Transfer pricing and multinational financial institutions : the case for replacing arm’s length price with a unitary approach

The international tax system, designed a century ago, has not kept pace with the modern multinational entity rendering it ineffective in taxing many modern businesses according to economic activity. One of those modern multinational entities is the multinational financial institution (MNFI). The recent global financial crisis provides a particularly relevant and significant example of the failure of the current system on a global scale. The modern MNFI is increasingly undertaking more globalised and complex trading operations. A primary reason for the globalisation of financial institutions is that they typically ‘follow-the-customer’ into jurisdictions where international capital and international investors are required. The International Monetary Fund (IMF) recently reported that from 1995-2009, foreign bank presence in developing countries grew by 122 per cent. The same study indicates that foreign banks have a 20 per cent market share in OECD countries and 50 per cent in emerging markets and developing countries. Hence, most significant is that fact that MNFIs are increasingly undertaking an intermediary role in developing economies where they are financing core business activities such as mining and tourism. IMF analysis also suggests that in the future, foreign bank expansion will be greatest in emerging economies. The difficulties for developing countries in applying current international tax rules, especially the current traditional transfer pricing regime, are particularly acute in relation to MNFIs, which are the biggest users of tax havens and offshore finance. This paper investigates whether a unitary taxation approach which reflects economic reality would more easily and effectively ensure that the profits of MNFIs are taxed in the jurisdictions which give rise to those profits. It has previously been argued that the uniqueness of MNFIs results in a failure of the current system to accurately allocate profits and that unitary tax as an alternative could provide a sounder allocation model for international tax purposes. This paper goes a step further, and examines the practicalities of the implementation of unitary taxation for MNFIs in terms of the key components of such a regime, along with their their implications. This paper adopts a two-step approach in considering the implications of unitary taxation as a means of improved corporate tax coordination which requires international acceptance and agreement. First, the definitional issues of the unitary MNFI are examined and second, an appropriate allocation formula for this sector is investigated. To achieve this, the paper asks first, how the financial sector should be defined for the purposes of unitary taxation and what should constitute a unitary business for that sector and second, what is the ‘best practice’ model of an allocation formula for the purposes of the apportionment of the profits of the unitary business of a financial institution.

eHealth-as-a-Service (eHaaS) : the industrialisation of health informatics, a practical approach

With the introduction of the Personally Controlled Health Record (PCEHR), the Australian public is being asked to accept greater responsibility for their healthcare. Although well designed, constructed and intentioned, policy and privacy concerns have resulted in an eHealth model that may impact future health information sharing requirements. Thus an opportunity to transform the beleaguered Australian PCEHR into a sustainable on-demand technology consumption model for patient safety must be explored further. Moreover, the current clerical focus of healthcare practitioners must be renegotiated to establish a shared knowledge creation landscape of action for safer patient interventions. To achieve this potential however requires a platform that will facilitate efficient and trusted unification of all health information available in real-time across the continuum of care. As a conceptual paper, the goal of the authors is to deliver insights into the antecedents of usage influencing superior patient outcomes within an eHealth-as-a-Service framework. To achieve this, the paper attempts to distil key concepts and identify common themes drawn from a preliminary literature review of eHealth and cloud computing concepts, specifically cloud service orchestration to establish a conceptual framework and a research agenda. Initial findings support the authors’ view that an eHealth-as-a-Service (eHaaS) construct will serve as a disruptive paradigm shift in the aggregation and transformation of health information for use as real-world knowledge in patient care scenarios. Moreover, the strategic value of extending the community Health Record Bank (HRB) model lies in the ability to automatically draw on a multitude of relevant data repositories and sources to create a single source of practice based evidence and to engage market forces to create financial sustainability.

An analysis of the timeliness and nature of profit warnings in the aftermath of the Global Financial Crisis

The global financial crisis (GFC) has severely impacted the financial position and performance of many companies internationally. Because of its severity and associated increase in uncertainty it challenges the effectiveness of existing disclosure regulation. Australia provides a unique environment in which to test the effects of the GFC on corporate disclosure because statutory rules mandate the timely disclosure of ‘price-sensitive’ information (ASX Rule 3.1) by listed entities. Exploiting this institutional setting we investigate the determinants and timeliness of profit warnings issued by the top 500 ASX-listed firms with profit declines in the 2009 fiscal year. Our findings show that firms behave differently with regard to the issuance of profit warnings: larger and more indebted firms are more likely to issue a profit warning and tend to be timelier; surprisingly, poorer performing firms tend to release the news more quickly and this might be attributed to an increasing threat of litigation. Our analysis of profit warning determinants shows interesting results with the presence of asset impairments hindering the early disclosure of profit warnings. Our findings are novel for two main reasons: first, we provide insights into the impact of global financial crisis on profit warning behaviour; second, we are the first to examine the differential impact of alternative features of profit warnings on disclosure timeliness. The findings have implications for regulators in determining compliance with continuous disclosure rules and more broadly, for market participants in interpreting profit warnings.

