International transfer pricing : the Australian approach and lessons for Canada

In response to developments in international trade and an increased focus on international transfer-pricing issues, Canada’s minister of finance announced in the 1997 budget that the Department of Finance would undertake a review of the transfer-pricing provisions in the Income Tax Act. On September 11, 1997, the Department of Finance released draft transfer-pricing legislation and Revenue Canada released revised draft Information Circular 87-2R. The legislation was subsequently amended and included in Bill C-28, which received first reading on December 10, 1997. The new rules are intended to update Canada’s international transfer-pricing practices. In particular, they attempt to harmonize the standards in the Income Tax Act with the arm’s-length principle established in the OECD’s transfer pricing guidelines. The new rules also set out contemporaneous documentation requirements in respect of cross-border related-party transactions, facilitate administration of the law by Revenue Canada, and provide for a penalty where transfer prices do not comply with the arm’s-length principle. The Australian tax authorities have similarly reviewed and updated their transfer-pricing practices. Since 1992, the Australian commissioner of taxation has issued three rulings and seven draft rulings directly relating to international transfer pricing. These rulings outline the selection and application of transfer pricing methodologies, documentation requirements, and penalties for non-compliance. The Australian Taxation Office supports the use of advance pricing agreements (APAs) and has expanded its audit strategy by conducting transfer-pricing risk assessment reviews. This article presents a detailed review of Australia’s transfer-pricing policy and practices, which address essentially the same concerns as those at which the new Canadian rules are directed. This review provides a framework for comparison of the approaches adopted in the two jurisdictions. The author concludes that although these approaches differ in some respects, ultimately they produce a similar result. Both regimes set a clear standard to be met by multinational enterprises in establishing transfer prices. Both provide for audits and penalties in the event of noncompliance. And both offer the alternative of an APA as a means of avoiding transfer-pricing disputes with Australian and Canadian tax authorities.

Travel behavior of workers in Dhaka and their attitude towards road pricing

Dhaka, the capital of Bangladesh, is facing severe traffic congestion. Owing to the flaws in past land use and transport planning decisions, uncontrolled population growth and urbanization, Dhaka’s traffic condition is worsening. Road space is widely regarded in the literature as a utility, so a common view of transport economists is that its usage ought to be charged. Road pricing policy has proven to be effective in managing travel demand, in order to reduce traffic congestion from road networks in a number of cities including London, Stockholm and Singapore. Road pricing as an economic mechanism to manage travel demand can be more effective and user-friendly when revenue is hypothecated into supply alternatives such as improvements to the transit system. This research investigates the feasibility of adopting road pricing in Dhaka with respect to a significant Bus Rapid Transit (BRT) project. Because both are very new concepts for the population of Dhaka, public acceptability would be a principal issue driving their success or failure. This paper explores the travel behaviour of workers in Dhaka and public perception toward Road Pricing with regards to work trips- based on worker’s travel behaviour. A revealed preference and stated preference survey has been conducted on sample of workers in Dhaka. They were asked limited demographic questions, their current travel behaviour and at the end they had been given several hypothetical choices of integrated BRT and road pricing to choose from. Key finding from the survey is the objective of integrated road pricing; subsidies Bus rapid Transit by road pricing to get reduced BRT fare; cannot be achieved in Dhaka. This is because most of the respondent stated that they would choose the cheapest option Walk-BRT-Walk, even though this would be more time consuming and uncomfortable as they have to walk from home to BRT station and also from BRT station to home. Proper economic analysis has to be carried out to find out the appropriate fare of BRT and road charge with some incentive for the low income people.

