Double tax agreements and the international allocation of business income in Australia

Increasingly, the effectiveness of the present system of taxation of international businesses is being questioned. The problem associated with the taxation of such businesses is twofold. A system of international taxation must be a fair and equitable system, distributing profits between the relevant jurisdictions and, in doing so, avoiding double taxation. At the same time, the prevention of fiscal evasion must be secured. In an attempt to achieve a fair and equitable system Australia adopts unilateral, bilateral and multilateral measures to avoid double taxation and restrict the avoidance of tax. The first step in ascertaining the international allocation of business income is to consider the taxation of business income according to domestic law, that is, the unilateral measures. The treatment of international business income under the Australian domestic law, that is, the Income Tax Assessment Act 1936 (Cth) and Income Tax Assessment Act 1997 (Cth), will depend on two concepts, first, whether the taxpayer is a resident of Australia and secondly, whether the income is sourced in Australia. After the taxation of business profits has been determined according to domestic law it is necessary to consider the applicability of the bilateral measures, that is, the Double Tax Agreements (DTAs) to which Australia is a party, as the DTAs will override the domestic law where there is any conflict. Australia is a party to 40 DTAs with another seven presently being negotiated. The preamble to Australia's DTAs provides that the purpose of such agreements is 'to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income'. Both purposes, for different reasons, are equally important. It has been said that: The taxpayer hopes the treaty will prevent the double taxation of his income; the tax gatherer hopes the treaty will prevent fiscal evasion; and the politician just hopes. The first purpose, the avoidance of double taxation, is achieved through the provision of rules whereby the Contracting States agree to the classification of income and the allocation of that income to a particular State. In this sense DTAs do not allocate jurisdiction to tax but rather provide an arrangement whereby the States agree to restrict their substantive law. The restriction is either through the non-taxing of the income or via the provision of a tax credit.

The Cube : a very large-scale interactive engagement space

“The Cube” is a unique facility that combines 48 large multi-touch screens and very large-scale projection surfaces to form one of the world’s largest interactive learning and engagement spaces. The Cube facility is part of the Queensland University of Technology’s (QUT) newly established Science and Engineering Centre, designed to showcase QUT’s teaching and research capabilities in the STEM (Science, Technology, Engineering, and Mathematics) disciplines. In this application paper we describe, the Cube, its technical capabilities, design rationale and practical day-to-day operations, supporting up to 70,000 visitors per week. Essential to the Cube’s operation are five interactive applications designed and developed in tandem with the Cube’s technical infrastructure. Each of the Cube’s launch applications was designed and delivered by an independent team, while the overall vision of the Cube was shepherded by a small executive team. The diversity of design, implementation and integration approaches pursued by these five teams provides some insight into the challenges, and opportunities, presented when working with large distributed interaction technologies. We describe each of these applications in order to discuss the different challenges and user needs they address, which types of interactions they support and how they utilise the capabilities of the Cube facility.

Monocular vision based autonomous navigation for a cost-effective MAV in GPS-denied environments

In this paper, we present a monocular vision based autonomous navigation system for Micro Aerial Vehicles (MAVs) in GPS-denied environments. The major drawback of monocular systems is that the depth scale of the scene can not be determined without prior knowledge or other sensors. To address this problem, we minimize a cost function consisting of a drift-free altitude measurement and up-to-scale position estimate obtained using the visual sensor. We evaluate the scale estimator, state estimator and controller performance by comparing with ground truth data acquired using a motion capture system. All resources including source code, tutorial documentation and system models are available online.

A data mining driven risk profiling method for road asset management

Road surface skid resistance has been shown to have a strong relationship to road crash risk, however, applying the current method of using investigatory levels to identify crash prone roads is problematic as they may fail in identifying risky roads outside of the norm. The proposed method analyses a complex and formerly impenetrable volume of data from roads and crashes using data mining. This method rapidly identifies roads with elevated crash-rate, potentially due to skid resistance deficit, for investigation. A hypothetical skid resistance/crash risk curve is developed for each road segment, driven by the model deployed in a novel regression tree extrapolation method. The method potentially solves the problem of missing skid resistance values which occurs during network-wide crash analysis, and allows risk assessment of the major proportion of roads without skid resistance values.

Information skills coursework for postgraduate students : investigation and response at the Queensland University of Technology

In response to current developments In the tertiary education sector, the Queensland University of Technology Library has mounted an Intensive course - Advanced Information Retrieval Skills - for higher degree students. In determining need for such a course, a survey of postgraduate students and their supervisors was conducted. Results of this survey are discussed and details of the four credit point subjects are outlined.