The performance of diversified emerging market equity funds

We investigate the performance of globally diversified emerging market equity funds during the first decade of the twenty-first century. A vast majority of these funds do not outperform the market benchmark even before transaction costs. The systematic risk of most of the funds is similar to that of the market benchmark portfolio, which may suggest that they aim to offer diversification benefits rather than seeking superior risk-adjusted returns through active management. We do not find any evidence of market timing ability amongst these funds. Finally, whilst we detect persistence in performance, this result is driven mainly by the poorly performing funds.

The equity and efficiency of the Australian share market with respect to director trading

Purpose – The purpose of this paper is to investigate the extent of directors breaching the reporting requirements of the Australian Stock Exchange (ASX) and the Corporations Act in Australia. Further, it seeks to assess whether directors in Australia achieve abnormal returns from trades in their own companies. Design/methodology/approach – Using an event study approach on an Australian sample, abnormal returns for a range of situations were estimated. Findings – A total of 13 (seven) per cent of own‐company directors trades do not meet the ASX (Corporations Act) requirement of reporting within five (14) business days. Directors do achieve abnormal returns through trading in shares of their own companies. Ignoring transaction costs, outsiders can achieve abnormal returns by imitating directors' trades. Analysis of returns to directors after they trade but before they announce the trade to the market shows that directors are making small but statistically significant returns that are not available to the market. Analysis of returns to directors subsequent to the ASX reporting requirement up to the day the trade is reported shows that directors are making small but statistically significant returns that should be available to the market. Research limitations/implications – Future research should investigate the linkages between late reporting by directors and disadvantages to outside shareholders and the implementation of internal policies implemented to mitigate insider trading. Practical implications – Market participants should remain vigilant regarding the potential for late/non‐reporting of directors' trades. Originality/value – Uncovering breaches of reporting regulations are particularly important given that directors tend to purchase (sell) shares when the price is low (high), thereby achieving abnormal returns.

The differential impact of monetary policy announcements and explanatory minutes releases on the Australian interest rate futures market

Unlike US and Continental European jurisdictions, Australian monetary policy announcements are not followed promptly by projections materials or comprehensive summaries that explain the decision process. This information is disclosed 2 weeks later when the explanatory minutes of the Reserve Bank board meeting are released. This paper is the first study to exploit the features of the Australian monetary policy environment in order to examine the differential impact of monetary policy announcements and explanatory statements on the Australian interest rate futures market. We find that both monetary policy announcements and explanatory minutes releases have a significant impact on the implied yield and volatility of Australian interest rate futures contracts. When the differential impact of these announcements is examined using the full sample, no statistically significant difference is found. However, when the sample is partitioned based on stable periods and the Global Financial Crisis, a differential impact is evident. Further, contrary to the findings of Kim and Nguyen (2008), Lu et al. (2009), and Smales (2012a), the response along the yield curve, is found to be indifferent between the short and medium terms.

Identifying the financial barriers to deliberative, affordable apartment development in Australia

Purpose The purpose of this paper is to identify the financial barriers to the supply of affordable apartments in Australia and examine whether demand aggregation and ‘deliberative development’ (self-build) can form a new affordable housing ‘structure of provision’. Design/methodology/approach Market design, an offshoot of game theory, is used to analyse the existing apartment development model, with ‘deliberative development’ proposed as an innovative alternative. Semi-structured interviews with residential development financiers are used to evaluate whether deliberative development could obtain the requisite development finance. Findings Our investigation into the financial barriers of a deliberative development model suggest that while there are hurdles, these can be addressed if key risks in the exchange process can be mitigated. Hence, affordability can be enhanced by ‘deliberative development’ replacing the existing speculative development model. Research implications Market design is a new innovative theoretical approach to understanding the supply of housing, offering practical solutions to affordable apartment supply in Australia. Originality/value This research identifies financial barriers to the supply of affordable apartments; introduces theoretical understandings gained from market design as an innovative solution; provides evidence that a new structure of building provision based on ‘deliberative development’ could become a key means of achieving more affordable and better designed apartments.

