted on a select group of companies that have already implemented cryptocurrency as a payment option, as well as on interviews of business leaders. According to the study's findings, there is a high demand for the adoption of cryptocurrencies in the travel and tourism sector. Customers seeking secure and convenient payment methods may benefit from the use of cryptocurrencies. The study emphasizes the importance of addressing security concerns and regulatory compliance, as these are significant barriers to cryptocurrency adoption in the travel industry. The study provides a road map for cryptocurrency adoption in the travel industry, recommending that the industry focus on developing secure and user-friendly cryptocurrency payment methods, as well as actively collaborate with regulatory bodies to ensure compliance. This case study offers valuable insights to industry participants on how to effectively embrace and use cryptocurrencies in day-to-day business operations. Finally, this study offers a thorough examination of the potential of cryptocurrencies as a new form of payment in the travel and tourism industry. The findings of the study provide a clear understanding of the benefits and drawbacks of using cryptocurrencies, as well as valuable insights for industry participants on how to effectively adopt and use cryptocurrencies in their operations.
摘要:本研究的目的是研究加密货币作为旅游和旅游业传统支付方式的可行替代方案的能力。鉴于数字货币的日益普及,旅游业必须考虑其他支付方式。这项研究的目的是确定加密货币是否可以成为旅游和旅游业的一种安全实用的支付选择。使用案例研究方法研究了加密货币在旅游和旅游业中采用的利弊。该研究的重点是客户偏好、安全性和法规遵从性。我们对一些已经实施加密货币作为支付选项的公司进行了深入的研究,并对商业领袖进行了采访。根据该研究的结果,旅游和旅游部门对采用加密货币的需求很大。寻求安全便捷支付方式的客户可能会从加密货币的使用中受益。该研究强调了解决安全问题和监管合规的重要性,因为这些都是旅游业采用加密货币的重大障碍。该研究为旅游业采用加密货币提供了路线图,建议该行业专注于开发安全和用户友好的加密货币支付方式,并积极与监管机构合作以确保合规性。本案例研究为行业参与者提供了如何在日常业务运营中有效地接受和使用加密货币的宝贵见解。最后,本研究对加密货币作为一种新的支付方式在旅游和旅游业中的潜力进行了全面的研究。该研究的结果清楚地了解了使用加密货币的优点和缺点,并为行业参与者提供了关于如何在其运营中有效采用和使用加密货币的宝贵见解。
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引用次数: 1
Symmetric and asymmetric volatility: Forecasting the Borsa Istanbul 100 index return volatility 对称与非对称波动率:预测Borsa Istanbul 100指数回报波动率
Pub Date : 2023-03-01 DOI: 10.2478/fiqf-2023-0005
Selma Öner, Hakan Öner
Abstract The development of technology and the globalization of financial markets have increased the volatility in financial markets and caused the emergence of risks and uncertainties that have not been previously encountered. Since traditional econometric models cannot fully explain this volatility, nonlinear conditional variance models such as ARCH, GARCH, EGARCH and TARCH are used today. From this point of view, this study aims to determine the most explanatory model that fund managers who are considering investing in the Borsa Istanbul 100 (BIST 100) Index, and academicians doing research on this subject, can use in estimating the BIST 100 Index return volatility. For this purpose, ARCH and GARCH models, as symmetric models, and EGARCH and TARCH models, as asymmetric nonlinear conditional models, are included in the econometric analysis by using the end-of-day values of 2657 observations belonging to the 04.01.2010-28.07.2020 period. According to the empirical results of the study, the TARCH model, which has the highest level of explanatory power, gives the most successful results among related models in revealing BIST 100 Index return volatility.
