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?

Postpositivist research in education : theorising social structure in critical and institutional ethnography

This chapter charts the theories and methods being adopted in an investigation of the 'micro-politics' of teacher education policy reception at a site of higher education in Queensland from 1980 to 1990. The paper combines insights and methods from critical ethnography with those from the institutional ethnography of feminist sociologist Dorothy Smith to link local policy activity at the institutional site to broader social structures and processes. In this way, enquiry begins with--and takes into account--the experiences of those groups normally excluded from mainstream and even critical policy analysis.

VIVO as an Institutional Data Registry

The Queensland University of Technology (QUT) in Brisbane, Australia, is involved in a number of projects funded by the Australian National Data Service (ANDS). Currently, QUT is working on a project (Metadata Stores Project) that uses open source VIVO software to aid in the storage and management of metadata relating to data sets created/managed by the QUT research community. The registry (called QUT Research Data Finder) will support the sharing and reuse of research datasets, within and external to QUT. QUT uses VIVO for both the display and the editing of research metadata.

Gender differences in recreational and transport cycling : a cross-sectional mixed-methods comparison of cycling patterns, motivators, and constraints

Background: Gender differences in cycling are well-documented. However, most analyses of gender differences make broad comparisons, with few studies modeling male and female cycling patterns separately for recreational and transport cycling. This modeling is important, in order to improve our efforts to promote cycling to women and men in countries like Australia with low rates of transport cycling. The main aim of this study was to examine gender differences in cycling patterns and in motivators and constraints to cycling, separately for recreational and transport cycling. Methods: Adult members of a Queensland, Australia, community bicycling organization completed an online survey about their cycling patterns; cycling purposes; and personal, social and perceived environmental motivators and constraints (47% response rate). Closed and open-end questions were completed. Using the quantitative data, multivariable linear, logistic and ordinal regression models were used to examine associations between gender and cycling patterns, motivators and constraints. The qualitative data were thematically analysed to expand upon the quantitative findings. Results: In this sample of 1862 bicyclists, men were more likely than women to cycle for recreation and for transport, and they cycled for longer. Most transport cycling was for commuting, with men more likely than women to commute by bicycle. Men were more likely to cycle on-road, and women off-road. However, most men and women did not prefer to cycle on-road without designed bicycle lanes, and qualitative data indicated a strong preference by men and women for bicycle-only off-road paths. Both genders reported personal factors (health and enjoyment related) as motivators for cycling, although women were more likely to agree that other personal, social and environmental factors were also motivating. The main constraints for both genders and both cycling purposes were perceived environmental factors related to traffic conditions, motorist aggression and safety. Women, however, reported more constraints, and were more likely to report as constraints other environmental factors and personal factors. Conclusion: Differences found in men’s and women’s cycling patterns, motivators and constraints should be considered in efforts to promote cycling, particularly in efforts to increase cycling for transport.

Creating new possibilities : using design processes to overcome constraints

This paper describes how a team from a large company, when faced with a challenge to develop new customers in fast growing international markets, carried out the exploration of the needs of new clients in the largely unexplored market space of a developing country. This team used design methods and processes to identify the latent needs of new customers in situations of major economic, geographical, cultural and financial constraints. This encapsulation of the life experiences of potential customers is used extensively in some new product development, but is largely novel to business practices and in processes of developing new services. This research links with the sub-theme of discovering creativity in necessity and highlights the potential benefits of design methodologies to create new possibilities for better accessibility of the company’s products to new clients, with future implications for organizational strategy. The overall theme of Design for the Colloquium encourages exploration of the ways and means of developing new ideas for new business with better outcomes, using design concepts and design technologies.

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

Neither an international tax, nor an international taxing body exists. Rather, there are domestic taxing rules adopted by jurisdictions which, coupled with double tax treaties, apply to cross-border transactions and international taxation issues. International bodies such as the OECD and UN, which provide guidance on tax issues, often steer and supplement these domestic adoptions but have no binding international taxing powers. These pragmatic realities, together with the specific use of the word ‘regime’ within the tax community, lead many to argue that an international tax regime does not exist. However, an international tax regime should be defined no differently to any other area of international law and when we step outside the confines of tax law to consider the definition of a ‘regime’ within international relations it is possible to demonstrate that such a regime is very real. The first part of this article, by defining an international tax regime in a broader and more traditional context, also outlining both the tax policy and principles which frame that regime, reveals its existence. Once it is accepted that an international tax regime exists, it is possible to consider its adoption by jurisdictions and subsequent constraints it places on them. Using the proposed changes to transfer pricing laws as the impetus for assessing Australia’s adoption of the international tax regime, the constraints on sovereignty are assessed through a taxonomy of the level adoption. This reveals the subsequent constraints which flow from the broad acceptance of an international tax regime through to the specific adoption of technical detail. By undertaking this analysis, the second part of this article demonstrates that Australia has inherently adopted an international tax regime, with a move towards explicit adoption and a clear embedding of its principles within the domestic tax legislation.

