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Relevant bibliographies by topics / Conceptual principles of transfer pricing

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Academic literature on the topic 'Conceptual principles of transfer pricing'

Author: Grafiati

Published: 28 May 2022

Last updated: 31 July 2025

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Journal articles on the topic "Conceptual principles of transfer pricing"

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Kvasovskyi, Oleksandr, and Vitaliy Rudan. "Theoretical-conceptual and scientific-applied dominants of transfer pricing policy for economic entities." Economic Analysis, no. 34(1) (2024): 165–78. http://dx.doi.org/10.35774/econa2024.01.165.

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Introduction. Through the adept use of transfer pricing, companies can optimize their costs, minimize various types of risks, maximize profits, and gain tangible competitive advantages. At the same time, in the context of increased fiscal control and constant changes in the international tax environment, adherence to fiscal-regulatory requirements regarding transfer pricing by economic entities gains special importance. Therefore, companies need to develop, implement, and continuously modernize their own corporate transfer pricing policy, as it not only contributes to overall financial success

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Brem, Markus, and Thomas Tucha. "Transfer Pricing: Conceptual Thoughts on the Nature of the Multinational Firm." Vikalpa: The Journal for Decision Makers 31, no. 2 (2006): 29–44. http://dx.doi.org/10.1177/0256090920060202.

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This paper deploys Transaction Cost Economics (TCE) to elaborate on the shortcomings of ‘mainstream‘ transfer pricing in multinational firms. Departing from the notion that multinationals increasingly (re-)organize their business along multinational value chains irrespective of jurisdictional borders, this paper discusses the nature of the multinational firm and the problem of choosing the right intra-group (transfer) price. The mainstream transfer pricing approach derived from the Arm�s Length Principle (ALP) is deemed inappropriate for globally operating multinational enterprises (MNEs). Ref

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Jakfar and Fariha Nuraini. "Transfer Pricing and Tax Avoidance: A Narrative Review of Global Strategies and Regulatory Challenges." Sinergi International Journal of Economics 3, no. 2 (2025): 97–107. https://doi.org/10.61194/economics.v3i2.645.

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This narrative review investigates how transfer pricing is strategically utilized by multinational enterprises to facilitate international tax avoidance. The study aims to assess the role of pricing arrangements between related entities in shifting profits to low-tax jurisdictions. Using a comprehensive narrative methodology, literature was gathered from databases such as Scopus and Google Scholar, applying specific keywords and inclusion criteria to identify relevant empirical and conceptual studies. The review identifies a pattern of aggressive transfer pricing behavior, particularly in indu

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Oguttu, Annet Wanyana. "Challenges of Applying the Comparability Analysis in Curtailing Transfer Pricing: Evaluating the Suitability of Some Alternative Approaches in Africa." Intertax 48, Issue 1 (2020): 74–102. http://dx.doi.org/10.54648/taxi2020006.

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This article asserts that transfer pricing is perhaps the greatest profit shifting problem facing the international tax system. Thus, countries have historically been keen on preventing transfer pricing and on finding effective and efficient methods for allocating revenue that are administratively cost effective for both taxpayers and tax administrators. However, the problem as articulated in this article is that the comparability analysis that underpins the application of the arm’s length principle (ALP) which is applied internationally to curb transfer pricing, continues to be a vexing probl

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Mwape, Victor, Austin Mwange, and Munyonzwe Hamalengwa. "Reassessing the Arm’s Length Principle in Transfer Pricing Regulation: A Doctrinal and Practical Analysis from a Zambian Perspective." African Journal of Commercial Studies 6, no. 1 (2025): 199–206. https://doi.org/10.59413/ajocs/v6.i.1.18.

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The arm’s length principle (ALP) has long been considered the cornerstone of international transfer pricing regimes. Originating from Article 9 of the OECD Model Tax Convention, the ALP aims to ensure that transactions between related entities reflect market conditions as if undertaken by independent enterprises. This article critically examines the doctrinal, institutional, and practical dimensions of the ALP, particularly within the context of developing economies such as Zambia. While the ALP underpins Zambia’s transfer pricing regulatory framework, significant concerns remain regarding its

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Jain, Ajit Kumar. "When Machines Create Value: Rethinking Transfer Pricing for AI-Driven Economies." International Journal for Research in Applied Science and Engineering Technology 13, no. 7 (2025): 1567–81. https://doi.org/10.22214/ijraset.2025.73236.