Fraud risk and the visibility of carbon

In recent years, carbon has been increasingly rendered ‘visible’ both discursively and through political processes that have imbued it with economic value. Greenhouse gas (GHG) emissions have been constructed as social and environmental costs and their reduction or avoidance as social and economic gain. The ‘marketisation’ of carbon, which has been facilitated through various compliance schemes such as the European Union Emissions Trading Scheme (EU ETS), the Kyoto Protocol, the proposed Australian Emissions Reduction Scheme and through the voluntary carbon credit market, have attempted to bring carbon into the ‘foreground’ as an economic liability and/or opportunity. Accompanying the increasing economic visibility of carbon are reports of frauds and scams – the ‘gaming of carbon markets’(Chan 2010). As Lohmann (2010: 21) points out, ‘what are conventionally classed as scams or frauds are an inevitable feature of carbon offset markets, not something that could be eliminated by regulation targeting the specific businesses or state agencies involved’. This paper critiques the disparate discourses of fraud risk in carbon markets and examines cases of fraud within emerging landscapes of green criminology.

Supporting an NGO in Developing Mozambique

Many efforts are made to assist with the advancement of developing economies through the activities of Non Government Organizations (NGOs). There are many management l and engagement issues associated with any successful NGO in a developed economy. When the organization is operating in a developing country, where a lack of infrastructure and education, distrust and corruption are part of the operating environment, the issues multiply. This case study discusses the structure of a NGO started in 2008 and describes the development and interaction of its two main components: a community-based NGO in a developing country and a NGO with a voluntary committee in a developed economy, australia. Despertai Mozambique is the NGO set up in Beira, which provides the necessary support, training and funding to the local poor (defined by the UN as living below the internationally accepted poverty line of US$1.25 a day) to help them set up small, often informal, businesses, to enable them to become sustainable, and ultimately to help alleviate poverty. The partnering Australian organization, Awaken Mozambique, is responsible for providing the necessary intellectual and financial resources required by Despertai Mozambique to operate.

Preparing for performance capture #1

This video article articulates two exercises that have been developed to respond to the need for preparedness in the growing field of Performance Capture. The first is called Walking Through (Delbridge 2013), where the actor navigates a series of objects that exist in screen space through a developed sense of the existing physical particularities of the studio and an interaction with a screen (or feedback loop). The second exercise is called The Donut (Delbridge 2013), where the performer continues to navigate screen space but this time does so through the literal stepping through of a Torus in the virtual – again with nothing but the studio infrastructure and the screen as a guide. Notions of Motion Captured performance infer the existence of an interface that combines performer with system, separating (or intervening in) the space between performance and the screen. It is precisely the effect and provided opportunity of the intermediary device on the practice, craft and preparedness of the actor as they navigate the connection between 3D screen space and the physical properties of the studio that is examined here. Defining the scope of current practice for the contemporary actor is a key construct of this challenge, with the most appropriate definition revolving around the provision of a required mixture of performance and content for live, mediated, framed and variously captured formats. One of these particular formats is Performance Capture. The exercises presented here are two from a series, developed over a three year study that contribute to our understanding of the potential for a training regimen to be developed for the rigors of Performance Capture.

Design LED innovation to rejuvenate local food systems and healthy communities : an emerging research agenda

Food Sovereignty (food freedom) is about empowering people to develop their own local food system. Food Sovereignty challenges designers to enable people to innovate the local food system, rather than having a food system which is dictated by corporate interests and failed business ethics. Communities are realising the potential for design to assist in the innovation process, and add strategic value to potentially localise the food system. Design Led Innovation (DLI) offers a strategic framework to address large-scale cultural, systemic and economic changes. The DLI approach empowers communities to take organised action to achieve a healthy, prosperous and happy way of life. DLI can assist with business models in the business world and it is evident this approach can assist with creating social change too. This paper presents on an emerging research agenda aimed to assist designer’s focus from individuals and systems to communities and urban problems. This paper also presents the research proposition that DLI and service design coupled with social entrepreneurial ventures such as local food projects and creative community inventions, have the potential to enable social innovation for healthy and happy communities.

Reconstructing places and spaces in blended work integrated learning

This paper considers the emergence and ongoing development of an embedded, studentnegotiated work placement model of Work Integrated Learning (WIL) in the engineering and built environment disciplines at an Australian metropolitan university. The characteristics of the model and a continuous improvement strategy are provided. The model is characterised by large student cohorts independently sourcing and negotiating relevant work placements and completing at least one, mandatory credit-bearing WIL unit. Through ongoing analyses and evaluation of the model more experiential and collaborative learning approaches have been adopted. This has included the creation of blended learning spaces using technology. The paper focuses on the five year journey travelled by the teaching team as they embarked on ways to improve curriculum, pedagogy, administrative processes and assessment - effectively relocating much of their interaction with students online. The insights derived from this rich, single case study should be of interest to others considering alternative ways of responding to increasing student enrolments in WIL and the impact of blended learning in this context.