Football supporter cultures in modern-day Brazil: Hypercommodification, networked collectivisms and digital productivity

This thesis analyses the implications for football cultures of the profound socio-economic changes that Brazil has experienced in the last decade. It explores two major impacts: the economic boom of the domestic football sector, and the large-scale adoption of new technologies in fans' activities. The study identified a new phase of football culture in Brazil, characterised by the domination of market logics and intense commercialisation. The empirical findings also showed that new technologies are changing how supporters coordinate activities that challenge the gentrification of the game.

The potential for consumer segmentation in the Finnish housing market

This article examines whether cluster analysis can be used to identify groups of Finnish residents with similar housing preferences. Because homebuilders in Finland have been providing relatively homogeneous products to an increasingly diverse population, current housing may not represent the occupiers' preferences so a segmentation approach relying on socioeconomic characteristics and expressed preferences may not be sufficient. We use data collected via questionnaire in a principal component analysis followed by a hierarchical cluster analysis to determine whether different combinations of housing attributes are important to groups of residents. We can identify four clusters of housing residents based on important characteristics when looking for a house. The clusters describe Finnish people in different phases of the life cycle and with different preferences based on their recreational activities and financial expenditures. Mass customization of housing could be used to better appeal to these different clusters of consumers who share similar preferences, increasing consumer satisfaction and improving profitability.

Managing flexible work arrangements in small not-for-profit firms: The influence of organisational size, financial constraints and workforce characteristics

Small, not-for-profit organisations fulfil a need in the economy that is typically not satisfied by for-profit firms. They also operate in ways that are distinct from larger organisations. While such firms employ a substantial proportion of the workforce, research addressing human resource management (HRM) practices in these settings is limited. This article used data collected from five small not-for-profit firms in Australia to examine the way one significant HRM practice – the provision and utilisation of flexible work arrangements – operates in the sector. Drawing on research from several scholarly fields, the article firstly develops a framework comprising three tensions in not-for-profits that have implications for HRM. These tensions are: (1) contradictions between an informal approach to HRM vs. a formal regulatory system; (2) employee values that favour social justice vs. external market forces; and (3) a commitment to service vs. external financial expectations. The article then empirically examines how these tensions are managed in relation to the specific case of flexible work arrangements. The study reveals that tensions around providing and accessing flexible work arrangements are managed in three ways: discretion, leadership style and distancing. These findings more broadly inform the way HRM is operationalised in this under-examined sector.

The economic consequences of financial reporting on Twitter

The use of social media has spread into many different areas including marketing, customer service, and corporate disclosure. However, our understanding of the timely effect of financial reporting information on Twitter is still limited. In this paper, we propose to examine the timely effect of financial reporting information on Twitter in Australian context, as reflect in the stock market trading. We aim to find out whether the level of information asymmetry within the stock market will be reduced, after the introduction of Twitter and the use of Twitter for financial reporting purpose

The economic consequences of corporate financial reporting on Twitter

The use of social media has spread into many different areas including marketing, customer service, and corporate disclosure. However, our understanding of the timely effect of financial reporting information on Twitter is still limited. In this paper, we examine the timely effect of financial reporting information on Twitter in the Australian context, as reflected in the follow-up stock market reaction. With the use of event methodology and comparative setting, we find that financial reporting disclosure on Twitter reduces the information asymmetry level. This is evidenced by reduction of bid-ask spread and increase of share trading volume. The results of this study imply that financial reporting disclosure on social media assists the dissemination of information and the stock market response to this information

Reforming technology company incentive programs for achieving knowledge-based economic development:a Brazil-Australia comparative study

This doctoral thesis aims to demonstrate the importance of incentives to technology-based firms as a strategy to promote knowledge-based economic development (KBED). To remain competitive, technology-based firms must innovate and seek new markets; therefore, this study aims to propose an incentive model to technology-based firms as a strategy to promote knowledge-based urban development, according to framework described by Yigitcanlar (2011). This is an exploratory and descriptive research with a qualitative approach. Surveys were carried out with national trade associations that represented technology-based firms both in Brazil and Australia. After analysing the surveys, structured interviews were conducted with government representatives, trade associations and businessmen who had used financial support by the federal government. When comparing both countries, the study found the importance of direct incentives through tax incentives, for it is a less bureaucratic, quicker and more direct process for firms. We suggest to include the terms incentives in the framework of knowledge-based urban development, as one of the pillars that contribute to knowledge-based economic development.