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Artificial Intelligence (AI) is transforming how multinational enterprises (MNEs) generate, manage, and capture value—posing unprecedented challenges for international transfer pricing frameworks rooted in traditional human-performed functions and tangible asset ownership. This paper explores the disruptive implications of AI-driven business models for the arm’s length principle, focusing on decentralized decision-making, data-based intangibles, and algorithmic value creation. By analyzing use cases across industries such as financial services, pharmaceuticals, and e-commerce, the study highli

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Pyroha, S. S. "Transfer pricing reforms in the context of BEPS: challenges remain." Law and Safety 92, no. 1 (2024): 163–72. http://dx.doi.org/10.32631/pb.2024.1.15.

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The presence of affiliated entities in different countries and the independence of tax systems make it easy to shift profits from jurisdictions with high corporate tax rates to jurisdictions with low rates. Transfer prices and the arm's length principle are used to prevent profit shifting. The article identifies the peculiarities of transfer pricing reform in the context of the BEPS plan, analyses changes to Ukrainian legislation and opportunities for its improvement. The article analyses the amendments to the Tax Code of Ukraine aimed at ensuring the implementation of the BEPS plan. The

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Solange Screpante, Mirna. "The Arm’s Length Principle Evolves Towards a ‘Value Creation Functional (i.e. DEMPE) Formula Standard’: A Barrier or a Gateway to Locational Business Planning?" Intertax 48, Issue 10 (2020): 861–78. http://dx.doi.org/10.54648/taxi2020087.

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Value creation vis-à-vis the DEMPE rationale and methodology converted a conceptual notion associated with contributions to value creation but lacking prescription into a new standard to allocate profits to achieve reunification for tax purposes in a manner consistent with the directions of the arm’s length principle (ALP). Within this context, this article questions whether value creation could or should be based on a functional (i.e. DEMPE)-formula-based standard to allocate profits, and whether such an approach would target or abet tax avoidance framed by apparently genuine structures –‘acc

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Khvesyk, Mykhailo A., Oleksandr M. Shubalyi, Julia M. Khvesyk, and Natalia M. Vasilik. "Conceptual basis of transformation of ecological and economic relations in the forest sector of Ukraine in the context of European integration." Folia Forestalia Polonica 61, no. 2 (2019): 97–111. http://dx.doi.org/10.2478/ffp-2019-0010.

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Abstract The article defines the priorities, principles and main provisions of national forest policy of Ukraine towards European integration. The main objectives and structure of the mechanism of transformation of ecological and economic relations in the forest sector of Ukraine is grounded. The main tasks of transformation of ecological and economic relations in the forest sector should be decentralization of the management system, budget savings and sustainability, sustainable development and ecological security, development of public and private partnership, and welfare of local communitie

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Pogorelova, Lioubov. "Transfer-Pricing and Game Theory." Intertax 43, Issue 5 (2015): 395–404. http://dx.doi.org/10.54648/taxi2015034.

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This article examines the complex nature of the transfer-pricing problem to determine how strategic considerations of organizations guide the application of different types of game-theoretic models for a profit-split transfer-pricing method. The article proposes a conceptual framework that links strategy with specific game-theoretic models in transfer-pricing decision-making.

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Dissertations / Theses on the topic "Conceptual principles of transfer pricing"

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Савченко, Тарас Григорович, Тарас Григорьевич Савченко та Taras Hryhorovych Savchenko. "Теоретичні аспекти трансфертного ціноутворення у банківських установах". Thesis, Таврійський національний університет ім. В.І. Вернадського, 2006. http://essuir.sumdu.edu.ua/handle/123456789/63195.

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Foster, Martie. "Withholding tax on services : a square peg in a round hole? : an analysis of intra-group cross border services in the context of source, related transfer pricing principles and witholding taxes." Master's thesis, University of Cape Town, 2014. http://hdl.handle.net/11427/13146.