Juggling information policy, rights to information and copyright licensing to enhance the accessibility and reusability of spatial data : the Australian experience

There is still no comprehensive information strategy governing access to and reuse of public sector information, applying on a nationwide basis, across all levels of government – local, state and federal - in Australia. This is the case both for public sector materials generally and for spatial data in particular. Nevertheless, the last five years have seen some significant developments in information policy and practice, the result of which has been a considerable lessening of the barriers that previously acted to impede the accessibility and reusability of a great deal of spatial and other material held by public sector agencies. Much of the impetus for change has come from the spatial community which has for many years been a proponent of the view “that government held information, and in particular spatial information, will play an absolutely critical role in increasing the innovative capacity of this nation.”1 However, the potential of government spatial data to contribute to innovation will remain unfulfilled without reform of policies on access and reuse as well as the pervasive practices of public sector data custodians who have relied on government copyright to justify the imposition of restrictive conditions on its use.

Energy efficient home with price sensitive stochastically programmable TCAs

Introduction of dynamic pricing in present retail market, considerably affects customers with an increased cost of energy consumption. Therefore, customers are enforced to control their loads according to price variation. This paper proposes a new technique of Home Energy Management, which helps customers to minimize their cost of energy consumption by appropriately controlling their loads. Thermostatically Controllable Appliances (TCAs) such as air conditioner and water heater are focused in this study, as they consume more than 50% of the total household energy consumption. The control process includes stochastic dynamic programming, which incorporated uncertainties in price and demand variation. It leads to an accurate selection of appliance settings. It is followed by a real time control of selected appliances with its optimal settings. Temperature set points of TCAs are adjusted based on price droop which is a reflection of actual cost of energy consumption. Customer satisfaction is maintained within limits using constraint optimization. It is showed that considerable energy savings is achieved.

Assessing the significance of climate and community factors on urban water demand

Ensuring adequate water supply to urban areas is a challenging task due to factors such as rapid urban growth, increasing water demand and climate change. In developing a sustainable water supply system, it is important to identify the dominant water demand factors for any given water supply scheme. This paper applies principal components analysis to identify the factors that dominate residential water demand using the Blue Mountains Water Supply System in Australia as a case study. The results show that the influence of community intervention factors (e.g. use of water efficient appliances and rainwater tanks) on water demand are among the most significant. The result also confirmed that the community intervention programmes and water pricing policy together can play a noticeable role in reducing the overall water demand. On the other hand, the influence of rainfall on water demand is found to be very limited, while temperature shows some degree of correlation with water demand. The results of this study would help water authorities to plan for effective water demand management strategies and to develop a water demand forecasting model with appropriate climatic factors to achieve sustainable water resources management. The methodology developed in this paper can be adapted to other water supply systems to identify the influential factors in water demand modelling and to devise an effective demand management strategy.

IT pricing: Copyright law, consumer rights, and competition policy. A submission to the House of Representatives Standing Committee on Infrastructure and Communications Inquiry into IT Pricing

For a hundred years, since Federation, Australian consumers have suffered the indignity and the tragedy of price discrimination. From the time of imperial publishing networks, Australia has been suffered from cultural colonialism. In respect of pricing of copyright works, Australian consumers have been gouged; ripped-off; and exploited. Digital technologies have not necessarily brought an end to such price discrimination. Australian consumers have been locked out by technological protection measures; subject to surveillance, privacy intrusions and security breaches; locked into walled gardens by digital rights management systems; and geo-blocked.

Bubble geometry and chaotic pricing behaviour

This paper is a deductive theoretical enquiry into the flow of effects from the geometry of price bubbles/busts, to price indices, to pricing behaviours of sellers and buyers, and back to price bubbles/busts. The intent of the analysis is to suggest analytical approaches to identify the presence, maturity, and/or sustainability of a price bubble. We present a pricing model to emulate market behaviour, including numeric examples and charts of the interaction of supply and demand. The model extends into dynamic market solutions myopic (single- and multi-period) backward looking rational expectations to demonstrate how buyers and sellers interact to affect supply and demand and to show how capital gain expectations can be a destabilising influence – i.e. the lagged effects of past price gains can drive the market price away from long-run market-worth. Investing based on the outputs of past price-based valuation models appear to be more of a game-of-chance than a sound investment strategy.

