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.

Breaking organizational barriers for greening Australian

Sustainability is an issue for everyone. For instance, the higher education sector is being asked to take an active part in creating a sustainable future, due to their moral responsibility, social obligation, and their own need to adapt to the changing higher education environment. By either signing declarations or making public statements, many universities are expressing their desire to become role models for enhancing sustainability. However, too often they have not delivered as much as they had intended. This is particularly evident in the lack of physical implementation of sustainable practices in the campus environment. Real projects such as green technologies on campus have the potential to rectify the problem in addition to improving building performance. Despite being relatively recent innovations, Green Roof and Living Wall have been widely recognized because of their substantial benefits, such as runoff water reduction, noise insulation, and the promotion of biodiversity. While they can be found in commercial and residential buildings, they only appear infrequently on campuses as universities have been very slow to implement sustainability innovations. There has been very little research examining the fundamental problems from the organizational perspective. To address this deficiency, the researchers designed and carried out 24 semi-structured interviews to investigate the general organizational environment of Australian universities with the intention to identify organizational obstacles to the delivery of Green Roof and Living Wall projects. This research revealed that the organizational environment of Australian universities still has a lot of room to be improved in order to accommodate sustainability practices. Some of the main organizational barriers to the adoption of sustainable innovations were identified including lack of awareness and knowledge, the absence of strong supportive leadership, a weak sustainability-rooted culture and several management challenges. This led to the development of a set of strategies to help optimize the organizational environment for the purpose of better decision making for Green Roof and Living Wall implementation.

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.

Were regulatory changes in reporting "abnormal items" justified? : evidence of intra-period classificatory earnings management practices in Australia

Purpose Managers generally have discretion in determining how components of earnings are presented in financial statements in distinguishing between ‘normal’ earnings and items classified as unusual, special, significant, exceptional or abnormal. Prior research has found that such intra-period classificatory choice is used as a form of earnings management. Prior to 2001, Australian accounting standards mandated that unusually large items of revenue and expense be classified as ‘abnormal items’ for financial reporting, but this classification was removed from accounting standards from 2001. This move by the regulators was partly in response to concerns that the abnormal classification was being used opportunistically to manage reported pre-abnormal earnings. This study extends the earnings management literature by examining the reporting of abnormal items for evidence of intra-period classificatory earnings management in the unique Australian setting. Design/methodology/approach This study investigates associations between reporting of abnormal items and incentives in the form of analyst following and the earnings benchmarks of analysts’ forecasts, earnings levels, and earnings changes, for a sample of Australian top-500 firms for the seven-year period from 1994 to 2000. Findings The findings suggest there are systematic differences between firms reporting abnormal items and those with no abnormal items. Results show evidence that, on average, firms shifted expense items from pre-abnormal earnings to bottom line net income through reclassification as abnormal losses. Originality/value These findings suggest that the standard setters were justified in removing the ‘abnormal’ classification from the accounting standard. However, it cannot be assumed that all firms acted opportunistically in the classification of items as abnormal. With the removal of the standardised classification of items outside normal operations as ‘abnormal’, firms lost the opportunity to use such disclosures as a signalling device, with the consequential effect of limiting the scope of effectively communicating information about the nature of items presented in financial reports.

Design of flight avoidance manoeuvre alphabets for mixed centralised-decentralised separation management

This paper investigates a mixed centralised-decentralised air traffic separation management system, which combines the best features of the centralised and decentralised systems whilst ensuring the reliability of the air traffic management system during degraded conditions. To overcome communication band limits, we propose a mixed separation manager on the basis of a robust decision (or min-max) problem that is posed on a reduced set of admissible flight avoidance manoeuvres (or a FAM alphabet). We also present a design method for selecting an appropriate FAM alphabet for use in the mixed separation management system. Simulation studies are presented to illustrate the benefits of our proposed FAM alphabet based mixed separation manager.

A situated approach to historical thinking in the Australian Curriculum : History

This paper focuses on the importance of foregrounding an emphasis on the development of historical thinking in the implementation of the Australian Curriculum: History as a way of making the study of history meaningful for their students. In doing so, it argues that teachers need to take up the opportunity to situate the study of Asia as a significant component of the curriculum’s ‘Australia in a world history approach’. In the discussion on the significance of historical thinking, the paper specifically addresses those seven historical concepts articulated in the new history curriculum by drawing from the international scholarship in the field of history education on the ways in which children and adolescents think about historical content and concepts.

Entrepreneurship education in non-business schools : best practice for Australian contexts of knowledge and innovation communities (Final Report)