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Includes bibliographical references.<br>Various countries have extended the levying of withholding taxes beyond the traditional withholding taxes on royalties, dividends and interest. Withholding taxes are now often levied on services such as management services, professional services, technical services, financial services, insurance services, fees, commission, advisory services and digital services, amongst others. The purpose of this paper is to consider the impact of these withholding taxes on certain services, in particularly intra-group cross border services in the context of source and

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Books on the topic "Conceptual principles of transfer pricing"

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John, Chandler Clark, ed. Transfer pricing: Economic, managerial, and accounting principles. Tax Management, 1995.

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Brem, Markus. On transfer pricing conceptual thoughts on the nature of the multinational firm. Indian Institute of Management, 2005.

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Global transfer pricing: Principles and practice. Bloomsbury Professional, 2016.

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Collardin, Marcus. Global Transfer Pricing: Principles and Practice. LexisNexis UK, 2003.

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Henshall, John, and Roy Donegan. Global Transfer Pricing: Principles and Practice. Bloomsbury Professional, 2019.

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Donegan, Roy. Global Transfer Pricing: Principles and Practice. Bloomsbury Publishing Plc, 2023.

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Deloitte and John Henshall. Global Transfer Pricing: Principles and Practice. Bloomsbury Publishing Plc, 2016.

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Global transfer pricing: Principles and practice. Bloomsbury Professional, 2013.

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Global Transfer Pricing: Principles and Practice. Bloomsbury Publishing Plc, 2016.

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Deloitte. Global Transfer Pricing: Principles and Practice 4th Edition. Bloomsbury Publishing Plc, 2020.

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Book chapters on the topic "Conceptual principles of transfer pricing"

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Dakhil, Omar M., Mohamed M. H. Maatouk, and Mohammed O. Aljoufie. "An Urban Resilience Conceptual Framework: A Tool to Enhance City Planning." In Proceedings in Technology Transfer. Springer Nature Singapore, 2025. https://doi.org/10.1007/978-981-97-8588-9_17.

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Abstract By 2050, the global urban population is projected to exceed 70%, necessitating substantial infrastructure upgrades and updated investments. However, rapid urbanization also exposes cities and their inhabitants to increased vulnerability from climate change and environmental degradation. Heatwaves, earthquakes, droughts, and floods have led to large-scale disasters, resulting in significant economic and human losses. Consequently, urban resilience has emerged as a crucial global concern, particularly in managing unexpected crises. This study examines international best practices in urb

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Collier, Richard S., and Joseph L. Andrus. "Practical and Theoretical Problems Encountered in Applying the Arm’s Length Principle." In Transfer Pricing and the Arm's Length Principle After BEPS. Oxford University Press, 2017. http://dx.doi.org/10.1093/law/9780198802914.003.0005.

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Abstract This chapter examines in greater detail several of the alleged shortcomings of transfer pricing rules based on the ALP. Critics of the ALP argue that various aspects of the ALP cause the existing transfer pricing rules to fall short of the objective of providing a clear and efficient means for accurately allocating income among members of a multi-national enterprise (MNE) group. Such problems, this chapter argues, fall into three categories. A first set of issues involves matters that are conceptual in nature. Next are the problems that are entirely practical in nature. Finally, there

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Collier, Richard S., and Joseph L. Andrus. "Practical and Theoretical Problems Encountered in Applying the Arm’s Length Principle." In Transfer Pricing and the Arm's Length Principle After BEPS. Oxford University Press, 2017. https://doi.org/10.1093/law/9780198802914.003.0005_update_001.

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Abstract This chapter examines in greater detail several of the alleged shortcomings of transfer pricing rules based on the ALP. Critics of the ALP argue that various aspects of the ALP cause the existing transfer pricing rules to fall short of the objective of providing a clear and efficient means for accurately allocating income among members of a multi-national enterprise (MNE) group. Such problems, this chapter argues, fall into three categories. A first set of issues involves matters that are conceptual in nature. Next are the problems that are entirely practical in nature. Finally, there

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Matsos, Georgios. "Transfer Pricing versus Formulary Apportionment." In The Oxford Handbook of International Tax Law. Oxford University Press, 2023. http://dx.doi.org/10.1093/oxfordhb/9780192897688.013.34.

