Global profit split: An evolutionary approach to international income allocation

International taxation is concerned mainly with the equitable allocation of cross-border income between countries in which income-earning activities take place. Such allocation has traditionally been governed by the arm’s-length principle, which has been interpreted as requiring a comparable transactional pricing approach. This approach assumes that each member of a multinational enterprise (MNE) group is a separate entity and that the transactions between related parties can be separated and compared with arm’s-length transactions. It has, however, proved difficult to apply comparable transactional pricing to internationally integrated businesses, especially those involving intangibles and services, and formulary apportionment has been suggested as an alternative. Essentially, formulary apportionment treats the MNE group as a single economic entity. The group’s profit is allocated to members according to a formula that reflects the particular member’s contribution to the production of that profit. A rich academic literature exists which either defends or attacks this alternative approach. The OECD and national governments have rejected formulary apportionment mainly on the ground that it violates the arm’s-length principle. This article proposes a global profit split (GPS) method for allocating international income. The GPS would allocate the global profit of an integrated business to each country in accordance with the economic contributions made by components of the business located in that country. The allocation would be based on a formula that would reflect the economic factors that contribute to profit making. While the GPS draws on elements of the traditional formulary apportionment and profit split methods, it also differs from them. The author discusses in detail the key issues involved in designing the GPS. She also presents and evaluates the main policy and pragmatic justifications for the adoption of this innovative approach. The author argues that the GPS is not only theoretically and practically superior to traditional income allocation methods, but also consistent with the arm’s-length principle. On the basis of historical developments, interpretation of article 9 of the OECD model tax convention, and international tax policy considerations, the author establishes that the GPS is not a radical departure from the arm’s-length principle, but rather a natural development in its evolution. She concludes that the law of evolution ison the side of reform because the GPS would provide for a fair and effective allocation of income derived from globally integrated business activities.

Southeast Asian perceptions of Australia's foreign policy

This article argues that while the US alliance remains at the forefront of Australian security policy, the deepening of ties between the United States and Australia has the potential to complicate Australia's relations with its Southeast asian neighbours. Moreover, the manner in which the Howard government has attempted to manage this shift in policy has only exacerbated the problem. Australian pronouncements of support for the US policy of pre-emption, the perceived preference of the Australian Prime Minister to take on the role of ‘Deputy Sheriff’, and the unwieldy approach taken by the Australian government in policy announcements pertaining to maritime and security policy have caused unnecessary tension and mistrust between Australia and some Southeast asian states.

International sentencing law: in search of a justification and coherent framework

An international sentencing jurisprudence is emerging from the decisions by the International Criminal Tribunal for the Former Yugoslavia (ICTY or the Yugoslav tribunal) and the International Criminal Tribunal for Rwanda (ICTR or the Rwanda tribunal) (collectively, 'the tribunals'). This article examines international sentencing law and practice and discusses the justification for the practice. International sentencing law has several objectives. The main goals are reconciliation, deterrence, retribution and rehabilitation. The sentencing inquiry is marked by a high degree of discretion and has resulted in sentencers developing a large amount of aggravating and mitigating considerations, such as being in a position of authority, remorse and good character. It is argued that the current international sentencing approach is flawed - fundamentally so. Most of the stated goals of international sentencing in the form of reconciliation, retribution and rehabilitation are either highly speculative or misguided. The only justification for the practice is general deterrence. This is, however, significantly undermined by the selective and infrequent enforcement of crimes within the jurisdiction of such tribunals. The stated aggravated and mitigating considerations are not valid given that they are not justified by reference to the stated aims of sentencing and only serve to undermine the search for a penalty which is commensurate the serious of the offence. This article suggests a coherent framework for international sentencing policy and practice.

