A nation’s role in addressing base erosion and profit shifting : balancing sovereignty with international collaboration and coordination

The notion of sovereignty is central to any international tax issue. While a nation is free to design its tax laws as it sees fit and raise revenue in accordance with the needs of its citizens, it is not possible to undertake such a task in isolation. In a world of cross-border investments and business transactions, all tax regimes impact on one another. Tax interactions between sovereign states cannot be avoided. Ultimately, the interactions mean that a nation must decide whether to engage in both collaboration and coordination with other nations and supranational bodies alike or maintain an individualised stance in relation to its tax policy. Whatever the decision, there is arguably an exercise in national sovereignty in some form. In the context of an international tax regime, whether that regime is interpreted broadly as meaning international norms generally adopted by nations around the world or domestic regimes legislating for cross-border transactions, rhetoric around national fiscal sovereignty takes on many different forms. At one end of the spectrum it is relied upon by financial secrecy jurisdictions (tax havens) as a defence to their position on the basis that ‘other’ nations cannot interfere with the fiscal sovereignty of a jurisdiction. At the other end of the spectrum, it is argued that profit shifting and international tax avoidance if not stopped is, in and of itself, a threat to a nation’s fiscal sovereignty on the basis that it threatens the ability to tax and raise the revenue needed. This paper considers a modern conceptualisation of sovereignty along with its role within international tax coordination and collaboration to argue that a move towards a more unified approach to addressing international base erosion and profit shifting may be the ultimate exercise of national fiscal sovereignty. By using the current transfer pricing regime as a case study, this paper posits that it is not merely enough to have international agreement on allocation rules to be applied, but that the ultimate exercise of national sovereignty is political agreement with other states to ensure that it is governments which determine the allocational basis of worldwide profits to be taxed. In doing so, it is demonstrated that the arm’s length pricing requirement of the current transfer pricing regime, rather than providing governments with the ability to determine the location of profits, is providing multinational entities with the ultimate power to determine that location. If left unchecked, this will eventually erode a nation’s ability to capture the required tax revenue and, as a consequence, may be deemed a failure by nation states to exercise their fiscal sovereignty.

A nation's role in addressing base erosion and profit shifting : sovereignty in relation to transfer pricing

The notion of sovereignty is central to any international tax issue. While a nation is free to design its tax laws as it sees fit and raise revenue in accordance with the needs of its citizens, it is not possible to undertake such a task in isolation. Tax interactions between sovereign states cannot be avoided. Ultimately, the interactions mean that a nation must decide whether or engage in both collaboration and co ordination with other nations and supranational bodies alike or maintain a unilateral stance in relation to its tax policy. This article considers a modern conceptualisation of sovereignty to argue that a move towards a more unified approach to addressing international base erosion and profit sharing may be the ultimate exercise of national fiscal sovereignty.

Task profiling : A task-Based approach to measuring the integration of ICT in the classroom

The measurement of ICT (information and communication technology) integration is emerging as an area of research interest with such systems as Education Queensland including it in their recently released list of research priorities. Studies to trial differing integration measurement instruments have taken place within Australia in the last few years, particularly Western Australia (Trinidad, Clarkson, & Newhouse, 2004; Trinidad, Newhouse & Clarkson, 2005), Tasmania (Fitzallen 2005) and Queensland (Finger, Proctor, & Watson, 2005). This paper will add to these investigations by describing an alternate and original methodological approach which was trialled in a small-scale pilot study conducted jointly by Queensland Catholic Education Commission (QCEC) and the Centre of Learning Innovation, Queensland University of Technology (QUT) in late 2005. The methodology described is based on tasks which, through a process of profiling, can be seen to be artefacts which embody the internal and external factors enabling and constraining ICT integration.

Attention and memory bias for body image and health related information using an Emotional Stroop task in a non-clinical sample

It has been proposed that body image disturbance is a form of cognitive bias wherein schemas for self-relevant information guide the selective processing of appearancerelated information in the environment. This threatening information receives disproportionately more attention and memory, as measured by an Emotional Stroop and incidental recall task. The aim of this thesis was to expand the literature on cognitive processing biases in non-clinical males and females by incorporating a number of significant methodological refinements. To achieve this aim, three phases of research were conducted. The initial two phases of research provided preliminary data to inform the development of the main study. Phase One was a qualitative exploration of body image concerns amongst males and females recruited through the general community and from a university. Seventeen participants (eight male; nine female) provided information on their body image and what factors they saw as positively and negatively impacting on their self evaluations. The importance of self esteem, mood, health and fitness, and recognition of the social ideal were identified as key themes. These themes were incorporated as psycho-social measures and Stroop word stimuli in subsequent phases of the research. Phase Two involved the selection and testing of stimuli to be used in the Emotional Stroop task. Six experimental categories of words were developed that reflected a broad range of health and body image concerns for males and females. These categories were high and low calorie food words, positive and negative appearance words, negative emotion words, and physical activity words. Phase Three addressed the central aim of the project by examining cognitive biases for body image information in empirically defined sub-groups. A National sample of males (N = 55) and females (N = 144), recruited from the general community and universities, completed an Emotional Stroop task, incidental memory test, and a collection of psycho-social questionnaires. Sub-groups of body image disturbance were sought using a cluster analysis, which identified three sub-groups in males (Normal, Dissatisfied, and Athletic) and four sub-groups in females (Normal, Health Conscious, Dissatisfied, and Symptomatic). No differences were noted between the groups in selective attention, although time taken to colour name the words was associated with some of the psycho-social variables. Memory biases found across the whole sample for negative emotion, low calorie food, and negative appearance words were interpreted as reflecting the current focus on health and stigma against being unattractive. Collectively these results have expanded our understanding of processing biases in the general community by demonstrating that the processing biases are found within non-clinical samples and that not all processing biases are associated with negative functionality

Final report : task 2 : design guidelines for delivering high quality indoor environments

This report is for one of the four Tasks of the CRC project ‘Regenerating Construction to Enhance Sustainability’. The report specifically addresses Task 2 ‘Design guidelines for delivering high quality indoor environments’.

