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.

Current research in risk-aware business process management : overview, comparison, and gap analysis

The management of risks in business processes has been a subject of active research in the past few years. Many benefits can potentially be obtained by integrating the two traditionally-separated fields of risk management and business process management, including the ability to minimize risks in business processes (by design) and to mitigate risks at run time. In the past few years, an increasing amount of research aimed at delivering such an integrated system has been proposed. However, these research efforts vary in terms of their scope, goals, and functionality. Through systematic collection and evaluation of relevant literature, this paper compares and classifies current approaches in the area of risk-aware business process management in order to identify and explain relevant research gaps. The process through which relevant literature is collected, filtered, and evaluated is also detailed.

Best practice business community partnerships

In the last two years or so, the Prime Minister has made the development of a social coalition, involving business partnerships with the community, central to his Government’s vision of a fair and just Australian society. This is clearly a new and exciting era in thinking for government, business and community partnerships. However, there has been a tendency, particularly in the media reporting of these initiatives, especially the Prime Minister's Business Community Partnership awards held in 1999 and in July this year, to concentrate the agenda more on philanthropy and corporate donations, than on some of the many other ways that partnerships can develop...

Creating and evaluating IT-related business value in developing markets : part 1

There is no doubt that information technology (IT) resources are important for organisations in any jurisdiction to manage their processes. Organisations consume considerable financial resources to acquire and manage their IT resources with various IT governance structures. Investment in IT, thus, is a strategic necessity. IT resources, however, do not contribute fully to business value on their own. Business value considers performance impacts of resources at various organisational levels (e.g., processes and firm levels). ITs are biased resources in that they require some form of manipulation to attain their maximum value. While we know that IT resources are important, a deeper understanding on two aspects of use of IT resources in organisations is important. First, is how to leverage the IT resources to attain its maximum value, and second, is where to evaluate IT-related business value in the organisation’s value chain. This understanding is important for organisation to sustain their operations in an ever-changing business environment. We address these issues in two parts. This paper discusses the first aspect of ways in which organisations can create and sustain their IT-related business value.

Creating and evaluating IT-related business value in developing markets - Part 2

A deeper understanding on two aspects of use of IT resources in organisations is important to ensure sustainable investment in these IT resources. The first is how to leverage the IT resources to attain its maximum value. We discussed this aspect of use of IT resources in part 1 of this series. This discussion suggested a complementary approach as a first stage of IT business value creation, and dynamic capabilities approach to secure sustainable IT-related business value from the IT resources. The second important aspect of IT business value is where to evaluate IT-related business value in the organisations value chains. This understanding is important for organisations to ensure appropriate accountability of the investment and management of IT resources. We address this issue in this second part of the two part series.

Profit and organisational legitimacy in an emerging market

While there is common acknowledgement that the main aim of organisations is to maximise shareholder wealth, firms also have the obligation to manage the needs of a broader group of stakeholders as these firms are a product of social creation. In this study, we test the notion that the concept, profit, is fundamental to society’s perception of the firm in an emerging market, and the need for a firm to legitimise a level of profit. We evaluate the relationship between the readability of various components of corporate annual reports and the level of profit, and we also take into account the nature of disclosure (mandatory and non-mandatory), the size of the firm and the nature of setup (public enterprises and publicly listed companies). Our findings suggest that, as with developed markets, in emerging markets profit is indeed an important determinant of the nature of operations of a firm, and that firms consider readability of their disclosures in attempting to legitimise a level of profit.

From product innovation to organizational innovation – and what that has to do with Business Process Management

One of the key trends that we currently witness not only in academic circles but also in industry - all throughout Australia at least – is that “Innovation” is becoming an important driver for business projects, for change agendas – and in turn, for Business Process Management initiatives.

A ‘service logic’ rationale for business model innovation

Successful firms use business model innovation to rethink the way they do business and transform industries. However, current research on business model innovation is lacking theoretical underpinnings and is in need of new insights. This objective of this paper is to advance our understanding of both the business model concept and business model innovation based on service logic as foundation for customer value and value creation. We present and discuss a rationale for business models based on ‘service logic’ with service as a value-supporting process and compared it with a business model based on ‘goods logic’ with goods as value-supporting resources. The implications for each of the business model dimensions: customer, value proposition, organizational architecture and revenue model, are described and discussed in detail.

Chinese online literature : creative consumers and evolving business models

Purpose – The internet is transforming possibilities for creative interaction, experimentation and cultural consumption in China and raising important questions about the role that “publishers” might play in an open and networked digital world. The purpose of this paper is to consider the role that copyright is playing in the growth of a publishing industry that is being “born digital”. Design/methodology/approach – The paper approaches online literature as an example of a creative industry that is generating value for a wider creative economy through its social network market functions. It builds on the social network market definition of the creative industries proposed by Potts et al. and uses this definition to interrogate the role that copyright plays in a rapidly-evolving creative economy. Findings – The rapid growth of a market for crowd-sourced content is combining with growing commercial freedom in cultural space to produce a dynamic landscape of business model experimentation. Using the social web to engage audiences, generate content, establish popularity and build reputation and then converting those assets into profit through less networked channels appears to be a driving strategy in the expansion of wider creative industries markets in China. Originality/value – At a moment when publishing industries all over the world are struggling to come to terms with digital technology, the emergence of a rapidly-growing area of publishing that is being born digital offers important clues about the future of publishing and what social network markets might mean for the role of copyright in a digital age.

Factors influencing the adoption of information technology in a construction business

Construction firms are increasingly utilizing information technologies to better manage geographically dispersed projects. Often these technologies involve changes to existing working practices and processes and are viewed as disruptive by members of the organization. Understanding the factors that can influence individuals’ intention to utilize technology can assist managers to implement strategies to increase and improve the uptake of technologies and improve the innovation adoption process. Using a case study organization, factors identified in the Unified Theory of Acceptance and Use of Technology (UTAUT) are examined and the UTAUT is extended and by including resistance to change and top management support. The findings indicate effort expectancy, internal facilitating conditions and top management support all influence individuals’ intention to use information technology. The results also show that resistance to change or fear of change does not always play a role in innovation adoption. The findings reinforce the need to support new technologies from both a managerial and technical perspective.

Modeling and analyzing the carbon footprint of business processes

Many corporations and individuals realize that environmental sustainability is an urgent problem to address. In this chapter, we contribute to the emerging academic discussion by proposing two innovative approaches for engaging in the development of environmentally sustainable business processes. Specifically, we describe an extended process modeling approach for capturing and documenting the dioxide emissions produced during the execution of a business process. For illustration, we apply this approach to the case of a government Shared Service provider. Second, we then introduce an analysis method for measuring the carbon dioxide emissions produced during the execution of a business process. To illustrate this approach, we apply it in the real-life case of a European airport and show how this information can be leveraged in the re-design of "green" business processes.

Business Process Data Compliance

Most approaches to business process compliance are restricted to the analysis of the structure of processes. It has been argued that full regulatory compliance requires information on not only the structure of processes but also on what the tasks in a process do. To this end Governatori and Sadiq[2007] proposed to extend business processes with semantic annotations. We propose a methodology to automatically extract one kind of such annotations; in particular the annotations related to the data schema and templates linked to the various tasks in a business process.