科技的发展和金融市场的全球化,增加了金融市场的波动性,造成了以前没有遇到过的风险和不确定性的出现。由于传统的计量经济模型不能完全解释这种波动,现在使用的是非线性条件方差模型,如ARCH、GARCH、EGARCH和TARCH。从这个角度来看,本研究旨在确定最具解释性的模型,以供考虑投资伊斯坦布尔博尔萨100指数(BIST 100)的基金经理和从事该主题研究的学者用于估计BIST 100指数的收益波动。为此,采用2010年1月4日- 2020年7月28日2657次观测值的日末值,将对称模型ARCH和GARCH模型,非对称非线性条件模型EGARCH和TARCH模型纳入计量分析。从实证研究结果来看,在相关模型中,TARCH模型在揭示BIST 100指数收益波动方面的结果最为成功,解释力最高。
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引用次数: 0
Relationship between the green finance index, CO2 emission, and GDP 绿色金融指数、二氧化碳排放与GDP的关系
Pub Date : 2023-03-01 DOI: 10.2478/fiqf-2023-0007
Çağrı Hamurcu
Abstract Green technology innovation and effective use of green financing tools are very important in order to ensure sustainable economic and environmental development without environmental degradation, and to decarbonize all sectors. Evaluating the green investment process together with the inputs, outputs and the factors involved in the process will make important contributions in terms of determining the current situation, developing new and effective policies and raising awareness on green finance. For all these reasons, it is aimed to reveal the interaction mechanisms between GFI, CO2 emissions and GDP in this study. GFI, CO2 emissions, and GDP variables covering 26 countries between 2018-2021 were analyzed using panel data analysis with a fixed effects model. Firstly, it is found that CO2 emission had a negative effect on GFI, but GDP had a positive effect on GFI, and the effect of CO2 was greater than GDP. Secondly, GFI was found to have negative effects on CO2 emissions whereas GDP had positive effects, with GFI benefiting slightly more than GDP from these effects. Thirdly, GDP was shown to be positively affected by both GFI and CO2, and the analyses revealed that the effect of CO2 was much greater than that of GFI. The findings are considered important in terms of making predictions in terms of understanding and developing green finance and its effects.
摘要绿色技术创新和绿色融资工具的有效使用对于确保经济和环境的可持续发展而不使环境恶化,实现各行业的脱碳至关重要。评估绿色投资过程及其投入、产出和过程中涉及的因素,将在确定现状、制定新的有效政策和提高对绿色金融的认识方面做出重要贡献。基于这些原因,本研究旨在揭示GFI、CO2排放和GDP之间的相互作用机制。采用固定效应模型的面板数据分析,分析了2018-2021年间覆盖26个国家的GFI、二氧化碳排放和GDP变量。首先,研究发现CO2排放对GFI有负向影响,而GDP对GFI有正向影响,且CO2的影响大于GDP。其次,GFI被发现对二氧化碳排放有负面影响,而GDP有积极影响,GFI从这些影响中获得的好处略高于GDP。第三,GFI和CO2对GDP均有正向影响,且分析显示CO2的影响远大于GFI。这些发现对于做出预测、理解和发展绿色金融及其影响具有重要意义。
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引用次数: 2
Evolution of loyalty programs offered to customers and investors 向客户和投资者提供忠诚计划的演变
Pub Date : 2023-03-01 DOI: 10.2478/fiqf-2023-0004
Danuta Dziawgo
Abstract The subject of this study is loyalty programs. The aim of the article is to draw attention to loyalty in the current economy. The purpose of the article is to examine the evolution of loyalty programs offered to consumers and investors. The study will cover the issue of building a loyal base of clients and investors. To achieve the aim of the study in the article, analysis of the literature, description, comparison, desk research and case study methods were applied. The study presents the author's definition and classification of loyalty programs. The research has demonstrated that there is social acceptance for activities undertaken in the field of loyalty programs. Such loyalty programs tighten financial and non-financial links with stakeholders. At the same time, programs offered to consumers are evolving towards creating an emotional loyalty that resonates with consumers. In turn, programs offered to investors are evolving towards generating financial benefits only on the capital market. However, that means resigning from creating an investor as a consumer through the loyalty program. At the same time, the loyalty program is open to every investor, regardless of the country of origin and type of investor. It can be expected that in the next stage of evolution these will be aware of their rights and environmentally sensitive stakeholders’ attitudes and preferences will have to be taken into account to an increasing extent by the company