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Abstract This chapter assesses formulary apportionment (FA) as an alternative towards transfer pricing for the allocation of corporate profits among taxing jurisdictions. Although FA has been a relatively old operational notion in subnational corporate taxation, especially in the USA and Canada, it was not generally used in international taxation, other than in theoretical exercises. This is bound to change, as FA is currently the basis of major reform proposals aiming to reregulate the cross-border allocation of taxing powers. FA is usually juxtaposed with transfer pricing and with the arm’s-

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Ramsdahl Jensen, Dennis. "Transfer Pricing Principles VAT/GST v. Direct Taxation." In Value Added Tax and Direct Taxation: Similarities and Differences. IBFD, 2009. http://dx.doi.org/10.59403/2d9em2y036.

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Collier, Richard S., and Joseph L. Andrus. "Practical Application of the Arm’s Length Principle." In Transfer Pricing and the Arm's Length Principle After BEPS. Oxford University Press, 2017. http://dx.doi.org/10.1093/law/9780198802914.003.0004.

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Abstract This chapter provides a general summary of transfer pricing practices prior to the Base Erosion and Profit Shifting (BEPS) Project. The summary is based primarily on the principles and concepts contained in the 2010 version of the Organisation for Economic Co-operation and Development (OECD) Transfer Pricing Guidelines and in the 2013 UN Manual. The chapter first describes the general process of conducting a transfer pricing analysis. Thereafter, the application of that process in two especially difficult situations, those involving intangibles and services, is examined. The chapter t

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Collier, Richard S., and Joseph L. Andrus. "Practical Application of the Arm’s Length Principle." In Transfer Pricing and the Arm's Length Principle After BEPS. Oxford University Press, 2017. https://doi.org/10.1093/law/9780198802914.003.0004_update_001.

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Abstract This chapter provides a general summary of transfer pricing practices prior to the Base Erosion and Profit Shifting (BEPS) Project. The summary is based primarily on the principles and concepts contained in the 2010 version of the Organisation for Economic Co-operation and Development (OECD) Transfer Pricing Guidelines and in the 2013 UN Manual. The chapter first describes the general process of conducting a transfer pricing analysis. Thereafter, the application of that process in two especially difficult situations, those involving intangibles and services, is examined. The chapter t

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Polishchuk, Serhii. "ACCOUNTING INTERPRETATION OF TRANSFER PRICING TRANSACTIONS: CHALLENGES OF UNIFICATION AND AREAS OF CONCEPTUAL DISAGREEMENT." In Transfer pricing in Ukraine: a system of analytical, digital, and control management. Publishing House “Baltija Publishing”, 2025. https://doi.org/10.30525/978-9934-26-553-2-6.

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"12. Reforming the International Tax Transfer Pricing Regime. Part I: Principles and Norms." In Taxing Multinationals. University of Toronto Press, 1998. http://dx.doi.org/10.3138/9781442680371-013.

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Vodianka, Liubov, and Nataliia Stakhova. "INVESTMENTS IN TECHNOLOGY STARTUPS: CONCEPTUAL PRINCIPLES AND STRATEGIC IMPERTATIVES." In Modernisation of the Economy and Financial System: Problems, Opportunities, Prospects. Publishing House "Baltija Publishing", 2025. https://doi.org/10.30525/978-9934-26-540-2-33.

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Investment attractiveness is a combination of economic, social, and natural factors that determine capital inflows into a region. It reflects both objective investment conditions – profitability and risk – and the subjective perception of investors. Investment attractiveness is closely linked to investment activity and the investment environment, which influence a region’s overall image. Assessing investment attractiveness involves quantitative and qualitative evaluations of innovation potential and implementation. Key factors include socio-economic development, production and commercial poten

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Conference papers on the topic "Conceptual principles of transfer pricing"

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Miltén, Petter, Isak Jonsson, Anders Lundbladh, and Carlos Xisto. "Generalized Method for the Conceptual Design of Compact Heat Exchangers." In ASME Turbo Expo 2024: Turbomachinery Technical Conference and Exposition. American Society of Mechanical Engineers, 2024. http://dx.doi.org/10.1115/gt2024-123982.

