Double tax agreements and the international allocation of business income in Australia

Increasingly, the effectiveness of the present system of taxation of international businesses is being questioned. The problem associated with the taxation of such businesses is twofold. A system of international taxation must be a fair and equitable system, distributing profits between the relevant jurisdictions and, in doing so, avoiding double taxation. At the same time, the prevention of fiscal evasion must be secured. In an attempt to achieve a fair and equitable system Australia adopts unilateral, bilateral and multilateral measures to avoid double taxation and restrict the avoidance of tax. The first step in ascertaining the international allocation of business income is to consider the taxation of business income according to domestic law, that is, the unilateral measures. The treatment of international business income under the Australian domestic law, that is, the Income Tax Assessment Act 1936 (Cth) and Income Tax Assessment Act 1997 (Cth), will depend on two concepts, first, whether the taxpayer is a resident of Australia and secondly, whether the income is sourced in Australia. After the taxation of business profits has been determined according to domestic law it is necessary to consider the applicability of the bilateral measures, that is, the Double Tax Agreements (DTAs) to which Australia is a party, as the DTAs will override the domestic law where there is any conflict. Australia is a party to 40 DTAs with another seven presently being negotiated. The preamble to Australia's DTAs provides that the purpose of such agreements is 'to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income'. Both purposes, for different reasons, are equally important. It has been said that: The taxpayer hopes the treaty will prevent the double taxation of his income; the tax gatherer hopes the treaty will prevent fiscal evasion; and the politician just hopes. The first purpose, the avoidance of double taxation, is achieved through the provision of rules whereby the Contracting States agree to the classification of income and the allocation of that income to a particular State. In this sense DTAs do not allocate jurisdiction to tax but rather provide an arrangement whereby the States agree to restrict their substantive law. The restriction is either through the non-taxing of the income or via the provision of a tax credit.

Business process variability modeling : A survey

It is common for organizations to maintain multiple variants of a given business process, such as multiple sales processes for different products or multiple bookkeeping processes for different countries. Conventional business process modeling languages do not explicitly support the representation of such families of process variants. This gap triggered significant research efforts over the past decade leading to an array of approaches to business process variability modeling. This survey examines existing approaches in this field based on a common set of criteria and illustrates their key concepts using a running example. The analysis shows that existing approaches are characterized by the fact that they extend a conventional process mod- eling language with constructs that make it able to capture customizable process models. A customizable process model represents a family of process variants in a way that each variant can be derived by adding or deleting fragments according to configuration parameters or according to a domain model. The survey puts into evidence an abundance of customizable process modeling languages, embodying a diverse set of con- structs. In contrast, there is comparatively little tool support for analyzing and constructing customizable process models, as well as a scarcity of empirical evaluations of languages in the field.

The next generation health intervention tool - Can smart phone applications help young people track and moderate alcohol use and potential harms?

Whilst alcohol is a common feature of many social gatherings, there are numerous immediate and long-term health and social harms associated with its abuse. Alcohol consumption is the world’s third largest risk factor for disease and disability with almost 4% of all deaths worldwide attributed to alcohol. Not surprisingly, alcohol use and binge drinking by young people is of particular concern with Australian data reporting that 39% of young people (18-19yrs) admitted drinking at least weekly and 32% drank to levels that put them at risk of alcohol-related harm. The growing market penetration and connectivity of smartphones may be an opportunities for innovation in promoting health-related self-management of substance use. However, little is known about how best to harness and optimise this technology for health-related intervention and behaviour change. This paper explores the utility and interface of smartphone technology as a health intervention tool to monitor and moderate alcohol use. A review of the psychological health applications of this technology will be presented along with the findings of a series of focus groups, surveys and behavioural field trials of several drink-monitoring applications. Qualitative and quantitative data will be presented on the perceptions, preferences and utility of the design, usability and functionality of smartphone apps to monitoring and moderate alcohol use. How these findings have shaped the development and evolution of the OnTrack app will be specifically discussed, along with future directions and applications of this technology in health intervention, prevention and promotion.

Development and validation of an instrument to measure organizational cultures' support of business process management

The purpose of Business Process Management (BPM) is to increase the efficiency and effectiveness of organizational processes through improvement and innovation. Despite a common understanding that culture is an important element in these efforts, there is a dearth of theoretical and empirical research on culture as a facilitator of successful BPM. We develop the BPM culture construct and propose a validated instrument with which to measure organizational cultures’ support of BPM. The operationalization of the BPM culture concept provides a theoretical foundation for future research and a tool to assist organizations in developing a cultural environment that supports successful BPM.