Teaching design thinking and design led innovation to non-designers : a tertiary facilitator multidisciplinary study

This paper aims to address the knowledge gap in regards to the potential intermediary role tertiary institutions can play in developing generic design thinking/design led innovation capabilities in non-designers. Specifically, it investigates the value derived from the contribution of postgraduate design students as facilitators/educators for undergraduate non-design student cohorts. It examines a design immersion workshop designed to encourage the use of design thinking capabilities for project brief development for undergraduate multi-disciplinary student teams involved in a community service learning project for a social enterprise. The workshop was facilitated by design led innovation masters students embedded in industry organisations to research the integration of design led innovation capabilities in business. Data was collected from participating non-design students and postgraduate facilitators’ in the form of reflective journals and semi-structured interviews. The thematic analysis provided insight into the value of design thinking/design led innovation immersion programs for both the postgraduate facilitators and the undergraduate non-design students. The research results will inform a tentative foundation prototype framework to allow for ongoing program developments and research in design thinking/design led innovation integration in higher education, facilitating the development of generic capabilities required to empower future generations for business innovation and active citizenship in the 21st century knowledge economy.

Designing innovative business models: Five emerging meta-models

Business models to date have remained the creation of management, however, it is the belief of the authors that designers should be critically approaching, challenging and creating new business models as part of their practice. This belief portrays a new era where business model constructs become the new design brief of the future and fuel design and innovation to work together at the strategic level of an organisation. Innovation can no longer rely on technology and R&D alone but must incorporate business models. Business model innovation has become a strong type of competitive advantage. As firms choose not to compete only on price, but through the delivery of a unique value proposition in order to engage with customers and to differentiate a company within a competitive market. The purpose of this paper is to explore and investigate business model design through various product and/or service deliveries, and identify common drivers that are catalysts for business model innovation. Fifty companies spanning a diverse range of criteria were chosen, to evaluate and compare commonalities and differences in the design of their business models. The analysis of these business cases uncovered commonalities of the key strategic drivers behind these innovative business models. Five Meta Models were derived from this content analysis: Customer Led, Cost Driven, Resource Led, Partnership Led and Price Led. These five key foci provide a designer with a focus from which quick prototypes of new business models are created. Implications from this research suggest there is no ‘one right’ model, but rather through experimentation, the generation of many unique and diverse concepts can result in greater possibilities for future innovation and sustained competitive advantage.

Early challenges of shifting an Australian manufacturer’s utilisation of design

This paper presents the findings from the initial exploration phase of an 11 month project, identifying the early challenges that a design innovation catalyst faces while initiating a shift in the way a medium sized manufacturing firm utilises design. Ultimately, the overarching aims of the project are to transform the utilisation of design within the participating company from a styling tool to a strategic process through the implementation of a design led approach to innovation. Insights were found through qualitative interviews with company staff and reflective journal entries as part of an Action Research methodology. Challenges identified include managing expectations, conveying the potential of a design innovation catalyst and a design led approach to innovation, and a siloed and risk averse culture. Findings presented in this paper will assist in identifying and understanding the preliminary challenges encountered by a design innovation catalyst when embarking on a design led transformation. Future innovation catalysts can prepare for possible barriers by highlighting considerations, opportunities and challenges when embarking on a design led transformation. Implications of this research are provided as possible approaches to overcoming these challenges.

Can emotion provide a new approach to business model innovation?

Companies require new strategies to drive growth and survival, as the fast pace of change has created the need for greater business flexibility. Therefore, industry leaders are looking to business innovation as a principle source of differentiation and competitive advantage. However, most companies rely heavily on either technology or products to provide business innovation, yet competitors can easily and rapidly surpass these forms of innovation. Business model innovation expands beyond innovation in isolated areas, such as product innovation, to create strategies that incorporate many business avenues to work together to create and deliver value to its customers. Existing literature highlights that a business model’s central role is ‘customer value’. However, the emotional underpinnings of customer value within a business model are not well understood. The integration of customer emotion into business model design and value chain can be viewed as a way to innovate beyond just products, services and processes. This paper investigates the emotional avenues within business strategy and operations, business model innovation and customer engagement. Three propositions are outlined and explored as future research. The significance of this research is to provide companies with a new approach to innovation through a deeper understanding and integration of their customers’ emotions.

From production to purpose : using design led innovation to Build Strategic Potential in a Family-Owned SME

There is an evident need to develop the strategic capabilities of companies from within, to ensure competitive competence in a time where strategy is a necessity. This paper is based on the first 4 months of a longitudinal embedded case study of a family-owned Australian small to medium enterprise, in their journey towards design integration. The first author was embedded as a ‘Design Innovation Catalyst’ to collaborate on overcoming early barriers of strategic development, using design led innovation. Action research methodology, semi-structured interviews with seven out of eight employees and a reflective journal revealed the absence of a shared vision, conflicting drivers and a focus on operational efficiency rather than strategy. Through the Catalyst’s facilitation, a company vision, general awareness, practice and knowledge in strategic development have emerged as the first steps to generating strategic design competence within the firm.