The enterprising artist and the arts entrepreneur : Emergent pedagogies for new disciplinary habits of mind

Traditional pedagogies in the arts in higher education focus largely on the studio experience in which a novice artist studies under one or more master teachers (e.g., Don, Garvey, & Sadeghpour, 2009). In more recent times, however, a shift in higher education curriculum and pedagogy in the arts has expanded this traditional conservatory model of training to include, among other components, career self-management and enterprise creation—in a word, entrepreneurship.This chapter examines the developing field of arts enterprise and arts entrepreneurship in higher education in a multinational context. The field is contextualized within the broader landscape of the creative industries and the consequential development of knowledge, skills, and the habits of mind necessary for artistic venture creation, sustainability, and success. Whereas the discourse about learning and teaching for business entrepreneurship is well established (e.g., Fiet, 2001), equivalent conversations about arts enterprise and entrepreneurship have only recently begun (Beckman, 2007, 2011; Essig, 2009). This chapter will address the contested definitions of key terms and concepts and also the question of how arts educators, although mindful of the pedagogic traditions of the arts school, are also drawing on the pedagogies of business entrepreneurship and cognitive theories of entrepreneurship to create innovative new transdisciplinary signature pedagogies for creative enterprise and entrepreneurship education in the arts.

The taxing effects of the advance pricing arrangement program: A review of APAs and their impact on stakeholders

The current transfer pricing rules contained in Australia’s taxation regime are designed to counter the underpayment of tax by businesses engaged in international related-party dealings. Currently, these transactions must take place at an arm’s length price, a requirement which is becoming increasingly difficult to demonstrate. This results in an increased risk of an audit by the Australian Taxation Office. If a taxpayer wishes to avoid the risk of an audit, and any ensuing penalties, there is one option: an advance pricing arrangement (‘APA’). An APA is an agreement whereby the future transfer pricing methodology to be used to determine the arm’s length price is agreed to by the taxpayer and the relevant tax authority or authorities. This article investigates the use of APAs as a solution to the problem of transfer pricing and considers their impact on stakeholders. It is argued that while APAs provide a valuable practical tool for multinational entities facing the challenges of the taxation of global trading under the current regime, they may not be a practical long term solution.

Advance pricing arrangements : an Australian Tax Office success or a legislative failure?

Australia’s domestic income tax legislation and double tax agreements contain transfer pricing rules which are designed to counter the underpayment of tax by businesses engaged in international dealings between related parties. The current legislation and agreements require that related party transactions take place at a value which reflects an arm’s length price, that is, a price which would be charged between unrelated parties. For a host of reasons, it is increasingly difficult for multinational entities to demonstrate that they are transferring goods and services at a price which is reflective of the behaviour of independent parties, thereby making it difficult to demonstrate compliance with the relevant legislation. Further, where an Australian business undertakes cross-border related party transactions there is the risk of an audit by the Australian Tax Office (ATO). If a business wishes to avoid the risk of an audit, and any ensuing penalties, there is one option: an advance pricing arrangement (APA). An APA is an agreement whereby the future transfer pricing methodology to be used to determine the arm’s length price is agreed to by the taxpayer and the relevant tax authority or authorities. The ATO views the APA process as an important part of its international tax strategy and believes that there are complementary benefits provided to both the taxpayer and the ATO. The ATO promotes the APA process on the basis of creating greater certainty for all parties while reducing compliance costs and the risk of audit and penalty. While the ATO regards the APA system as a success, it may be argued that the implementation of such a system is simply a practical solution to an ongoing problem of an inherent failure in both the legislation and ATO interpretation and application of this legislation to provide certainty to the taxpayer. This paper investigates the use of APAs as a solution to the problem of transfer pricing and considers whether they are the success the ATO claims. It is argued that there is no doubt that APAs provide a valuable practical tool for multinational entities facing the challenges of the taxation of global trading under the current transfer pricing regime. It does not, however, provide a long term solution. Rather, the long term solution may be in the form of legislative amendment.

Unitary taxation : The case for global formulary apportionment

Unitary taxation is the taxation of the worldwide income of a multinational enterprise (MNE) and is normally based on a formulary apportionment method, which allocates income to the relevant jurisdictions based on a percentage of the MNE's world-wide profits. The unitary taxation model has several advantages over the existing arm's length model: 1. Where MNEs are highly integrated, unitary taxation has greater consistency with economic reality. 2. Greater certainty is provided to taxpayers. 3. Unitary taxation conforms to the aim of efficient operations within the MNE. 4. The aim of unitary taxation, to find an equitable split of profits between the jurisdictions, should ultimately be the overall aim of any tax regime. The advantages and disadvantages associated with the adoption of a unitary taxation model through the implementation of a formulary apportionment approach to the taxation of MNEs are examined.