本研究的主题是忠诚度计划。这篇文章的目的是引起人们对当前经济中忠诚度问题的关注。本文的目的是研究向消费者和投资者提供的忠诚度计划的演变。这项研究将涵盖建立一个忠实的客户和投资者基础的问题。为了达到本文的研究目的,本文采用了文献分析法、描述法、比较法、案头研究法和案例研究法。本研究提出了作者对忠诚度计划的定义和分类。研究表明,在忠诚计划领域开展的活动具有社会接受度。这种忠诚计划加强了与利益相关者的财务和非财务联系。与此同时,提供给消费者的节目正在朝着创造一种与消费者产生共鸣的情感忠诚的方向发展。反过来,提供给投资者的项目正朝着只在资本市场上产生经济效益的方向发展。然而,这意味着放弃通过忠诚计划将投资者变成消费者的机会。与此同时,忠诚计划对所有投资者开放,无论原籍国和投资者类型如何。可以预期,在下一阶段的发展中,这些人将意识到他们的权利,而对环境敏感的利益相关者的态度和偏好将不得不被公司越来越多地考虑在内
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引用次数: 0
Reaction of the USD/PLN currency pair exchange rate to the published macroeconomic data 美元/兹罗提货币对汇率对公布的宏观经济数据的反应
Pub Date : 2023-03-01 DOI: 10.2478/fiqf-2023-0001
Jolanta Pasionek
Abstract The results of the research presented in the article regard the importance of publication of macroeconomic data from the United States for the short-term USD/PLN currency pair exchange rate volatility. The main purpose of the research was to indicate what macroeconomic data is important for the short-term USD/PLN exchange rate volatility. The following research questions have been posed does the USD/PLN exchange rate react to the published macroeconomic data from the American economy and second could greater USD/PLN exchange rate volatility be observed during the COVID pandemic and has the war in Ukraine impacted the USD/PLN exchange rate volatility. International Foreign Exchange Market is the largest and most dynamically developing financial market in the world. In the globalized world the exchange rates are mainly influenced by economic factors. The most significant economic factors that impact short-term exchange rate volatility are primarily macroeconomic data from the American economy. Therefore in this article the author attempts to analyze macroeconomic data and their impact on short-term USD/PLN exchange rate volatility. Data based on which the research was made is as follows: Consumer Price Index, Non-Farm Payrolls (NFP), Services PMI, Manufacturing PMI, Empire State Manufacturing Index or Retail Sales. The analysis of connections between the publication of macroeconomic data and the reaction of exchange rates was carried out using the linear regression model with GARCH process for the random parameter. Conclusions of this research is exchange rate volatility USD/PLN was higher after publications of the macroeconomic data from Americans economy. The strongest exchange rate reaction was after publication of data regarding inflation, Manufacturing PMI and Retail Sales. In the COVID (1.03.20—14.02.22) period we observed increased USD/PLN exchange rate volatility. Exchange rate volatility was expressly larger in the period of war in Ukraine (15.02.22 – end of experiment).
摘要本文的研究结果考虑了美国宏观经济数据的公布对短期美元/PLN货币对汇率波动的重要性。研究的主要目的是指出哪些宏观经济数据对短期美元/兹罗提汇率波动很重要。以下研究问题已经提出,美元/PLN汇率是否对美国经济公布的宏观经济数据做出反应,第二,在COVID大流行期间,美元/PLN汇率是否会出现更大的波动,乌克兰战争是否影响了美元/PLN汇率波动。国际外汇市场是世界上规模最大、发展最活跃的金融市场。在全球化的世界里,汇率主要受经济因素的影响。影响短期汇率波动的最重要经济因素主要是来自美国经济的宏观经济数据。因此在本文中,作者试图分析宏观经济数据及其对美元/兹罗提短期汇率波动的影响。该研究所基于的数据如下:消费者价格指数、非农就业人数(NFP)、服务业PMI、制造业PMI、纽约州制造业指数或零售销售。采用随机参数GARCH过程的线性回归模型,分析宏观经济数据公布与汇率反应之间的关系。本研究的结论是美国经济宏观经济数据公布后,美元/PLN的汇率波动率更高。在通胀、制造业PMI和零售销售数据公布后,汇率反应最为强烈。在COVID(1.03.20-14.02.22)期间,我们观察到美元/兹罗提汇率波动增加。在乌克兰战争期间(22年2月15日-实验结束),汇率波动明显更大。
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引用次数: 0
On separation of monetary and fiscal operations in macroeconomics statistics 论宏观经济统计中的货币与财政操作分离
Pub Date : 2022-12-01 DOI: 10.2478/fiqf-2022-0023
Václav Rybáček, J. Janáček
Abstract The aim of the paper is to discuss one of the major topical and controversial issues in contemporary statistics, which is the separation of monetary and fiscal operations in national accounts. This issue revolves mainly around the operation of public financial institutions mandated to carry out monetary as well as fiscal transactions on behalf of governments. After discussing the methodological dimension of the point at issue, the paper numerically demonstrates the impact on final figures given the existing data constraints. Admittedly, substantial changes to the current recporting may modify the aggregates utilized in the analysis of the fiscal sustainability or the economic role of the government as such. The paper demonstrates that the statistical uncertainty about the size of the government sector is a fundamental issue. The impact on the level of government indebtedness may reach up to tens of percentage points.