Capping them off! Exploring and explaining the patterns in undergraduate capstone subjects in Australian business schools

Universities are increasingly offering capstone subjects as part of curricula to prepare final year undergraduates for employment through consolidating and integrating their knowledge and skills while bridging the gap between academic learning and professional work. This study investigates capstone subjects offered by Australian business schools, drawing on national survey data collected in 2010-2011, complemented by interviews with associate deans teaching and learning instrumental in course and curricula design. Findings indicate the sector-wide use of capstone subjects in business disciplines, diversity in the patterns of offerings, and instances where subjects labelled as capstones do not meet the definition of capstones. We argue that these features are explained by a range of historic and strategic factors, such as the ad hoc development of subjects and a lack of understanding of the features of capstones. The findings of this paper inform the debate on the design, development, value and use of capstone subjects identifying the implications for staff development and knowledge management in higher education.

Culture in global business transformation projects : the discovery of a grounded theory

Presently organisations engage in what is termed as Global Business Transformation Projects [GBTPs], for consolidating, innovating, transforming and restructuring their processes and business strategies while undergoing fundamental change. Culture plays an important role in global business transformation projects as these involve people of different cultural backgrounds and span across countries, industries and disciplinary boundaries. Nevertheless, there is scant empirical research on how culture is conceptualised beyond national and organisational cultures but also on how culture is to be taken into account and dealt with within global business transformation projects. This research is situated in a business context and discovers a theory that aids in describing and dealing with culture. It draws on the lived experiences of thirty-two senior management practitioners, reporting on more than sixty-one global business transformation projects in which they were actively involved. The research method used is a qualitative and interpretive one and applies a grounded theory approach, with rich data generated through interviews. In addition, vignettes were developed to illustrate the derived theoretical models. The findings from this study contribute to knowledge in multiple ways. First, it provides a holistic account of global business transformation projects that describe the construct of culture by the elements of culture types, cultural differences and cultural diversity. A typology of culture types has been developed which enlarges the view of culture beyond national and organisational culture including an industry culture, professional service firm culture and 'theme' culture. The amalgamation of the culture types instantiated in a global business transformation project compromises its project culture. Second, the empirically grounded process for managing culture in global business transformation projects integrates the stages of recognition, understanding and management as well as the enablement providing a roadmap for dealing with culture in global business transformation projects. Third, this study identified contextual variables to global business transformation projects, which provide the means of describing the environment global business transformation projects are situated, influence the construct of culture and inform the process for managing culture. Fourth, the contribution to the research method is the positioning of interview research as a strategy for data generation and the detailed documentation applying grounded theory to discover theory.

ACE research vignette 025 : Is business planning important for entrepreneurial success?

This series of research vignettes is aimed at sharing current and interesting research findings from our team of international Entrepreneurship researchers. This vignette, written by Professor Per Davidsson, takes a closer look at the value of business planning.

On effective accounting information systems in a dynamic business environment : the role of complementing capabilities

The global business environment is witnessing tough times, and this situation has significant implications on how organizations manage their processes and resources. Accounting information system (AIS) plays a critical role in this situation to ensure appropriate processing of financial transactions and availability to relevant information for decision-making. We suggest the need for a dynamic AIS environment for today’s turbulent business environment. This environment is possible with a dynamic AIS, complementary business intelligence systems, and technical human capability. Data collected through a field survey suggests that the dynamic AIS environment contributes to an organization’s accounting functions of processing transactions, providing information for decision making, and ensuring an appropriate control environment. These accounting processes contribute to the firm-level performance of the organization. From these outcomes, one can infer that a dynamic AIS environment contributes to organizational performance in today’s challenging business environment.

Cost-aware business process management: A research agenda

Organisations are constantly seeking cost-effective improvements for their business processes. Business process management (BPM) provides organisations with a range of methods, techniques and tools for analysing, managing, and optimising their business operations. However, BPM initiatives within organisations tend to focus on investigating time and resource utilisation inefficiencies, rather than directly on cost inefficiencies. As a result, high-level cost-based managerial decisions are still being made separately from process related decisions. This position paper describes a research agenda that envisages a holistic approach to managing the cost of business operations in a structured manner, by making an explicit link between cost and processes in all phases of the business process management life cycle. We discuss a number of research challenges that need to be addressed in order to realise such an approach as well as findings from some of the initial research outcomes. It is envisioned that the research outcomes will enable organisations to make operational and strategic decisions with confidence based on accurate and real-time cost information about their operations.

