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.

Management accounting adaptability in an integrated information system environment

In this study, we explore the relationship between the qualities of the information system environment and management accounting adaptability. The information system environment refers to three distinct elements: the degree of information system integration, system flexibility, and shared knowledge between business unit managers and the IT function. We draw on the literature on integrated information systems (IIS) and management accounting change and propose a model to test the hypothesized relationships. The sample for this study consists of Australian companies from all industries.

The Rise of the BASIC Group Within the International Climate Regime : The Challenge of Ensuring Equitable Mitigation Obligations

The chapter examines the current emission reduction obligations within the climate regime. It looks at the formation and rise of the BASIC negotiation group within the international climate COP negotiations and examines the role that BASIC nations are now playing shaping international mitigation policy.

Second international workshop on theory and applications of process visualization

The representation of business process models has been a continuing research topic for many years now. However, many process model representations have not developed beyond minimally interactive 2D icon-based representations of directed graphs and networks, with little or no annotation for information overlays. In addition, very few of these representations have undergone a thorough analysis or design process with reference to psychological theories on data and process visualization. This dearth of visualization research, we believe, has led to problems with BPM uptake in some organizations, as the representations can be difficult for stakeholders to understand, and thus remains an open research question for the BPM community. In addition, business analysts and process modeling experts themselves need visual representations that are able to assist with key BPM life cycle tasks in the process of generating optimal solutions. With the rise of desktop computers and commodity mobile devices capable of supporting rich interactive 3D environments, we believe that much of the research performed in computer human interaction, virtual reality, games and interactive entertainment have much potential in areas of BPM; to engage, provide insight, and to promote collaboration amongst analysts and stakeholders alike. We believe this is a timely topic, with research emerging in a number of places around the globe, relevant to this workshop. This is the second TAProViz workshop being run at BPM. The intention this year is to consolidate on the results of last year's successful workshop by further developing this important topic, identifying the key research topics of interest to the BPM visualization community.

International corporate entrepreneurship among SMEs : a test of Stevenson's notion of entrepreneurial management

Geographical market expansion is included in various definitions of entrepreneurship as it entails the opening up of new markets (for example, Davidsson 2003). Expansion into new international markets and launch of new products in international markets are also consistent with definitions of entrepreneurship which center on the pursuit of opportunities {e.g.\Stevenson, 1983 #922;Gartner, 1993 #931}. Accordingly, the decision by managers of small, internationally active businesses to continue to internationalize can be viewed as an entrepreneurial act. In spite of the fact that both start-ups and existing firms can behave entrepreneurially by expanding into new international markets, the attention of entrepreneurship researchers interested in international activities has largely focused on international new ventures (INVs); that is, business organizations that internationalize from inception (Oviatt, and McDougall 1994; Oviatt, and McDougall 1997). Consequently, pursuit of international opportunities by established small and medium-sized enterprises (SMEs) lacks theoretical understanding and empirical investigation through an entrepreneurship lens. This paper contributes to the body of knowledge at the entrepreneurship-internationalization interface by testing whether Stevenson’s opportunity-based conceptualization of entrepreneurial management (Stevenson 1983; Stevenson and Gumpert 1985; Stevenson and Jarillo 1990) can explain the attainment of continued entrepreneurial outcomes by SMEs operating in foreign markets. We choose Stevenson’s conceptualization as it gauges firm-level characteristics that are theorized to facilitate the pursuit of entrepreneurial opportunities, which arguably is at the heart of SMEs’ continued venturing into international markets.

Entrepreneurial growth : the role of international knowledge acquisition as moderated by firm age

In line with repeated recent calls for research on specific forms of growth rather than on an undifferentiated notion of “total growth,” our study contributes to the understanding of entrepreneurial growth. By this we mean growth through expansion into new geographic markets and/or via the introduction of new products or services. Building on Penrose's theory of the growth of the firm and on the research streams she has in part inspired, we investigate the impact of knowledge acquisition from international markets on entrepreneurial growth both at home and abroad. We further suggest that the effects of international knowledge acquisition on entrepreneurial growth will vary with firm age. Utilizing longitudinal data on 138 small and medium-sized enterprises (SMEs), we find that the acquisition of knowledge from international markets fuels growth through market development, and that this effect is stronger for international expansion than domestic expansion. Our results also show that firm age negatively moderates the relationship between international knowledge acquisition and entrepreneurial growth via the introduction of new products or services. Specifically, international knowledge acquisition has a positive effect on growth via new products/services development in young firms, but a negative effect in mature firms. We assume this reflects changes over time in how international knowledge is managed.

International acclaim : the role(s) of the international film festival in supporting emerging women’s cinema

