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MES Forecast has been developed for two years. It represents an approach for forecasting, which is new to Russia and is based on the Foresight methodology, which does not concern with predicting future, but rather with its formation. During the development of the Forecast there was an expertise made concerning the promising directions of the scientific and technological development and the sectors of the Russian economy by the Delphi method, involving a large group of experts (more than 2000).

The RAS forecast is a routine step in the process of the annual long-term forecasting which is executed by the research institutes of the Russian Academy of Science, involving external experts.

Within the framework of both the forecasts the following main problems were set and solved to a different extent of specification:

Estimation of the existing level of the scientific and technological development of the Russian Federation was conducted and its main problems were revealed;

External and internal conditions that should be taken into account when making a forecast, including the challenges present, were defined;

Long-term forecasts of scientific and technological development of Russia were developed both for the scientific and technological directions and for the main sectors of the economy;

The directions for the improvement of the scientific and technological policy were formulated.

On the whole the MES forecast contains more detailed information concerning both the initial conditions, whose analysis is essential for the Forecast making, and the results of the forecast itself. Thus, the analysis of the internal and external conditions, setting the limits and the directions of the forecast is detailed in MES Forecast, but condensed in RAS forecast. There is an analysis of the internal economic situation, including challenges present (resource, demographic ones, challenges connected with the conditions of the scientific and technological complex development), internal institutional conditions (including the imperfection of the national institutions, both specific, directly connected with the provision for the innovation activity and general, providing the operation of the market economy as a whole), as well as the external conditions, including the detailed analysis of the world markets of goods and services (fuel and energy complex, metallurgy etc). External conditions, concerning the specific features of Russian high-tech commodities positioning at the international markets are also estimated.

In RAS forecast, meanwhile, there are two sections present, which are not sufficiently elaborated in the MES forecast. These are the forecast for the development of provision of science with resources and the indices of the innovation development, as well as the analysis of the directions for the development of the fundamental research.

There are insignificant deviations concerning the estimations of the current state of affairs in the scientific and technological spheres in MES and RAS forecasts. For instance, according to MES forecast data, there is 45% of the higher educational institutions that conduct research and development works, and according to RAS forecast there is 37% such. The proportion of the entrepreneurial sector in R&D financing is equal to 45%, according to MES forecast, and to 27.7% according to RAS forecast. If one refers to the data of the Federal State Statistics Service, the data given in RAS forecast seem to be more reliable. For instance, according to MES forecast it is supposed that the number of research workers will decrease down to 400-600 thousand of people, whereas at present there are already only 390 thousand research workers occupied in the Russian science46.

The forecasts differ substantially when it comes to the methods of estimation. The MES forecast includes the results of prognostication by Delphi method for scientific and technological directions, as well as for the sectors of the Russian economy. These two kinds of the predictive estimation are made thoroughly and conscientiously, but they are weakly connected with each other. It is the forecast for the development for the sectors of the Russian economy that was elaborated to the highest extent and contains the calculations for the conservative and the innovation variants of the development, and the result of the forecast if the list of the realistic directions and priorities of the development. Scientific Data for 2007. Source: Main indices of the development of science in the Russian Federation in 2000-Express information. Moscow, edited by the Center for science research and statistics, 2008, p.26.

http://www.csrs.ru and technological directions were estimated by the experts and the estimation included the finding of the niches in which Russia can strengthen its positions thanks to the competitive advantages, using two criteria: strengthening of the positions at global markets and integration in global chains. On the basis of the estimations received the list of critical technologies adopted by the Government was corrected.

Table Comparative Characterization of Long-term Forecast for the Scientific and Technological Development of the Russian Federation (up to 2025) the Forecast of the Scientific and Technological Development of the Russian Federation for Long-term Outlook (up to 2030) Feature MES forecast RAS forecast Basic methodology Delphi method, expert estimations, extrapola- Expert estimations, extrapolation tion Experts Representatives of higher education, industrial Representatives of the academic scientific and academic scientific research and business. community (RAS institutes), attracting a The majority of experts is the representatives number of organizations of other sectors of the scientific community Estimation of the current Deviations from the data of the official statis- Estimations correspond with the data of state of affairs tics the official statistics that are analyzed in the context of the international comparisons Challenges analysis Present, broken by types of challenges (inter- General estimations nal and external) Approach to define Making a list of the critical technologies on The list of the priority directions and priority fields the basis of the expert survey (Delphi me- critical technologies adopted by the Govthod). The list of the priority directions ernment is used as the basis adopted by the Government was supplemented by three new ones as a result of the expert estimation Method for estimation of Experts estimation, compared with the level Experts estimation, using 4-point scale, scientific and techno- in the foreign countries, and for a number of with the help of which the critical techlogical direction directions there is an estimation of the terms nologies are compared for the fulfillment of different thematic directions Forecast for the devel- No. There is a list of priority thematic fields There is a detailed description of the diopment of the fundamen- for the development of the fundamental re- rections of research (list of topics) tal science search Forecast for development No Present, including the context of the comof the provision of sci- parison with the foreign countries ence with resources Forecast for development Present. There are calculations for the conser- No of economy sectors vative and innovative variants Definition of the tools Outlined for a number of directions (for the General approaches are listed for scientific and techno- development institutions, chain organizations, logical policy small-scale enterprises, technological, platforms) The RAS forecast takes as basis the priority directions and the list of the critical technologies adopted by the Government. They were estimated using 4-point scale. There is no derailed description of the estimations received in the Forecast. The prognosis of the scientific and technological directions with a big potential for applications is made by the institutes of the Russian Academy of Science in RAS forecast. This is a weakness since it is important to attract practicing experts and representatives of the industry for the forecast. Even if this opinion is highly competent, it still the opinion of the representative of the science that do not normally deal with commercialization of the R&D results and their putting in the practice of the industrial production.