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.

Globalization of science education : comment and a commentary

The globalized nature of modern society has generated a number of pressures that impact internationally on countries’ policies and practices of science education. Among these pressures are key issues of health and environment confronting global science, global economic control through multinational capitalism, comparative and competitive international testing of student science achievement, and the desire for more humane and secure international society. These are not all one-way pressures and there is evidence of both more conformity in the intentions and practices of science education and of a greater appreciation of how cultural differences, and the needs of students as future citizens can be met. Hence while a case for economic and competitive subservience of science education can be made, the evidence for such narrowing is countered by new initiatives that seek to broaden its vision and practices. The research community of science education has certainly widened internationally and this generates many healthy exchanges, although cultural styles of education other than Western ones are still insufficiently recognized. The dominance of English language within these research exchanges is, however, causing as many problems as it solves. Science education, like education as a whole, is a strongly cultural phenomenon, and this provides a healthy and robust buffer to the more negative effects of globalization

The inherent international tax regime and its constraints on Australia's sovereignty

On 1 November 2011 the Minister for Financial Services and Superannuation, the Honourable Bill Shorten MP, announced that Australia would be undertaking a reform of the ‘transfer pricing rules in the income tax law and Australia’s future tax treaties to bring them into line with international best practice, improving the integrity and efficiency of the tax system.’ Mr Shorten stated that the reason for the reform was that ‘recent court decisions suggest our existing transfer pricing rules may be interpreted in a way that is out-of-kilter with international norms.’ Further, he stated that ‘the Government has asked the Treasury to review how the transfer pricing rules can be improved, including but not limited to how to be more in line with international best practice.’ He urged all interested parties to participate in this consultation process. On 16 March 2012, an Exposure Draft and accompanying Explanatory Memorandum outlining the proposed amendments to implement the first stage of the transfer pricing reforms were released. Within the proposed changes is the explicit embedding of the use of the OECD’s Model Tax Convention on Income and on Capital and Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations to help determine the arm’s length price. Does this mean that Australia engages in an international tax regime?

Regulating for corporate human rights abuses : the emergence of corporate reporting on the ILO’s human rights standards within the global garment manufacturing and retail industry

Despite the ubiquitous nature of the discourse on human rights there is currently little research on the emergence of disclosure by multinational corporations on their human rights obligations or the regulatory dynamic that may lie behind this trend. In an attempt to begin to explore the extent to which, if any, the language of human rights has entered the discourse of corporate accountability, this paper investigates the adoption of the International Labour Organisation's (ILO) human rights standards by major multinational garment retail companies that source products from developing countries, as disclosed through their reporting media. The paper has three objectives. Firstly, to empirically explore the extent to which a group of multinational garment retailers invoke the language of human rights when disclosing their corporate responsibilities. The paper reviews corporate reporting media including social responsibility codes of conduct, annual reports and stand-alone social responsibility reports released by 18 major global clothing and retail companies during a period from 1990 to 2007. We find that the number of companies adopting and disclosing on the ILO's workplace human rights standards has significantly increased since 1998 – the year in which the ILO's standards were endorsed and accepted by the global community (ILO, 1998). Secondly, drawing on a combination of Responsive Regulation theory and neo-institutional theory, we tentatively seek to understand the regulatory space that may have influenced these large corporations to adopt the language of human rights obligations. In particular, we study the role that International Governmental Organisation's (IGO) such as ILO may have played in these disclosures. Finally, we provide some critical reflections on the power and potential within the corporate adoption of the language of human rights.

Media pressures and corporate disclosure of social responsibility performance information : a study of two global clothing and sports retail companies

This paper investigates the social and environmental disclosure practices of two large multinational companies, specifically Nike and Hennes&Mauritz. Utilising a joint consideration of legitimacy theory and media agenda setting theory, we investigate the linkage between negative media attention, and positive corporate social and environmental disclosures. Our results generally support a view that for those industry‐related social and environmental issues attracting the greatest amount of negative media attention, these corporations react by providing positive social and environmental disclosures. The results were particularly significant in relation to labour practices in developing countries – the issue attracting the greatest amount of negative media attention for the companies in question.

Social Responsibility Disclosure Practices : Evidence from Bangladesh

This report provides the results of a study of the social and environmental reporting practices of organisations operating in, or sourcing products from, a developing country; in this case, Bangladesh. The study comprised three distinct but related components: 1. an investigation of the social and environmental disclosure practices of the Bangladesh Garment Manufacturers and Exporters Association (BGMEA) 2. an investigation of the social and environmental disclosure practices of two major multinational buying companies: Nike and H&M 3. an exploration of possible drivers for the media agenda in reporting the activities of multinationals and NGOs.