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Abstract The paper introduces a novel method for generalized heat exchanger design and evaluation, freeing the process from predefined geometries. It aims to facilitate early-stage conceptual exploration, allowing the designer to make informed decisions. The paper explores heat transfer and fluid friction principles in order to set key parameters for estimating aerothermal performance, introduced by LaHaye. Arguing against a single metric, the paper proposes a custom cost function for evaluating the integrated generalized heat exchanger. A case study applies the method to a particular aircraft

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Diller, Thomas E., and Chris Williams. "Exploration of Hands-On Discovery Pedagogy in Heat Transfer." In ASME 2013 Heat Transfer Summer Conference collocated with the ASME 2013 7th International Conference on Energy Sustainability and the ASME 2013 11th International Conference on Fuel Cell Science, Engineering and Technology. American Society of Mechanical Engineers, 2013. http://dx.doi.org/10.1115/ht2013-17597.

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Recent research in the development of the “Thermal and Transport Concept Inventory” test (TTCI) has shown that, despite completing several related courses, students have significant misconceptions of heat transfer principles such as the differences between heat, energy and temperature. This lack of conceptual understanding limits students’ problem-solving abilities (and thus their transition to expertise) and their ability to transfer knowledge to other courses and contexts. This research demonstrates how this problem can be addressed by integrating hands-on workshops into a traditional heat t

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Dartnall, W. John, and John A. Reizes. "Molecular Dynamic Computer Simulation Models for Teaching Thermodynamic Principles." In ASME 2011 International Mechanical Engineering Congress and Exposition. ASMEDC, 2011. http://dx.doi.org/10.1115/imece2011-64892.

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Modern mechanical engineers need to learn more than the traditional classical approaches to thermodynamics and heat transfer. Matter is comprised of molecules and in many situations the behavior of these molecules may be modeled using hard spheres whose motion is governed by Newtonian mechanics. This is particularly true in those situations involving relatively low density gases, that are valuable in introducing the concepts of thermodynamics. This paper presents some models that have been developed using simple-to-use software that students can handle in a time-efficient way during class-room

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Ruiz, Janneth, Antonio Ardila, Bernardo Rueda, et al. "Empirical Determination of the Design Influence of Large Industrial Rotary Kilns for Ferronickel Production on Heat Transfer and Energy Performance." In ASME 2021 Heat Transfer Summer Conference collocated with the ASME 2021 15th International Conference on Energy Sustainability. American Society of Mechanical Engineers, 2021. http://dx.doi.org/10.1115/ht2021-63970.

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Abstract In the industrial process of ferronickel production from lateritic minerals, the influence of design factors, constructive and dimensional aspects on the heat transfer and energy performance of the equipment have been little addressed. The literature focuses on cement kilns or iron and steel production applications. This work compares the influence of the approaches considered in the early phases of the design process on heat transfer and energy performance for two ferronickel rotary kilns. For this purpose, a retrospective analysis was realized identifying requirements, operating pri

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Larsen, K., A. Hossain, and M. Weiser. "Optimizing the Curriculum in Thermodynamics and Heat Transfer With Better Labs, In-Class Demonstrations and Interesting Realistic Problems to Enhance Learning." In ASME 2015 International Mechanical Engineering Congress and Exposition. American Society of Mechanical Engineers, 2015. http://dx.doi.org/10.1115/imece2015-52264.

