The internetalisation of information, knowledge and interaction components of the firm’s internationalisation process

Transcending traditional national borders, the Internet is an evolving technology that has opened up many new international market opportunities. However, ambiguity remains, with limited research and understanding of how the Internet influences the firm’s internationalisation process components. As a consequence, there has been a call for further investigation of the phenomenon. Thus, the purpose of this study was to investigate the Internet’s impact on the internationalisation process components, specifically, information availability, information usage, interactive communication and international market growth. Analysis was undertaken using structural equation modelling. Findings highlight the mediating impact of the Internet on information and knowledge transference in the internationalisation process. Contributions of the study test conceptualisations and give statistical validation of interrelationships, while illuminating the Internet’s impact on firm internationalisation.

Taxation of multinational banks : using formulary apportionment to reflect economic reality (Part 1)

Formulary apportionment does not attempt to undertake a transactional division of a highly integrated multinational entity. Rather, it allocates income to the jurisdictions based on an economically justifiable formula. Opposition to formulary apportionment is generally based on the argument that it is not a theoretically superior (or optimal) model because of the implementation difficulties. The conclusion that the unitary taxation model may be theoretically superior to the current arm's-length model that applies to multinational banks, despite significant implementation, compliance, and enforcement issues, is based on the unitary taxation model providing greater alignment with the unique features of these banks. The formulary apportionment model looks to the economic substance of the multinational entity and, in this sense, adopts a substance-over- form approach. Formulary apportionment further recognizes the impossibility of using arm's-length pricing for economically interdependent multinational entities. A final advantage to formulary apportionment, which is also a consequence of this model achieving greater inter-nation equity, is the elimination of double taxation.

The taxation of multinational banks : alternative apportionment through a unitary taxation regime aligning with economic reality

The taxation of multinational banks currently is governed by the general principles of international tax. However, it is arguable that there are characteristics exclusive to multinational banks that may warrant the consideration of a separate taxing regime. This article argues that because of the unique nature of multinational banks, the traditional international tax rules governing jurisdiction to tax and allocation of income do not produce a result which is optimal, as it does not reflect economic reality. That is, the current system does not produce a result that accurately reflects the economic source of the income or the location of the economic activity. The suggested alternative is unitary taxation using global formulary apportionment. Formulary apportionment is considered as an alternative that reflects economic reality by recognising the unique nature of multinational banks and allocating the income to the location of the economic activity. The unique nature of multinational banking is recognised in the fact that formulary apportionment does not attempt to undertake a transactional division of a highly integrated multinational entity. Rather, it allocates income to the jurisdictions based on an economically justifiable formula. Starting from this recognition, the purpose of this article is to demonstrate that formulary apportionment is a theoretically superior (or optimal) model for the taxation of multinational banks. An optimal regime, for the purposes of this article, is considered to be one that distributes the taxing rights in an equitable manner between the relevant jurisdictions, while, simultaneously allowing decisions of the international banks to be tax neutral. In this sense, neutrality is viewed as an economic concept and equity is regarded as a legal concept. A neutral tax system is one in which tax rules do not affect economic choices about commercial activities. Neutrality will ideally be across jurisdictions as well as across traditional and non-traditional industries. The primary focus of this article is jurisdictional neutrality. A system that distributes taxing rights in an equitable manner between the relevant jurisdictions ensures that each country receives its fair share of tax revenue. Given the increase in multinational banking, jurisdictions should be concerned that they are receiving their fair share. Inter-nation equity is concerned with re-determining the proper division of the tax base among countries. Richard and Peggy Musgrave argue that sharing of the tax base by countries of source should be seen as a matter of inter-nation equity requiring international cooperation. The rights of the jurisdiction of residency will also be at issue. To this extent, while it is agreed that inter-nation equity is an essential attribute to an international tax regime, there is no universal agreement as to how to achieve it. The current system attempts to achieve such equity through a combined residency and source regime, with the transfer pricing rules used to apportion income between the relevant jurisdictions. However, this article suggests, that as an alternative to the current regime, equity would be achieved through formulary apportionment. Opposition to formulary apportionment is generally based on the argument that it is not a theoretically superior (or optimal) model because of the implementation difficulties. Yet these are two separate issues. As such, this article is divided into two core parts. The first part examines the theoretical soundness of the formulary apportionment model concluding that it is theoretically superior to the arm’s length pricing requirement of the traditional transfer pricing regime. The second part examines the practical implications of accepting formulary apportionment as an optimal model with a view to disclosing the issues that arise when a formulary apportionment regime is adopted. Prior to an analysis of the theoretical and practical application of formulary apportionment to multinational banks, the unique nature of these banks is considered. The article concludes that, while there are significant implementation, compliance, and enforcement issues to overcome, the unitary taxation model may be theoretically superior to the current arm’s length model which applies to multinational banks. This conclusion is based on the unitary taxation model providing greater alignment with the unique features of these banks.