International Film Festivals act as important sites for the exhibition of contemporary world cinema. Film festivals represent an increasingly transnational film culture, where audiences, filmmakers, distributors, press, critics and academics come together from all over the world to discover new films, network with one another and debate about the past, present and future of cinema. This research project investigates the role that international film festivals play within the wider international film industry, with a specific focus on emerging women filmmakers. It therefore explores the arena of contemporary women.s cinema at its intersection with the international film festival industry. The significance and original contribution of the research is its intervention in the growing field of film festival studies through a specific investigation of how international film festivals support emerging women filmmakers. The positioning of the research at the intersection of feminist film theory and festival research within the broader context of transnational cinema allows the examination of each festival, the attending filmmakers and their films to be addressed within a more refined and nuanced lens. A core method for the thesis is the close textual analysis of particular emerging women filmmakers. films which are screened at the respective festivals. The research also utilises the qualitative research strategies of the case study and the interview to ¡°seek to understand the context or setting of the participants through visiting this context and gathering information personally¡± (Creswell 2003, 9). The textual analysis is used in dialogue with the interviews and the participant observational data gathering to provide a related context for understanding these films and their cultural meanings, both personally for the filmmaker and transnationally across the festival circuit. The focus of the case studies is the Brisbane International Film Festival, the International Film Festival Rotterdam and the Toronto International Film Festival. These three festivals were chosen for their distinct geographical locations in the Asia Pacific, Europe and North America, as well as for their varying size and influence on the international film festival circuit. Specifically, I investigate the reasons behind why the organisers of a particular festival have chosen a certain woman.s film, how it is then packaged or displayed within the programme, and how all of this impacts on the filmmaker herself. The focus of my research is to investigate film festivals and their .real-life. applications and benefits for the filmmakers being supported, both through the exhibition of their films and through their attendance as festival guests. The research finds that the current generation of emerging women filmmakers has varying levels of experience and success at negotiating the international film festival circuit. Each of the three festivals examined include and promote the films of emerging women filmmakers through a range of strategies, such as specific programming strands dedicated to showcasing emerging talent, financial support through festival funds, providing visibility within the programme, exposure to international audiences and networking opportunities with industry professionals and other filmmakers. Furthermore, the films produced by the emerging women filmmakers revealed a strong focus on women.s perspectives and experiences, which were explored through the interweaving of particular aesthetic and cinematographic conventions.

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.

From production to purpose : using design led innovation to Build Strategic Potential in a Family-Owned SME

There is an evident need to develop the strategic capabilities of companies from within, to ensure competitive competence in a time where strategy is a necessity. This paper is based on the first 4 months of a longitudinal embedded case study of a family-owned Australian small to medium enterprise, in their journey towards design integration. The first author was embedded as a ‘Design Innovation Catalyst’ to collaborate on overcoming early barriers of strategic development, using design led innovation. Action research methodology, semi-structured interviews with seven out of eight employees and a reflective journal revealed the absence of a shared vision, conflicting drivers and a focus on operational efficiency rather than strategy. Through the Catalyst’s facilitation, a company vision, general awareness, practice and knowledge in strategic development have emerged as the first steps to generating strategic design competence within the firm.

Making sense of purpose, direction and innovation : an embedded design led innovation case study in the Australian mining industry

The mining equipment technology services sector is driven by a reactive and user-centered design approach, with a technological focus on incremental new product development. As Australia moves out of its sustained mining boom, companies need to rethink their strategic position, to become agile to stay relevant in an enigmatic market. This paper reports on the first five months on an embedded case study within an Australian, family-owned mining manufacturer. The first author is currently engaged in a longitudinal design led innovation project, as a catalyst to guide the company’s journey to design integration. The results find that design led innovation could act as a channel for highlighting and exploring company disconnections with the marketplace and offer a customer-centric catalyst for internal change. Data collected for this study is from 12 analysed semistructured interviews, a focus group and a reflective journal, over a five-month period. This paper explores limitations to design integration, and highlights opportunities to explore and leverage entrepreneurial characteristics to stay agile, broaden innovation and future-proof through the next commodity cycle in the mining industry.

Industry-school partnerships : an ecological approach

Internationally, Industry-School Partnerships (ISPs) are a ubiquitous government approach for enabling school to work transitions. Significant benefits of ISPs for centralised bureaucracies that are seeking to address common educational problems include: i) cost reduction; ii) supply to geographically dispersed locations, and; iii) industry access to innovative education solutions. In Queensland, there exists a government led ISP, the Gateway to Industry Schools Program. Under this initiative is the Queensland Minerals and Energy Academy, a lead industry organisation for 34 schools and 17 multinational sponsor companies. Acquiring an understanding of this strategic ISP is critical, given the current Resources Industry boom, and the workforce skills shortage experienced in Australia. This review paper adopts Ecological Systems Theory as a lens to understand the inner workings of ISPs. Acknowledging that ISPs will remain a key feature of government policy, this paper seeks to further illuminate the role of ISPs in transitioning young people from school to the working world.

Corporate social responsibility in Japanese firms in transport sector

Corporate Social Responsibility (CSR) reporting has become common practice for large organisations globally, yet there is variance in the CSR related activities claimed in disclosures. CSR researchers argue that cultural and historical backgrounds are the influential drivers of CSR behaviour. However, the links between actual activities claimed in CSR reports and the cultural systems that underpin these reported activities is an under-explored area. This thesis discusses the uniqueness of Japanese socio-cultural aspects. While Japan is well-known for having the most advanced energy efficient technologies in the world, it is also known for being below international standards for gender equality in the workplace. Therefore, this thesis aims to explore and examine organisational behaviours through the lens of relativism in order to understand what organisations are reporting and how and why managers prioritise these activities. This thesis is based on longitudinal qualitative research focusing on the Japanese transport companies that published CSR reports between 2005 and 2009. The findings from manually coded content analysis revealed: (1) that activities related to providing public safety, waste management and the 3Rs (reduce, reuse and recycle), and environmental innovation were the top three most frequently reported CSR activities; and (2) complying with laws, career planning, flexible work practices, and providing public safety were the three categories that showed the most significant increase in reporting frequency from 2005-2009. This thesis extends the previous literature. Takagaki (2010b) identified that the transport industry, particularly the air and water sub-sectors, is the industry where the environmental problems are serious and require urgent attention. Takagaki (2010b) chose to explore the electronics industry as this industry is considered to be middle ground for its level of seriousness and urgency. This research: (1) examines the transport industry; (2) investigates the links between the actual activities reported, and the activities reported to be influential drivers of these activities.