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.

Design and Ethics: Reflections on Practice

This book is an multi disciplinary approach to design thinking across the fields of Architecture, Communication Design, Fashion, Graphic Design, Urban Design and Philosophy.

Framing perspectives on design and ethics

This chapter discusses design thinking and design as a process which spans all spheres of everyday life.

Reply to Camens : how recently did modern monotremes diversify?

Camens (1) responds to our analysis of morphological data (2) in which platypuses (Ornithorhynchidae) and echidnas (Tachyglossidae) were inferred to be each other's closest relatives, to the exclusion of Early Cretaceous forms, Teinolophos and Steropodon. Our phylogeny is consistent with the late appearance of undisputed fossil echidnas and platypuses. Molecular dating provided important independent corroboration, revealing that platypuses and echidnas diverged only 19–48 Ma, implying that Teinolophos and Steropodon (105–121 Ma) must lie outside the platypus–echidna dichotomy...

Strolling through the (post)modern city: Modes of being a flaneur in picture books

The city and the urban condition, popular subjects of art, literature, and film, have been commonly represented as fragmented, isolating, violent, with silent crowds moving through the hustle and bustle of a noisy, polluted cityspace. Included in this diverse artistic field is children’s literature—an area of creative and critical inquiry that continues to play a central role in illuminating and shaping perceptions of the city, of city lifestyles, and of the people who traverse the urban landscape. Fiction’s textual representations of cities, its sites and sights, lifestyles and characters have drawn on traditions of realist, satirical, and fantastic writing to produce the protean urban story—utopian, dystopian, visionary, satirical—with the goal of offering an account or critique of the contemporary city and the urban condition. In writing about cities and urban life, children’s literature variously locates the child in relation to the social (urban) space. This dialogic relation between subject and social space has been at the heart of writings about/of the flâneur: a figure who experiences modes of being in the city as it transforms under the influences of modernism and postmodernism. Within this context of a changing urban ontology brought about by (post)modern styles and practices, this article examines five contemporary picture books: The Cows Are Going to Paris by David Kirby and Allen Woodman; Ooh-la-la (Max in love) by Maira Kalman; Mr Chicken Goes to Paris and Old Tom’s Holiday by Leigh Hobbs; and The Empty City by David Megarrity. I investigate the possibility of these texts reviving the act of flânerie, but in a way that enables different modes of being a flâneur, a neo-flâneur. I suggest that the neo-flâneur retains some of the characteristics of the original flâneur, but incorporates others that take account of the changes wrought by postmodernity and globalization, particularly tourism and consumption. The dual issue at the heart of the discussion is that tourism and consumption as agents of cultural globalization offer a different way of thinking about the phenomenon of flânerie. While the flâneur can be regarded as the precursor to the tourist, the discussion considers how different modes of flânerie, such as the tourist-flâneur, are an inevitable outcome of commodification of the activities that accompany strolling through the (post)modern urban space.

Second Life machinima enhancing the learning of law : Lessons from successful endeavours

A traditional approach centred on weekly lectures, perhaps supported by a tutorial programme, still predominates in modern legal education in Australia. This approach tends to focus on the transmission of knowledge about legal rules and doctrine to students who adopt a largely passive role. Criticisms of the traditional approach have led to law schools expanding their curricula to include the teaching of skills, including the skill of negotiation and an appreciation of legal ethics and professional responsibility. However, in a climate of limited government funding for law schools in Australia, innovation in legal education remains a challenge. This paper considers the successful use of Second Life machinima in two programs, Air Gondwana and Entry into Valhalla and their part in the creation of engaging, effective learning environments. These programs not only engage students in active learning but also facilitate flexibility in their studies and other benefits. The programs yield important lessons concerning the use of machinima innovations in curricula, not only for academics involved in legal education but also those in other disciplines, especially those that rely on traditional passive lectures in their teaching and learning approaches.

Sustainable, smart, safe : a 3'S' approach towards a modern transportation system

Sustainability, smartness and safety are three sole components of a modern transportation system. The objective of this study is to introduce a modern transportation system in the light of a 3‘S’ approach: sustainable, smart and safe. In particular this paper studies the transportation system of Singapore to address how this system is progressing in this three-pronged approach towards a modern transportation system. While sustainability targets environmental justice and social equity without compromising economical efficiency, smartness incorporates qualities like automated sensing, processing and decision making, and action-taking into the transportation system. Since a system cannot be viable without being safe, the safety of the modern transportation system aims minimizing crash risks of all users including motorists, motorcyclists, pedestrians, and bicyclists. Various policy implications and technology applications inside the transportation system of Singapore are discussed to illustrate a modern transportation system within the framework of the 3‘S’ model.