Finally, both the forecasts contain suggestion on the development of the innovation activity. Thee RAS forecast includes the list of the policy measures to be fulfilled, not giving details of tools and approaches. The MES forecast is quite declarative as to the recommendations on the innovation pol icy, but it contains a number of better elaborated measures, concerning the support for the development institutions, fulfillment of the main innovation projects of the state significance (VIP-projects), formation of technological platforms. The MES forecast suggests the state concentrate the efforts on two main directions:

Realization of initiatives, securing the formation of the potential for technological development in the long run (for instance, the development of nanotechnologies), including the realization of VIP projects.

The development of the institutions and infrastructure of the national innovation system which gives an access to the necessary technological solutions and simultaneously concentrates the sphere of science on the creation of the technologies that are important for business.

It is envisaged that this will be achieved thanks to the further development of the financial institutions, innovation clusters as well as to the creation of the system of the government support for new (small) innovation companies.

As to the measures of the innovation policy the Forecasts differ not only in the extent of their specification, but also in the list of the measures itself. The development institutions that are emphasized in the MES forecast are not mentioned in RAS forecast.

Some comparative characteristics of two forecasts are represented in table 1.

After official promulgation of these two documents a sort of a conflict situation has evolved since both the forecasts are claimed to be the national forecast. The analysis of the forecasts content allows drawing the conclusion that they rather supplement than contradict each other. That is why it seems reasonable to develop unified Long-term forecast for the scientific and technological development of the Russian Federation, which would include the estimation of the development of provision of science with resources, scientific and technological directions, directions of fundamental research, as well as sectors of economy. The introduction of the main goals and directions of the development of the fundamental research in the forecast would contribute in the deeper understanding of the key trends of the global technological development by the forecast consumers. Complex forecast may be elaborated by joining the efforts of the academic, higher education communities, representatives of business and industry, as well as non-commercial sector. It is significant at the same time for the Forecast to end with the description of measures and tools of the innovation policy and preferably including their order of comparative priority. At present the Forecasts developed do not give clear understanding of the strategy for the development of the innovation system, in the crisis environment, especially, as well as the sequence and the content of the measures of the government regulations.

Important issues of Transfer Pricing Kornienko N., Velokova E.

The discussion of the draft of the law concerning the improvement of the principles for prices determining for the purposes of taxation developed by the Ministry of Finance of the Russian Federation is going on. According to the explanatory note accompanying this document the changes suggested are in accordance with the international practice of taxation. On the whole the structure of the document corresponds to the similar acts in effect in the developed countries and is yet another step on the way of the improvement of the Russian taxation system. At the same time the draft of the law contains some inaccuracies that might limit the application of new mechanisms.

At present the discussion of the draft of the law concerning the improvement of the principles for prices determining for the purposes of taxation developed by the Ministry of Finance of the Russian Federation47 is going on, according to it the articles of the Tax Code of the Russian Federation on the regulation of the transfer pricing that are currently in effect are changed and supplemented. According to the explanatory note accompanying this document the changes suggested are in accordance with the international practice of taxation.

It is in fact the OECD Transfer pricing Guidelines for multinational enterprises and tax administrations adopted by the OECD Committee on Fiscal Affairs on June, 25 1995 that is the basic document in the field of the international regulation of transfer pricing for the purposes of taxation. The Transfer See http://www1.minfin.ru/ru/tax_relations/policy/use_regulation/government_docs/ pricing Guidelines for multinational enterprises and tax administrations (further referred to as the Guidelines) is a combined version of the OECD Committee on budget issues, concerning the issues of transfer pricing (taking into account the addenda of 1996, 1997, 1999, 2005, 2007).

The Guidelines concern mainly the practical application of the principle of arm's length to estimate the transfer prices of the interdependent persons. The Guidelines presents the analysis of the methods for the estimation of the correspondence of the commercial and financial relations between the interdependent persons according to the principle of the arm's length, and the discussion of the practical applications of these methods.

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