Taxation of multinational banks : using formulary apportionment to reflect economic reality (Part 2)

As stated in Part 1 of this article, formulary appointment does not attempt to undertake a transactional division of a highly integrated multinational entity; rather, it allocates income to the jurisdictions based on economically justifiable formula. This article argues that the unitary taxation model is superior to the current arms-lenght model for the taxation of multinational banks despite significant implementation, complicance and enforcement issues. Part one of the article gave some background on the taxation of multinational banks, followed by a discussion of their uniqueness, and the theoretical benefits of the unitary tax model for multinational banking. Part 2 below covers the practical implications of accepting formulary apportionment as an 'optimal' regime for taxing multinational banks.

The taxation of multinational banking income : is the traditional rationale correct?

This article argues that multinational banks have characteristics which are unique and distinguishable from traditional multinational entities. The first distinguishing feature is the unique nature of the services and consequent products supplied by multinational banks, which are aimed at meeting client global demand. The second distinguishing feature is the non-traditional organisational structure that is adopted. This structure, also designed to meet client global demand, introduces issues previously not recognised in the traditional taxation system, which is designed for the structure of traditional multinational entities. The unique differences between traditional multinational entities and multinational banks means there may be the need for a distinct international tax regime. It is argued that there are “outmoded economic assumptions” upon which the present tax laws relating to multinational banks are based. An examination of the unique nature of multinational banks leads to the conclusion that the appropriate tax treatment of these banks is different from the appropriate tax treatment of multinational entities generally.

ACE research vignette 002 : competing through service innovation - the case of project-oriented firms

This series of research vignettes is aimed at sharing current and interesting research findings from our team of international Entrepreneurship researchers. In this vignette, Dr Sandeep Salunke shares insights from his research on project-oriented firms.

ACE research vignette 006 : why saving jobs and supporting failing firms can be detrimental

This series of research vignettes is aimed at sharing current and interesting research findings from our team and other international Entrepreneurship researchers. In this vignette, we summarise the findings from a paper written by Avaid Pe'er and Ilan Vertinsky that examines "Why saving jobs and supporting failing firms can be detrimental".

The traditional rationale of the arm’s length approach to transfer pricing : should the separate accounting model be maintained for modern multinational entities?

This article examines the current transfer pricing regime to consider whether it is a sound model to be applied to modern multinational entities. The arm's length price methodology is examined to enable a discussion of the arguments in favour of such a regime. The article then refutes these arguments concluding that, contrary to the very reason multinational entities exist, applying arm's length rules involves a legal fiction of imagining transactions between unrelated parties. Multinational entities exist to operate in a way that independent entities would not, which the arm's length rules fail to take into account. As such, there is clearly an air of artificiality in applying the arm's length standard. To demonstrate this artificiality with respect to modern multinational entities, multinational banks are used as an example. The article concluded that the separate entity paradigm adopted by the traditional transfer pricing regime is incongruous with the economic theory of modern multinational enterprises.