Making a match: Combining theory and evidence in policy-oriented macroeconomic modeling

A persistent question in the development of models for macroeconomic policy analysis has been the relative role of economic theory and evidence in their construction. This paper looks at some popular strategies that involve setting up a theoretical or conceptual model (CM) which is transformed to match the data and then made operational for policy analysis. A dynamic general equilibrium model is constructed that is similar to standard CMs. After calibration to UK data it is used to examine the utility of formal econometric methods in assessing the match of the CM to the data and also to evaluate some standard model-building strategies. Keywords: Policy oriented economic modeling; Model evaluation; VAR models

Specifying and enforcing a fine-grained information flow policy : model and experiments

In this paper we present a model for defining and enforcing a fine-grained information flow policy. We describe how the policy can be enforced on a typical computer and present experiments using the proposed model. A key feature of the model is that it allows the expression of rules which detail precisely which information elements are allowed to mix together. For example, the model allows the expression of a policy which forbids a doctor from mixing the personal medical details of the patients. The enforcement mechanisms tracks and records information flows within the system so that dynamic changes to the policy can be made with respect to information elements which may have propagated to different locations in the system.

Development and implementation of the areawide Dynamic ROad traffic NoisE (DRONE) simulator

This paper discusses the areawide Dynamic ROad traffic NoisE (DRONE) simulator, and its implementation as a tool for noise abatement policy evaluation. DRONE involves integrating a road traffic noise estimation model with a traffic simulator to estimate road traffic noise in urban networks. An integrated traffic simulation-noise estimation model provides an interface for direct input of traffic flow properties from simulation model to noise estimation model that in turn estimates the noise on a spatial and temporal scale. The output from DRONE is linked with a geographical information system for visual representation of noise levels in the form of noise contour maps.

Assembling dynamic repertoires of literate practices : teaching that makes a difference

This chapter considers how teachers can make a difference to the kinds of literacy young people take up. Increasingly, researchers and policy-makers see literacy as an ensemble of socio-cultural situated practices rather than as a unitary skill. Accordingly, the differences in what young people come to do with literacy, in and out of school, confront us more directly. If literacy development involves assembling dynamic repertoires of practices, it is crucial to consider what different groups of children growing up and going to school in different places have access to and make investments in over time; the kinds of literate communities from which some are excluded or included; and how educators make a difference to the kinds of literate trajectories and identities young people put together.

Travel behaviour of workers in Dhaka and their attitudes towards road pricing

Dhaka, Bangladesh faces chronic traffic congestion Funding for major infrastructure proves challenging This research is investigating feasibility of adopting: -Road Pricing -with significant Bus Rapid Transit (BRT) project

Road Pricing - Is it Acceptable for a Developing Country?

Dhaka, which is the capital of Bangladesh, is facing serious traffic congestion and whole traffic situation in Dhaka is in chaos. Government has initiated some projects; such as BRT, MRT and elevated expressway; to improve the situation. Road pricing is very popular concept, which can be implemented in Dhaka with BRT and MRT as an integrated manner. Even though it is very popular concept not many countries except some developed countries implemented road pricing practically. None of the developing countries adopted this policy. For success of road pricing it has to be acceptable among the stakeholders. Public are the main stakeholders for road pricing. This paper will explore whether road pricing will be acceptable in Dhaka considering only work trip in Dhaka. A sample of workers had been surveyed randomly. They were asked some demographic questions, such as age, gender, income and educational qualification; how they travelled to work; and whether they would accept road pricing; and if they would not accept road pricing the reasons behind that. Also respondents were given several hypothetical choices to see how respondents react with different road charge by choosing travel mode for their work trip. The methodological approach taken for analysis is qualitative and quantitative analysis. For quantitative analysis Binary Logit Regression analysis was carried out to find out the significant factors for accepting or not accepting road pricing.