Informational constraints on the emergence of passing direction in the team sport of futsal

This study investigated compound spatial and temporal measures of interpersonal interactions purported to constrain the emergence of affordances for passing direction in the team sport of futsal. For this purpose, attacker–defender interactions in 37 sequences of play from a futsal competition in which 24 male professional players participated (M=30.04 years, SD=4.10) were filmed and analysed using TACTO software. Relative angle data were used as measures to study coordination tendencies that emerged between players during performance. Results showed that the direction for a pass emerged from relative angles between: (1) the vector from a ball carrier to ball receiver and the vector from the ball carrier to the nearest defender (70°) (p<0.01) and (2) the vector from a ball carrier to ball receiver and the vector from the ball carrier to a ball receiver's nearest defender (31°) (p < 0.01). Furthermore, passing direction was also constrained by temporal information from the emergence of both angles, since the pass was performed to attacker–defender dyads with the highest velocities of these angles (p < 0.05). Results suggested that decisions on selecting the direction of a pass in the team sport of futsal emerged at critical values of these key compound motion measures.

Institutional and individual labor market discrimination based on hukou status : an artefactual field experiment

We study discrimination based on the hukou system that segregates citizens in groups of migrants and locals in urban China. We use an artefactual field experiment with a labor market framing. We recruit workers on their real labor market as experimental participants and investigate if official discrimination motivates individual discrimination based on hukou status. In our experimental results we observe discrimination based on the hukou characteristic: however, statistical discrimination does not seem to be the source of this, as status is exogeneous for our participants and migrants and locals behave similarly. Furthermore, discrimination increases between two experimental frameworks when motives for statistical discrimination are removed.

PartSS : An efficient partition-based filtering for edit distance constraints

This paper introduces PartSS, a new partition-based fil- tering for tasks performing string comparisons under edit distance constraints. PartSS offers improvements over the state-of-the-art method NGPP with the implementation of a new partitioning scheme and also improves filtering abil- ities by exploiting theoretical results on shifting and scaling ranges, thus accelerating the rate of calculating edit distance between strings. PartSS filtering has been implemented within two major tasks of data integration: similarity join and approximate membership extraction under edit distance constraints. The evaluation on an extensive range of real-world datasets demonstrates major gain in efficiency over NGPP and QGrams approaches.

An evolutionary computation approach to three-dimensional path planning for unmanned aerial vehicles with tactical and kinematic constraints

This paper presents a novel evolutionary computation approach to three-dimensional path planning for unmanned aerial vehicles (UAVs) with tactical and kinematic constraints. A genetic algorithm (GA) is modified and extended for path planning. Two GAs are seeded at the initial and final positions with a common objective to minimise their distance apart under given UAV constraints. This is accomplished by the synchronous optimisation of subsequent control vectors. The proposed evolutionary computation approach is called synchronous genetic algorithm (SGA). The sequence of control vectors generated by the SGA constitutes to a near-optimal path plan. The resulting path plan exhibits no discontinuity when transitioning from curve to straight trajectories. Experiments and results show that the paths generated by the SGA are within 2% of the optimal solution. Such a path planner when implemented on a hardware accelerator, such as field programmable gate array chips, can be used in the UAV as on-board replanner, as well as in ground station systems for assisting in high precision planning and modelling of mission scenarios.

Factors that influence Chinese TEFL academics' research capacity building : an institutional case study

Research capacity building has become a prominent theme in higher education institutions across the world. To build research capacity, it is necessary to identify areas of challenges academics face within the academia. This case study focuses on Chinese teaching English as a foreign language (TEFL) academics with the purpose of identifying factors that influence their research capacity building. Six TEFL academics from a Chinese national university were interviewed and institutional research documents were analysed. Findings showed that obstacles and difficulties in conducting research were more related to departmental factors than individual characteristics. The institution was keen on developing a research culture, and encouraged research and publications. Departmental support for research was improving, but it seems that it was more generic than tailored to individual needs. The findings of this study provide implications for research administrators in further supporting TEFL academics’ research capacity building.

Grouping people in social networks using a weighted multi-constraints clustering method

Grouping users in social networks is an important process that improves matching and recommendation activities in social networks. The data mining methods of clustering can be used in grouping the users in social networks. However, the existing general purpose clustering algorithms perform poorly on the social network data due to the special nature of users' data in social networks. One main reason is the constraints that need to be considered in grouping users in social networks. Another reason is the need of capturing large amount of information about users which imposes computational complexity to an algorithm. In this paper, we propose a scalable and effective constraint-based clustering algorithm based on a global similarity measure that takes into consideration the users' constraints and their importance in social networks. Each constraint's importance is calculated based on the occurrence of this constraint in the dataset. Performance of the algorithm is demonstrated on a dataset obtained from an online dating website using internal and external evaluation measures. Results show that the proposed algorithm is able to increases the accuracy of matching users in social networks by 10% in comparison to other algorithms.

