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.

A roadside survey of unlicensed driving in Queensland

Unlicensed driving remains a serious problem in many jurisdictions, and while it does not play a direct causative role in road crashes, it undermines driver licensing systems and is linked to other high risk driving behaviours. Roadside licence check surveys represent the most direct means of estimating the prevalence of unlicensed driving. The current study involved the Queensland Police Service (QPS) checking the licences of 3,112 drivers intercepted at random breath testing operations across Queensland between February and April 2010. Data was matched with official licensing records from Transport and Main Roads (TMR) via the drivers’ licence number. In total, 2,914 (93.6%) records were matched, with the majority of the 198 unmatched cases representing international or interstate licence holders (n = 156), leaving 42 unknown cases. Among the drivers intercepted at the roadside, 20 (0.6%) were identified as being unlicensed at the time, while a further 11 (0.4%) were driving unaccompanied on a Learner Licence. However, the examination of TMR licensing records revealed that an additional 9 individuals (0.3%) had a current licence sanction but were not identified as unlicensed by QPS. Thus, in total 29 of the drivers were unlicensed at the time, representing 0.9% of all the drivers intercepted and 1% of those for whom their licence records could be checked. This is considerably lower than the involvement of unlicensed drivers in fatal and serious injury crashes in Queensland, which is consistent with other research confirming the increased crash risk of the group. However, the number of unmatched records suggest that it is possible the on-road survey may have under-estimated the prevalence of unlicensed driving, so further development of the survey method is recommended.

Optimising meritocratic advantage with the International Baccalaureate Diploma in Australian schools

This paper explores two of the tensions Tarc (2009) identifies in the history of the International Baccalaureate (IB) Diploma: firstly between its design for meritocratic competition and its internationalist vision; and secondly between the IB as a global commodity and its localised interpretations. Using data from three case studies of Australian schools offering both the IB Diploma and the local government curriculum, and student responses to an online survey across 26 such schools, the analysis shows how choices behind the IB’s growing popularity foreground strategies for optimising meritocratic competition. Framed through Bourdieu’s concepts of field and ‘rules of the game’, the analysis shows how students act on their own comparative analyses of each curriculum to optimise their chances to access desirable university pathways within the local rules of the game for university placement. Schools are shown to offer the IB Diploma to recruit and retain academically ambitious students by pooling their relative advantage in different local ecologies. Students are shown to carefully evaluate the benefits and costs of the IB choice. The conclusion reflects on how the choice of the IB Diploma for meritocratic advantage by some might change conditions for others not choosing it.

Tax concessions in support of charitable giving: an international comparison

The Australian taxation system encourages charitable giving through tax deductibility for donations made by individuals and companies, and via tax exemption for income distributed to charities through charitable trusts. Other means of giving, such as through bequests enjoy little tax concessions...

“They’re lunatics on the road” : Exploring the normative influences of parents, friends, and police on young novices’ risky driving decisions

Purpose: Young novice drivers experience significantly greater risk of being injured or killed in car crashes than older more experienced drivers. This research utilised a qualitative approach guided by the framework of Akers’ social learning theory. It explored young novice drivers’ perspectives on risky driving including rewards and punishments expected from and administered by parents, friends, and police, imitation of parents’ and friends’ driving, and advantages and disadvantages of risky driving. Methods: Twenty-one young drivers (12 females, 9 males) aged 16–25 years (M = 17.71 years, SD = 2.15) with a Learner (n = 11) or Provisional (n = 10) driver licence participated in individual or small group interviews. Findings and conclusions: Content analysis supported four themes: (1) rewards and (2) punishments for risky driving, and the influence of (3) parents and (4) friends. The young novice drivers differed in their vulnerability to the negative influences of friends and parents, with some novices advising they were able to resist risky normative influences whilst others felt they could not. The authority of the police as enforcers of road rules was either accepted and respected or seen as being used to persecute young novices. These findings suggest that road safety interventions should consider the normative influence of parents and friends on the risky and safe behaviour of young novices. Police were also seen as influential upon behaviour. Future research should explore the complicated relationship between parents, friends, the police, young novices, and their risky driving behaviour.