In the current era of global economic instability, business and industry have already identified a widening gap between graduate skills and employability. An important element of this is the lack of entrepreneurial skills in graduates. This Teaching Fellowship investigated two sides of a story about entrepreneurial skills and their teaching. Senior players in the innovation commercialisation industry, a high profile entrepreneurial sector, were surveyed to gauge their needs and experiences of graduates they employ. International contexts of entrepreneurship education were investigated to explore how their teaching programs impart the skills of entrepreneurship. Such knowledge is an essential for the design of education programs that can deliver the entrepreneurial skills deemed important by industry for future sustainability. Two programs of entrepreneurship education are being implemented at QUT that draw on the best practice exemplars investigated during this Fellowship. The QUT Innovation Space (QIS) focuses on capturing the innovation and creativity of students, staff and others. The QIS is a physical and virtual meeting and networking space; a connected community enhancing the engagement of participants. The Q_Hatchery is still embryonic; but it is intended to be an innovation community that brings together nascent entrepreneurial businesses to collaborate, train and support each other. There is a niche between concept product and business incubator where an experiential learning environment for otherwise isolated ‘garage-at-home’ businesses could improve success rates. The QIS and the Q_Hatchery serve as living research laboratories to trial the concepts emerging from the skills survey. The survey of skills requirements of the innovation commercialisation industry has produced a large and high quality data set still being explored. Work experience as an employability factor has already emerged as an industry requirement that provides employee maturity. Exploratory factor analysis of the skills topics surveyed has led to a process-based conceptual model for teaching and learning higher-order entrepreneurial skills. Two foundational skills domains (Knowledge, Awareness) are proposed as prerequisites which allow individuals with a suite of early stage entrepreneurial and behavioural skills (Pre-leadership) to further leverage their careers into a leadership role in industry with development of skills around higher order elements of entrepreneurship, management in new business ventures and progressing winning technologies to market. The next stage of the analysis is to test the proposed model through structured equation modelling. Another factor that emerged quickly from the survey analysis broadens the generic concept of team skills currently voiced in Australian policy documents discussing the employability agenda. While there was recognition of the role of sharing, creating and using knowledge in a team-based interdisciplinary context, the adoption and adaptation of behaviours and attitudes of other team members of different disciplinary backgrounds (interprofessionalism) featured as an issue. Most undergraduates are taught and undertake teamwork in silos and, thus, seldom experience a true real-world interdisciplinary environment. Enhancing the entrepreneurial capacity of Australian industry is essential for the economic health of the country and can only be achieved by addressing the lack of entrepreneurial skills in graduates from the higher education system. This Fellowship has attempted to address this deficiency by identifying the skills requirements and providing frameworks for their teaching.

Australian higher education evaluation through assurance of learning

A collaborative research project conducted by five Australian universities inquired into the philosophy and motivation for Assurance of Learning (AoL) as a process of education evaluation. Associate Deans Teaching and Learning representing Business schools from twenty-five universities across Australia participated in telephone interviews. Data was analysed using NVIVO9. Results indicated that articulated rationale for AoL was both ensuring that students had acquired the attributes and skills the universities claimed they had, and the philosophy of continuous improvement. AoL was motivated both by ritualistic objectives to satisfy accreditation requirements and virtuous agendas for quality improvement. Closing-the-loop was emphasised, but was mostly wishful thinking for next steps beyond data collection and reporting. AoL was conceptualised as one element within the larger context of quality review, but there was no evidence of comprehensive frameworks or strategic plans.

Assurance of learning – are academics and senior management singing from the same hymn sheet?

Assurance of learning (AoL) is an important process in quality education, designed to measure the accomplishment of educational aims at the core of an institution’s programs, whilst encouraging faculty to continuously develop and improve the programs and courses. This paper reports on a study of Australian business schools to investigate current AoL practices through semi structured interviews with senior faculty leaders followed by focus group interviews with groups of senior program leaders and groups of academic teaching staff. Initial findings indicate there are significant challenges in encouraging academic staff to commit to the process and recognise the benefits of assuring learning. The differences in understanding between the various leaders and the academics were highlighted through the different focus groups. Leaders’ stressed strategic issues such as staff engagement and change, while academics focussed on process issues such as teaching graduate attributes and external accreditation. Understanding the differences in the perspectives of leaders and faculty is important, as without a shared understanding between the two groups, there is likely to be limited engagement, which creates difficulties in developing effective assurance of learning processes. Findings indicate that successful strategies developed to foster shared values on assurance of learning include: strong senior leaders’ commitment; developing champions among program and unit level staff; providing professional development opportunities; promoting and celebrating success and effectiveness; and ensuring an inclusive process with academics of all levels collaborating in the development and implementation of the process.

As trajetorias de carreiras tradicionais estao dando passegem as proteanas? Um estudo com gereentes no setor public Australiano com foco em diferencas quanto ao genero ( Have traditional career paths given way to protean ones?: Evidence from senior managers in the Australian public sector)

Purpose – This mixed-method study aims to determine the extent to which the career paths of senior managers conform with the traditional versus protean elements described in the careers literature and whether these paths vary by gender. Design/methodology/approach – A total of 15 senior managers (seven women and eight men) in a large public sector agency in Australia were interviewed about their career trajectories to date. Data were coded according to four major areas which characterise and distinguish between traditional and protean careers: development, orientation of the employee, definition of success, and organisational environment. A total of 81 managers (34 women and 47 men) from the same organisation were also surveyed. Variables of interest were those that could be triangulated with qualitative data such as the availability of career opportunities. Findings – Results suggest that, contrary to much existing literature which proposes that all careers have been fundamentally altered, the traditional career which relies on length of service, geographic mobility and a steady climb up the corporate ladder, is still the dominant model in some organisations. However, the trend towards protean careers is evident and is more pronounced for women than for men. Research limitations/implications – The specific nature of the organisation (large, male-dominated, public sector) may limit the generalisability of results. Practical implications – The framework used to explore career paths according to traditional/ protean elements in this study may assist human resource practitioners to develop appropriate strategies which maximise the professional development of employees. Originality/value – The results of this research challenge the universality of change in the nature of careers, particularly in public sector environments.