Designing innovative business models: Five emerging meta-models

Business models to date have remained the creation of management, however, it is the belief of the authors that designers should be critically approaching, challenging and creating new business models as part of their practice. This belief portrays a new era where business model constructs become the new design brief of the future and fuel design and innovation to work together at the strategic level of an organisation. Innovation can no longer rely on technology and R&D alone but must incorporate business models. Business model innovation has become a strong type of competitive advantage. As firms choose not to compete only on price, but through the delivery of a unique value proposition in order to engage with customers and to differentiate a company within a competitive market. The purpose of this paper is to explore and investigate business model design through various product and/or service deliveries, and identify common drivers that are catalysts for business model innovation. Fifty companies spanning a diverse range of criteria were chosen, to evaluate and compare commonalities and differences in the design of their business models. The analysis of these business cases uncovered commonalities of the key strategic drivers behind these innovative business models. Five Meta Models were derived from this content analysis: Customer Led, Cost Driven, Resource Led, Partnership Led and Price Led. These five key foci provide a designer with a focus from which quick prototypes of new business models are created. Implications from this research suggest there is no ‘one right’ model, but rather through experimentation, the generation of many unique and diverse concepts can result in greater possibilities for future innovation and sustained competitive advantage.

Can emotion provide a new approach to business model innovation?

Companies require new strategies to drive growth and survival, as the fast pace of change has created the need for greater business flexibility. Therefore, industry leaders are looking to business innovation as a principle source of differentiation and competitive advantage. However, most companies rely heavily on either technology or products to provide business innovation, yet competitors can easily and rapidly surpass these forms of innovation. Business model innovation expands beyond innovation in isolated areas, such as product innovation, to create strategies that incorporate many business avenues to work together to create and deliver value to its customers. Existing literature highlights that a business model’s central role is ‘customer value’. However, the emotional underpinnings of customer value within a business model are not well understood. The integration of customer emotion into business model design and value chain can be viewed as a way to innovate beyond just products, services and processes. This paper investigates the emotional avenues within business strategy and operations, business model innovation and customer engagement. Three propositions are outlined and explored as future research. The significance of this research is to provide companies with a new approach to innovation through a deeper understanding and integration of their customers’ emotions.

A business engineering approach to client relationship management in a knowledge based firm

This thesis examines Customer Relationship Management and how the capabilities of an organisation to innovate can be enhanced via its implementation in a Knowledge Based Firm. The research identifies current customer knowledge components within an organisation and identifies for future use, CRM components for implementation within a Knowledge Based Firm. Opinions from a panel of experts' are identified for best practice customer relationship strategy, the most important CRM processes and identification of customer knowledge components that will form the basis of implementing a successful CRM to gain a competitive advantage through enhancing the innovative capability for a Knowledge Based Firm.

Capturing opportunities for business and innovation in knowledge intensive services

Research on opportunity has been extensively studied in contexts of new firm or new venture creation (Choi & Shepherd, 2004; Mullins & Forlani, 2005; Ozgen & Baron, 2007) where start-ups and new ventures use both opportunity discovery and opportunity creation (Alvarez & Barney 2005, 2007). Less research is found on examining the relationship between opportunity and innovation in existing firms (with Drucker (1985) an exception). In large firms, opportunity recognition has been analysed in terms of antecedent conditions, elements and outcomes (Ireland, Covin & Kuratko, 2009), but to date less attention has been given to how small and medium enterprises capture and use opportunities to remain competitive. Little research has been carried out regarding how smaller firms use opportunities to create new business with existing customers or use technological advances with new customers to create new economic activity, growth and competitive advantage. This study presents findings from a comparative case analysis of 20 diverse firms in the spatial information industry and identifies constructs associated with identifying opportunities that lead to better business performance and firm level innovation.

A case study analysis of Israeli Organised Crime (IOC) (1990-2005) : applying the Crime Business Analysis Matrix (CBAM)

Israeli Organised Crime (IOC) gained prominence in the 1990s for its involvement in the manufacturing and wholesale distribution of MDMA through traditional trafficking networks across Europe. Equipped with astute business acumen and an entrepreneurial spirit, IOC dominated MDMA trafficking in Europe for more than a decade and remains as a major participant in this drug market. The paper analyses the entrepreneurial activities of IOC within the context of the MDMA market in Europe between 1990 and 2005 using the Crime Business Analysis Matrix (CBAM) as proffered by Dean, et al (2010). The study is in two parts. Part A provides a review of the literature as it pertains to IOC and its involvement in the European drug market, while Part B provides a qualitative analysis of their criminal business practices and entrepreneurialism of IOC within this context.