Environmental reporting in the Australian mining industry : complying with regulation or meeting international best practice?

It is nearly 10 years since the introduction of s 299(1)(f) Corporations Act , which requires the disclosure of information regarding a company's environmental performance within its annual report. This provision has generated considerable debate in the years since its introduction, fundamentally between proponents of either a voluntary or mandatory environmental reporting framework. This study examines the adequacy of the current regulatory framework. The environmental reporting practices of 24 listed companies in the resources industries are assessed relative to a standard set by the Global Reporting Initiative (GRI) Sustainability Reporting Guidelines. These Guidelines are argued to represent "international best practice" in environmental reporting and a "scorecard" approach is used to score the quality of disclosure according to this voluntary benchmark. Larger companies in the sample tend to report environmental information over and above the level required by legislation. Some, but not all companies present a stand-alone environmental/sustainability report. However, smaller companies provide minimal information in compliance with s 299(1)(f) . The findings indicate that "international best practice" environmental reporting is unlikely to be achieved by Australian companies under the current regulatory framework. In the current regulatory environment that scrutinises s 299(1)(f) , this article provides some preliminary evidence of the quality of disclosures generated in the Australian market.

Teachers’ work in curricular markets : conditions of design and relations between the International Baccalaureate Diploma and the local curriculum

School level strategy enabled by neoliberal choice policies can produce internal curricular markets whereby branded curricula such as the International Baccalaureate are offered alongside the local government curriculum in the same school. This project investigated how such curricular markets operating in Australian schools impacted on teachers’ work. This paper reports on teachers work in three case study schools that offered both the International Baccalaureate Diploma program and the local senior schooling curriculum, then draws on an online survey of 225 teachers in 26 such schools across Australia. The analysis reveals the impact of curricular markets along two dimensions: the curriculum’s internal design; and the relational aspects of how schools manage to deliver tandem offerings within institutional constraints. Teachers working in the IBD Diploma program were shown to relish its design, despite additional demands, while teachers working in just the local curriculum reported more relational issues. The paper argues that these trends suggest that there are winners and losers emerging in the work conditions produced by curricular markets.  

Not-for-profit ratios for financial resilience and internal accountability : a study of Australian international aid organisations

Not-for-profit (NFP) financial ratio research has focused primarily on organisational efficiency measurements for external stakeholders. Ratios that also capture information about stability, capacity (liquidity), gearing and sustainability, enable an assessment of financial resilience. They are thus valuable tools that can provide a framework of internal accountability between boards and management. The establishment of an Australian NFP regulator highlights the importance of NFP sustainability, and affirms the timeliness of this paper. We propose a suite of key financial ratios for use by NFP boards and management, and demonstrate its practical usefulness by applying the ratios to financial data from the 2009 reports of ACFID (Australian Council for International Development)-affiliated international aid organisations.

Road safety in Singapore

Singapore is a highly developed country that has a well connected island-wide road transport system including a network of expressways. The road standards of Singapore are generally good and road safety level is very high by international standards. This chapter discusses road safety status in Singapore and highlights the practices that have been undertaken to enhance the road safety. Statistics show that road traffic fatalities were decreasing over the years, albeit an increasing trend for total crashes. Motorcyclists and pedestrians were two vulnerable road user groups and shared significant proportions respectively about 49% and 28% of total road traffic deaths. In particular, young riders and pedestrians had a higher crash potential. To enhance safety of those vulnerable road users, Singapore has taken several initiatives including infrastructure improvements like paving better skid-resistant materials at crash-prone sites, providing more rain shelters for motorcyclists, and installation of reflective signs and markings near school zones; safety campaigns and awareness programs like ride safe programme, the road courtesy campaign, and the anti-drink drive campaign. While Land Transport Authority (LTA) looks into road safety through engineering solutions and road infrastructure developments, the Traffic Police of Singapore is responsible for law enforcements and regulations. A number of non-government organizations, private companies, and university research groups are also continuously working with the Traffic Police to study, promote, and educate the general public on road safety matters.