Environmental law and the economic impact on Australian firms

In response to international awareness of environmental issues and the inadequacies of common law actions, legislation has been enacted by Australian governments to facilitate environmental protection. The Environmental Protection Act 1994 (Qld) and accompanying Environmental Protection (Interim) Regulation 1995 (Qld) is one example of government response to mounting public pressure to legislate for the environment. Investigation into the operation of the legislation exposes the costs faced by Australian firms in its application. The legislation identifies a number of environmentally relevant activities and imposes licensing and reporting requirements on firms undertaking such activities. In view of these legislative requirements and the increasing public awareness of environmental issues over the last decade in Australia, it could be expected that firms undertaking environmentally sensitive activities will place greater importance on the management of environmental issues. If so, the greater prominence placed on environmental management may be reflected in disclosures made by the firm to its shareholders and other interested parties. This article investigates the type and extent of costs currently imposed by the body of environmental laws in Australia with the discussion primarily focusing upon costs imposed due to the operation of environmental legislation in Queensland. Further, the article reports empirical analysis of management response to environmental issues where firms are undertaking environmentally sensitive activities.

Competing through service innovation : the role of bricolage and entrepreneurship in project-oriented firms

The criticality of service innovation in building and sustaining competitive advantage is gaining increasing recognition in the marketplace. Using empirical data from US and Australian project-oriented firms, the study uses a multi-staged multi-method research program to demonstrate how entrepreneurial service firms strategically combine resources at hand (bricolage) to innovate and stay ahead of rivals. The research shows that service entrepreneurship (SE) and bricolage influence two forms of service innovation (interactive and supportive), which in turn is associated with sustained competitive advantage (SCA). The results suggest that SE and bricolage indirectly relate to SCA through service innovation. The findings offer novel insights into how project-oriented service firms engage in innovation. In short, the findings encourage the “making do by combining resources at hand” as higher levels of entrepreneurial bricolage are associated with higher levels of interactive and supportive innovation enabling SCA, suggesting a new model.

HRM in professional service firms : engendering commitment to what or whom?

Professional service firms (PSFs) present HR professionals with a number of unique challenges, as they share characteristics of both service and knowledge intensive organizations. While many of these firms are relying on High Commitment Work Practices (HCWPs) to enhance critical employee behaviors such as service quality and turnover, the analysis presented in this paper raises questions about traditional understandings of commitment in professional service environments. In particular, data from three Danish financial investment PSFs suggest that employees are more committed to developing and promoting their own professions than to the organization itself, which has important implications for the way in which HCWPs are designed and utilized. In addition, the focus of HCWP research has favored the use of social exchange theory as an underpinning framework for considering the impact of HR practices on employee commitment. In the context of PSFs, we question the applicability of social exchange theory and instead draw upon the Ability-Motivation-Opportunity (AMO) framework (1982) to analyze how specific HRM practices contribute to the development of commitment, and to successful organizational outcomes in PSFs.

Business planning in emerging firms : do nascent and young firms use business planning differently

Previous research suggested that due to the uncertainties surrounding the venture creation process, planning activities may be more valuable for already operating firms than for emerging ventures (McGrath and MacMillan, 1995). Business planning may serve different purposes during the early stages of the venture development process. Early planning during the nascent stage may be used to marshal the resources toward the achievement of preliminary goals (Locke and Latham, 2000), to gain external legitimization and funding (Karlssson & Honig, 2009; Stinchcombe, 1965). Planning may reduce the risk of future failure by facilitating the decision making process of launching -or not- the venture (Chwolka & Raith, 2011) by analysing the opportunity and its market potential (Boyd, 1991; Delmar & Shane, 2003). In later stages, planning may have a more internal role and may act as a strategic implementation tool (Brews & Hunt, 1999). However, if the reasons why ventures should engage (Frese, 2009) –or not- (Honig, 2004) in business planning have been investigated quite extensively (Brinckmann et al., 2010), how business plans are actually used over time by new ventures at different stages of their development and how these uses impact the performance of the firms are still unclear.