Business in troubled waters : does adverse attitude affect firm value?

This paper investigates the relationship between US MNCs' valuations and anti-Americanism in countries where MNCs' foreign subsidiaries are located. We find that MNCs suffer value-destruction when they enter markets where people express severe anti-Americanism. However, we uncover that geographic diversification into these high anti-Americanism countries significantly increases firm value if the MNC has high levels of intangibles such as technological know-how and marketing expertise. Our findings are consistent with the notion that the advantages from internalizing the cross-border transfer of intangibles are greater when barriers to competition are higher.

Simplifying process model abstraction : techniques for generating model names

The increased adoption of business process management approaches, tools and practices, has led organizations to accumulate large collections of business process models. These collections can easily include hundred to thousand models, especially in the context of multinational corporations or as a result of organizational mergers and acquisitions. A concrete problem is thus how to maintain these large repositories in such a way that their complexity does not hamper their practical usefulness as a means to describe and communicate business operations. This paper proposes a technique to automatically infer suitable names for business process models and fragments thereof. This technique is useful for model abstraction scenarios, as for instance when user-specific views of a repository are required, or as part of a refactoring initiative aimed to simplify the repository’s complexity. The technique is grounded in an adaptation of the theory of meaning to the realm of business process models. We implemented the technique in a prototype tool and conducted an extensive evaluation using three process model collections from practice and a case study involving process modelers with different experience.

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.

Cetuximab plus chemotherapy in patients with advanced non-small-cell lung cancer (FLEX) : an open-label randomised phase III trial

Background: Use of cetuximab, a monoclonal antibody targeting the epidermal growth factor receptor (EGFR), has the potential to increase survival in patients with advanced non-small-cell lung cancer. We therefore compared chemotherapy plus cetuximab with chemotherapy alone in patients with advanced EGFR-positive non-small-cell lung cancer. Methods: In a multinational, multicentre, open-label, phase III trial, chemotherapy-naive patients (≥18 years) with advanced EGFR-expressing histologically or cytologically proven stage wet IIIB or stage IV non-small-cell lung cancer were randomly assigned in a 1:1 ratio to chemotherapy plus cetuximab or just chemotherapy. Chemotherapy was cisplatin 80 mg/m 2 intravenous infusion on day 1, and vinorelbine 25 mg/m 2 intravenous infusion on days 1 and 8 of every 3-week cycle) for up to six cycles. Cetuximab-at a starting dose of 400 mg/m 2 intravenous infusion over 2 h on day 1, and from day 8 onwards at 250 mg/m 2 over 1 h per week-was continued after the end of chemotherapy until disease progression or unacceptable toxicity had occurred. The primary endpoint was overall survival. Analysis was by intention to treat. This study is registered with ClinicalTrials.gov, number NCT00148798. Findings: Between October, 2004, and January, 2006, 1125 patients were randomly assigned to chemotherapy plus cetuximab (n=557) or chemotherapy alone (n=568). Patients given chemotherapy plus cetuximab survived longer than those in the chemotherapy-alone group (median 11·3 months vs 10·1 months; hazard ratio for death 0·871 [95% CI 0·762-0·996]; p=0·044). The main cetuximab-related adverse event was acne-like rash (57 [10%] of 548, grade 3). Interpretation: Addition of cetuximab to platinum-based chemotherapy represents a new treatment option for patients with advanced non-small-cell lung cancer. Funding: Merck KGaA. © 2009 Elsevier Ltd. All rights reserved.

Assessing the suitability of market approach valuation methods for mine and quarry valuations

An area of property valuation that has attracted less attention than other property markets over the past 20 years has been the mining and extractive industries. These operations can range from small operators on leased or private land to multinational companies. Although there are a number of national mining standards that indicate the type of valuation methods that can be adopted for this asset class, these standards do not specify how or when these methods are best suited to particular mine operations. The RICS guidance notes and the draft IVSC guidance notes also advise the various valuations methods that can be used to value mining properties; but, again they do not specify what methods should be applied where and when. One of the methods supported by these standards and guidelines is the market approach. This paper will carry out an analysis of all mine, extractive industry and waste disposal sites sale transactions in Queensland Australia, a major world mining centre, to determine if a market valuation approach such as direct comparison is actually suitable for the valuation of a mine or extractive industry. The analysis will cover the period 1984 to 2011 and covers sale transactions for minerals, petroleum and gas, waste disposal sites, clay, sand and stone. Based on this analysis, the suitability of direct comparison for valuation purposes in this property sector will be tested.