Final report : task 3: occupant health, wellbeing and productivity

This report presents the results of a study on indoor environment quality (IEQ) and occupant productivity in two buildings that are owned and Occupied by City of Melbourne, and located next to each other in Central Melbourne, Council House 1 (CH1) and Council House 2 (CH2). The impact of a range of relevant IEQ and other parameters on health, wellbeing and productivity of occupants is assessed. The before-and-after case study has demonstrated that the productivity of office building occupants can potentially be enhanced through good building design, and provision of a high quality, healthy, comfortable and functional interior environment, that takes account of basic occupant needs. It has shown that good indoor environment quality is a necessary pre-requisite for enhanced productivity in office buildings, but that broader aspects of overall building and interior design are also important.

Final report : task 4 : waste minimisation in construction

The Regenerating Construction Project for the CRC for Construction Innovation aims to assist in the delivery of demonstrably superior ‘green’ buildings. Components of the project address eco-efficient redesign, achieving a smaller ecological footprint, enhancing indoor environment and minimising waste in design and construction. The refurbishment of Council House 1 for Melbourne City Council provides an opportunity to develop and demonstrate tools that will be of use for commercial building refurbishment generally. It is hoped that the refurbishment will act as an exemplar project to demonstrate environmentally friendly possibilities for office building refurbishment.

“I woke up and realised the ground had shifted”: the shifting terrain of English curriculum

The theme of this conference comes from the epitaph on the Lewis Carroll’s gravesite. “Is All our Life then But A Dream?” This seems fitting for a time when so much change in the terrain of English makes us feel as if we are somnambulating through a surrealist landscape. Like Lewis Carroll’s Alice, (Carroll, 2003) we might find ourselves at strange tea parties with bureaucratic mad hatters, and just when we think we have a grasp of applying new theory in our teaching, we fall down another rabbit hole, to swim in confusion as some queen calls out, ‘off with their heads!’. The shifting ground in English inevitably moves in response to waves of theory influencing classroom practice. Each new paradigm has claimed to liberate language learners from the flaws of the previous model. Each linguist or literary theorist who shaped the new paradigm no doubt dreamt of a new population emerging from school as more powerfully literate citizens than the previous generation.

A model to predict hypovigilance during a monotonous task

The driving task requires sustained attention during prolonged periods, and can be performed in highly predictable or repetitive environments. Such conditions could create drowsiness or hypovigilance and impair the ability to react to critical events. Identifying vigilance decrement in monotonous conditions has been a major subject of research, but no research to date has attempted to predict this vigilance decrement. This pilot study aims to show that vigilance decrements due to monotonous tasks can be predicted through mathematical modelling. A short vigilance task sensitive to short periods of lapses of vigilance called Sustained Attention to Response Task is used to assess participants’ performance. This task models the driver’s ability to cope with unpredicted events by performing the expected action. A Hidden Markov Model (HMM) is proposed to predict participants’ hypovigilance. Driver’s vigilance evolution is modelled as a hidden state and is correlated to an observable variable: the participant’s reactions time. This experiment shows that the monotony of the task can lead to an important vigilance decline in less than five minutes. This impairment can be predicted four minutes in advance with an 86% accuracy using HMMs. This experiment showed that mathematical models such as HMM can efficiently predict hypovigilance through surrogate measures. The presented model could result in the development of an in-vehicle device that detects driver hypovigilance in advance and warn the driver accordingly, thus offering the potential to enhance road safety and prevent road crashes.

Modeling web search : preliminary results

This paper reports preliminary results from a study modeling the interplay between multitasking, cognitive coordination, and cognitive shifts during Web search. Study participants conducted three Web searches on personal information problems. Data collection techniques included pre- and post-search questionnaires; think-aloud protocols, Web search logs, observation, and post-search interviews. Key findings include: (1) users Web searches included multitasking, cognitive shifting and cognitive coordination processes, (2) cognitive coordination is the hinge linking multitasking and cognitive shifting that enables Web search construction, (3) cognitive shift levels determine the process of cognitive coordination, and (4) cognitive coordination is interplay of task, mechanism and strategy levels that underpin multitasking and task switching. An initial model depicts the interplay between multitasking, cognitive coordination, and cognitive shifts during Web search. Implications of the findings and further research are also discussed.

Working memory correlates of three symptom clusters in schizophrenia

Examined whether discrete working memory deficits underlie positive, negative and disorganised symptoms of schizophrenia. 52 outpatients (mean age 37.5 yrs) with schizophrenia were studied using items drawn from the Positive and Negative Syndrome Scale (PANSS). Linear regression and correlational analyses were conducted to examine whether symptom dimension scores were related to performance on several tests of working memory function. Severity of negative symptoms correlated with reduced production of words during a verbal fluency task, impaired ability to hold letter and number sequences on-line and manipulate them simultaneously, reduced performance during a dual task, and compromised visuospatial working memory under distraction-free conditions. Severity of disorganisation symptoms correlated with impaired visuospatial working memory under conditions of distraction, failure of inhibition during a verbal fluency task, perseverative responding on a test of set-shifting ability, and impaired ability to judge the veracity of simple declarative statements. The present study provides evidence that the positive, negative and disorganised symptom dimensions of the PANSS constitute independent clusters, associated with unique patterns of working memory impairment.