Synergies and goal conflicts for climate change policy and spatial planning

The purpose of this paper is to identify goal conflicts – both actual and potential – between climate and social policies in government strategies in response to the growing significance of climate change as a socioecological issue (IPCC 2007). Both social and climate policies are political responses to long-term societal trends related to capitalist development, industrialisation, and urbanisation (Koch, 2012). Both modify these processes through regulation, fiscal transfers and other measures, thereby affecting conditions for the other. This means that there are fields of tensions and synergies between social policy and climate change policy. Exploring these tensions and synergies is an increasingly important task for navigating genuinely sustainable development. Gough et al (2008) highlight three potential synergies between social and climate change policies: First, income redistribution – a traditional concern of social policy – can facilitate use of and enhance efficiency of carbon pricing. A second area of synergy is housing, transport, urban policies and community development, which all have potential to crucially contribute towards reducing carbon emissions. Finally, climate change mitigation will require substantial and rapid shifts in producer and consumer behaviour. Land use planning policy is a critical bridge between climate change and social policy that provides a means to explore the tensions and synergies that are evolving within this context. This paper will focus on spatial planning as an opportunity to develop strategies to adapt to climate change, and reviews the challenges of such change. Land use and spatial planning involve the allocation of land and the design and control of spatial patterns. Spatial planning is identified as being one of the most effective means of adapting settlements in response to climate change (Hurlimann and March, 2012). It provides the instrumental framework for adaptation (Meyer, et al., 2010) and operates as both a mechanism to achieve adaptation and a forum to negotiate priorities surrounding adaptation (Davoudi, et al., 2009). The acknowledged role of spatial planning in adaptation however has not translated into comparably significant consideration in planning literature (Davoudi, et al., 2009; Hurlimann and March, 2012). The discourse on adaptation specifically through spatial planning is described as ‘missing’ and ‘subordinate’ in national adaptation plans (Greiving and Fleischhauer, 2012),‘underrepresented’ (Roggema, et al., 2012)and ‘limited and disparate’ in planning literature (Davoudi, et al., 2009). Hurlimann and March (2012) suggest this may be due to limited experiences of adaptation in developed nations while Roggema et al. (2012) and Crane and Landis (2010) suggest it is because climate change is a wicked problem involving an unfamiliar problem, various frames of understanding and uncertain solutions. The potential for goal conflicts within this policy forum seem to outweigh the synergies. Yet, spatial planning will be a critical policy tool in the future to both protect and adapt communities to climate change.

Emissions trading and the GATS financial services provisions : a case study of the Australian carbon pricing mechanism

Purpose The purpose of this paper is to determine whether greenhouse gas (GHG) tradeable instruments will be classified as financial products within the scope of the World Trade Organization (WTO) law and to explore the implications of this finding. Design/methodology/approach This purpose is achieved through examination of the units of the Australian Carbon Pricing Mechanism (CPM), namely eligible emissions units. These units are analysed through the lens of the definition of financial products provided in the General Agreement for Trade in Services (the GATS). Findings This paper finds that eligible emissions units will be classified as financial instruments, and therefore the provisions that govern their trade will be regulated by the GATS. Considering this, this paper explores the limitations that are introduced by the Australian legislation on the trade of eligible emissions units. Research limitations/implications This paper is limited in its analysis to the Australian CPM. In order to draw conclusions on the issues raised by this analysis it is necessary to consider the WTO requirements against an operating emissions trading scheme. The Australian CPM presents a contemporary model of an appropriate scheme. Originality/value The findings in this paper are crucial in a GHG constrained society. This is because emissions trading schemes are becoming popular measures for pricing GHG emissions, and for this reason the units that are traded and surrendered for emissions liabilities must be classified appropriately on a global scale. Failing to do this could result in differential treatment that may be contrary to the intentions of important global agreements, such as the WTO covered agreements.