Research data finder : an institutional metadata repository

QUT’s new metadata repository (data registry), Research Data Finder, has been designed to promote the visibility and discoverability of QUT research datasets. Funded by the Australian National Data Service (ANDS), it will provide a qualitative snapshot of research data outputs created or collected by members of the QUT research community that are available via open or mediated access. As a fully integrated metadata repository Research Data Finder aligns with institutional sources of truth, such as QUT’s research administrative system, ResearchMaster, as well as QUT’s Academic Profiles system to provide high quality data descriptions that increase awareness of, and access to, shareable research data. In addition, the repository and its workflows are designed to foster smoother data management practices, enhance opportunities for collaboration and research, promote cross-disciplinary research and maximize existing research datasets. The metadata schema used in Research Data Finder is the Registry Interchange Format - Collections and Services (RIF-CS), developed by ANDS in 2009. This comprehensive schema is potentially complex for researchers; unlike metadata for publications, which are often made publicly available with the official publication, metadata for datasets are not typically available and need to be created. Research Data Finder uses a hybrid self-deposit and mediated deposit system. In addition to automated ingests from ResearchMaster (research project information) and Academic Profiles system (researcher information), shareable data is identified at a number of key “trigger points” in the research cycle. These include: research grant proposals; ethics applications; Data Management Plans; Liaison Librarian data interviews; and thesis submissions. These ingested records can be supplemented with related metadata including links to related publications, such as those in QUT ePrints. Records deposited in Research Data Finder are harvested by ANDS and made available to a national and international audience via Research Data Australia, ANDS’ discovery service for Australian research data. Researcher and research group metadata records are also harvested by the National Library of Australia (NLA) and these records are then published in Trove (the NLA’s digital information portal). By contributing records to the national infrastructure, QUT data will become more visible. Within Australia and internationally, many funding bodies have already mandated the open access of publications produced from publicly funded research projects, such as those supported by the Australian Research Council (ARC), or the National Health and Medical Research Council (NHMRC). QUT will be well placed to respond to the rapidly evolving climate of research data management. This project is supported by the Australian National Data Service (ANDS). ANDS is supported by the Australian Government through the National Collaborative Research Infrastructure Strategy Program and the Education Investment Fund (EIF) Super Science Initiative.

Strategies for gaining and maintaining academic support for the institutional open access repository

The impact of research can be measured by use or citation count. The more widely available that research outputs are; the more likely they are to be used, and the higher the impact. Making the author-manuscript version of research outputs freely available via the institutional repository greatly increases the availability of research outputs and can increase the impact. QUT ePrints, the open access institutional repository of research outputs at Queensland University of Technology (QUT), Australia, was established in 2003 and is managed by the QUT Library. The repository now contains over 39,000 records. More than 21,000 of these records have full-text copies attached as result of continuous effort to maintain momentum and encourage academic engagement. The full-text deposit rate has continued to increase over time and, in 2012 (August, at the time of writing), 88% of the records for works published in 2012 provide access to a full-text copy. Achieving success has required a long term approach to collaboration, open access advocacy, repository promotion, support for the deposit process, and ongoing system development. This paper discusses the various approaches adopted by QUT Library, in collaboration with other areas of the University, to achieve success. Approaches include mainstreaming the repository via having it report to the University Research and Innovation Committee; regular provision of deposit rate data to faculties; championing key academic supporters; and holding promotional competitions and events such as during Open Access Week. Support and training is provided via regular deposit workshops with academics and faculty research support groups and via the provision of online self-help information. Recent system developments have included the integration of citation data (from Scopus and Web of Science) and the development of a statistical reporting system which incentivise engagement.

Instructional constraints on movement and performance of players in the penalty kick

The influence of different instructional constraints on movement organisation and performance outcomes of the penalty kick (PK) was investigated according to participant age. Sixty penalty takers and twelve goalkeepers from two age groups (under 15 and under 17) performed 300 PKs under five different task conditions, including: no explicit instructional constraints provided (Control); instructional constraints on immobility (IMMOBILE) and mobility (MOBILE) of goalkeepers; and, use of keeper-dependent (DEP) and independent (INDEP) strategies by penalty takers. Every trial was video recorded and digitised using motion analysis techniques. Dependent variables (DVs) were: movement speed of penalty takers and the angles between the goalkeeper's position and the goal line (i.e., diving angle), and between the penalty taker and a line crossing the penalty spot and the centre of the goal (i.e., run up angle). Instructions significantly influenced the way that goalkeepers (higher values in MOBILE relative to Control) and penalty takers (higher values in Control than in DEP) used movement speed during performance, as well as the goalkeepers' movements and diving angle (less pronounced dives in the MOBILE condition compared with INDEP). Results showed how different instructions constrained participant movements during performance, although players' performance efficacy remained constant, reflecting their adaptive variability.