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The primary objective of a thermodynamic/heat transfer course is to provide the fundamental knowledge necessary to understand the behavior of thermal systems. A thermodynamic/heat transfer course provides a detailed calculus-based analysis of energy, entropy, exergy, conduction, convection, and radiation using these concepts to calculate the behavior and efficiencies of different processes and cycles. Proper conceptual and theoretical understanding of thermodynamics/heat transfer is very important to solve real life problems. In order to understand and properly use the concepts, it is necessar

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Dietz, Timothy P., and Farrokh Mistree. "Integrated Pahl and Beitz and the Theory of Inventive Problem Solving for the Conceptual Design of Multi-Domain Systems." In ASME 2009 International Design Engineering Technical Conferences and Computers and Information in Engineering Conference. ASMEDC, 2009. http://dx.doi.org/10.1115/detc2009-87311.

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A key challenge facing designers creating innovative products is concept generation in conceptual design. Conceptual design can be more effective when the design space is broad and accelerated by including problem solving and solution triggering tools in its structure. The design space can be broadened by using an integrated design of product and material concepts approach. In this approach, structured analogy is used to transfer underlying principles from a solution suitable in one domain (i.e., product or mechanical domain) to an analogous solution in another domain (i.e., materials domain).

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Bejan, Adrian. "A Role for Exergy Analysis and Optimization in Aircraft Energy-System Design." In ASME 1999 International Mechanical Engineering Congress and Exposition. American Society of Mechanical Engineers, 1999. http://dx.doi.org/10.1115/imece1999-0828.

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Abstract This paper outlines a newly emerging body of work that relies on exergy analysis and thermodynamic optimization in the design of energy systems for modern aircraft. Exergy analysis establishes the theoretical performance limit. The minimization of exergy destruction brings the design as closely as permissible to the theoretical limit The system architecture springs out of this constrained optimization principle. A key problem is the extraction of maximum exergy from a hot gaseous stream that is gradually cooled and eventually discharged into the ambient. The optimal configuration cons

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Baritz, Mihaela ioana. "MODELING AND VIRTUAL SIMULATION OF THE OCULAR REFRACTION PROCESS FOR IMPROVING THE INFORMATION ACQUISITION MECHANISM - A STUDIES REVIEW." In eLSE 2020. University Publishing House, 2020. http://dx.doi.org/10.12753/2066-026x-20-089.

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The learning, information acquisition, processing and storage mechanisms form, at the level of the central human system, a complex, flexible, dynamic and self-regulating system to ensure the information transfer in the best conditions. Therefore, the path of informational transfer between the environment and the central system, being realized through the visual system requires a high level of functioning of all the component modules. Thus, in the first part of the paper, the main functional aspects of the visual system that participate in the process of ocular refraction are identified and ana

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Nikonorova, Inna, and Inna Nikonorova. "MANAGEMENT AND SPATIAL PLANNING IN THE COASTAL ZONE OF THE CHEBOKSARY RESERVOIR." In Managing risks to coastal regions and communities in a changing world. Academus Publishing, 2017. http://dx.doi.org/10.31519/conferencearticle_5b1b941dc9d866.24389672.

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Cheboksary reservoir impact to the coast is manifested in the geophysical impact associated with abrasion activities. Geomorphological area of influence at the moment reaches a width of about 40 m, where are the coasts reformation (erosion, collapse, slumping, sliding, transfer or accumulation of sediments, waterlogged processes). Hydrogeological impact is effect on the level of groundwater. We have proposed the conceptual foundations of functional zoning of the reservoir banks that will help to optimize its operation. Selection zones came in accordance with the principles of landscape plannin

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Nikonorova, Inna, and Inna Nikonorova. "MANAGEMENT AND SPATIAL PLANNING IN THE COASTAL ZONE OF THE CHEBOKSARY RESERVOIR." In Managing risks to coastal regions and communities in a changing world. Academus Publishing, 2017. http://dx.doi.org/10.21610/conferencearticle_58b431619fad1.

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Cheboksary reservoir impact to the coast is manifested in the geophysical impact associated with abrasion activities. Geomorphological area of influence at the moment reaches a width of about 40 m, where are the coasts reformation (erosion, collapse, slumping, sliding, transfer or accumulation of sediments, waterlogged processes). Hydrogeological impact is effect on the level of groundwater. We have proposed the conceptual foundations of functional zoning of the reservoir banks that will help to optimize its operation. Selection zones came in accordance with the principles of landscape plannin

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