摘要本文的目的是讨论当代统计学中一个主要的话题和有争议的问题,即国民核算中货币和财政操作的分离。这个问题主要围绕被授权代表政府进行货币和财政交易的公共金融机构的运作展开。在讨论了问题点的方法学维度后,本文在给定现有数据约束的情况下,用数值方法演示了对最终数字的影响。诚然,当前报告的重大变化可能会修改用于分析财政可持续性或政府经济作用的总量。本文论证了政府部门规模的统计不确定性是一个根本性问题。对政府负债水平的影响可能高达几十个百分点。
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引用次数: 0
Effects of COVID-19 on payment method preferences of Poles 新冠肺炎疫情对波兰人支付方式偏好的影响
Pub Date : 2022-12-01 DOI: 10.2478/fiqf-2022-0026
J. Kubiczek
Abstract Repeated payments create a certain habit in terms of the preferred payment method. Its formation stems from the simultaneous effect of a variety of factors, while its persistent character implies a difficulty in its change. The outbreak of the COVID-19 pandemic has influenced the terms of how society functions, thus affecting multiple spheres of people’s lives, including making purchases and payments. The aim of this paper is to identify and present the multidimensional impact of the COVID-19 pandemic on payment method preferences of people in Poland. The results indicate that the COVID-19 pandemic has stimulated the shrinkage of cash exchanges while at the same time made the tendency to use cashless payment methods grow. Cash payments are a path for viral transmissions and, thus, a potential source of infection and viewing them as an unsafe payment method effected the turn to cashless forms of payment. It is important to note that this fact constitutes one of the most vital factors of the dynamic growth of the BLIK payment system - a multi-institutional cashless payment system, working independently of the present card-based systems in Poland. Based on the conducted study it can be stated that the COVID-19 pandemic significantly changed payment method preferences of the people in Poland, yet the permanence of those changes will only be possible to determine in a larger timeframe.
重复支付在偏好支付方式方面形成了一定的习惯。它的形成是多种因素共同作用的结果,而它的持久性意味着它的变化是困难的。2019冠状病毒病大流行的爆发影响了社会的运作方式,从而影响了人们生活的多个领域,包括购买和支付。本文的目的是确定并呈现COVID-19大流行对波兰人民支付方式偏好的多维影响。结果表明,新冠肺炎疫情在刺激现金交易萎缩的同时,也促进了使用无现金支付方式的趋势。现金支付是病毒传播的途径,因此是潜在的感染源,将其视为不安全的支付方式影响了向无现金支付形式的转变。重要的是要注意到,这一事实构成了BLIK支付系统动态增长的最重要因素之一- -一个多机构无现金支付系统,独立于波兰目前基于卡的系统工作。根据所进行的研究,可以说COVID-19大流行极大地改变了波兰人民的支付方式偏好,但这些变化的持久性只有在更长的时间范围内才能确定。
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引用次数: 0
Relationship between government expenditure and economic growth in Visegrad Group 维谢格拉德集团政府支出与经济增长的关系
Pub Date : 2022-12-01 DOI: 10.2478/fiqf-2022-0024
Irena Szarowská
Abstract The goal of the article is to examine the relationship between government expenditure and economic growth in the Visegrad Group in the period 2000-2020. Economic theory as well as published studies have suggested that government expenditure is an important factor in ensuring economic growth, which has been the subject of increased interest in recent years. The article focuses on development of government expenditure, changes in its composition in individual countries during the analyzed period, and also on the direction of influence between these variables. Real GDP time series were cyclically adjusted as well as annual data on government expenditure which were used in compliance with the COFOG international standard. The results suggest that government expenditure and their composition are similar in the Visegrad Group despite the existing differences in the size of the public sector. On the other hand, the cyclicality of government expenditure differs across the countries. Results suggest that countries of the Visegrad Group did not use government expenditure as a stabilizer in the monitored period. Government expenditure was acyclical in Slovakia and procyclical in other countries of the Vise-grad Group. Applied Granger causality methodology provides mixed conclusions about the relationship between government expenditure and economic growth. Nevertheless, unidirectional Granger causality from GDP growth to government expenditure and its divisions predominates, which means that economic growth comes first, followed by government expenditure.
摘要本文的目的是考察2000-2020年维谢格拉德集团政府支出与经济增长之间的关系。经济理论和已发表的研究表明,政府支出是确保经济增长的一个重要因素,这是近年来人们越来越感兴趣的主题。本文的重点是政府支出的发展,在分析期间各国政府支出构成的变化,以及这些变量之间的影响方向。实际国内生产总值时间序列进行了周期性调整,政府支出的年度数据也按照COFOG国际标准使用。结果表明,尽管公共部门的规模存在差异,但维谢格拉德集团的政府支出及其构成是相似的。另一方面,各国政府支出的周期性有所不同。结果表明,在监测期间,维谢格拉德集团国家没有使用政府支出作为稳定器。斯洛伐克的政府支出是非周期性的,而维斯格勒集团其他国家的政府支出是顺周期性的。运用格兰杰因果关系方法对政府支出与经济增长之间的关系给出了复杂的结论。然而,GDP增长与政府支出及其划分之间的单向格兰杰因果关系占主导地位,即经济增长先,政府支出后。
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引用次数: 1
期刊
Financial Internet Quarterly
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