Responding to terrorism through networks at sites of critical infrastructure : a case study of Australian airport security networks

The importance of effective multilateral security networks is widely recognised in Australia and internationally as being essential to facilitate the large-scale sharing of information required to respond to the threat of terrorism. Australian national security agencies are currently constructing networks in order to bring the diverse national and international security agencies together to achieve this. This paper examines this process of security network formation in the area of critical infrastructure protection, with particular emphasis on airport security. We address the key issues and factors shaping network formation and the dynamics involved in network practice. These include the need for the networks to extend membership beyond the strictly defined elements of national security; the integration of public and private ‘nodes’ in counter-terrorism ‘networks’; and the broader ‘responsibilisation’ of the private sector and the challenges with ‘enabling’ them in counter-terrorism networks. We argue that the need to integrate public and private agencies in counter-terrorism networks is necessary but faces considerable organisational, cultural, and legal barriers.

Security as an element in environmental assessment and decision making

he prominence of global warming as an environmental issue has illustrated the close relationship between natural resources, ecosystems and global security. Whilst environmental decision making often uses techniques such as economic valuation and risk management, the security component is often not considered, at least not from a security analyst’s perspective. Yet environmental security considerations can be global, regional and/or national in impact. Environmental change and policy can effect human health and well being as well as initiating conflict; it can affect the existence of life itself. These aspects are firmly in the domain of the security discipline although the protection of the global ecosystem has not traditionally been considered by those who create security policy. The idea of environmental/ecological security ranges from the eco-centric approach which examines the impact of human activities that impact on the security of the natural systems to the more traditional anthropocentric perspectives that look at varied issues such as conflict caused by natural resource competition and environmental degradation, and the greening of military operations. This paper will assert that the inclusion of the security factor in policy creation and environmental assessments is essential to give richer solutions to these complex socio-economic and ecological situations. Systems theory over the last few decades has emphasised the inclusion of as many perspectives on messy problems as possible to provide truly systemic outcomes. It is posited that the addition of such concepts as threat analyses will produce more effective and sustainable outcomes.

国际关系发展中安全内涵的演变

This paper focuses on the origin of insecurity, safety and security of the content of the evolution of the concept of traditional security policy with the new security concept.The authors suggest that the contents of security and international relations with the social and historical development of evolving, evolve the main driving force of social progress of productive forces.In different historical periods, most representative of the level of productivity of the things often become the most valuable part of security.Compared with the past, modern security has the following characteristics: the scope of security beyond the region, for the first time the world has meaning; army in modern times to become the country's "principal basis"; to the ideology of nationalism as factors in the country on behalf of security policies and practices play a special role.But national security has an important strategic value of the field is not a qualitative change.Mid-century, the world entered the post-industrial society or information age, the concept of security from the content and form are undergoing a profound transformation.Economic, technological and other factors

Evidence-informed health policy - the crucial role of advocacy

Health policy makers and clinicians often face similar decision-making challenges. The issues are turbulent, characterised by high risk and complexity, often involve value conflicts and occur in settings of rapid change. Policy makers' decisions are under increasing scrutiny for their use of evidence, with many health policies reflecting political influence rather than rigorous analysis. The evidence-based policy movement offers a range of accounts for this. We argue that advocacy in three critical areas helps explain when evidence is used in the policy making process and then contrast the impacts of advocacy for evidence use in two nutrition policy cases.

Contentious Activism and Inter-Korean Relations

In South Korea, the contentious debate over relations with the North transcends traditional considerations of physical and economic security, and political activists play a critical role in shaping the discussion of these issues as they pursue the separate yet connected agendas of democracy, human rights, and unification.

Providing international observers with a better understanding of policymakers’ management of inter-Korean relations, Danielle L. Chubb traces the development of various policy disputes and perspectives from the 1970s through South Korea’s democratic transition. Focusing on four case studies—the 1980 Kwangju uprising, the June 1987 uprising, the move toward democracy in the 1990s, and the decade of “progressive” government that began with the election of Kim Dae Jung in 1997—she tracks activists’ complex views on reunification along with the rise and fall of more radical voices encouraging the adoption of a North Korean–style form of socialism. While these specific arguments have dissipated over the years, their vestiges can still be found in recent discussions over how to engage with North Korea and bring security and peace to the peninsula.

Extending beyond the South Korean example, this examination shows how the historical trajectory of norms and beliefs can have a significant effect on a state’s threat perception and security policy. It also reveals how political activists, in their role as discursive agents, play an important part in the creation of the norms and beliefs directing public debate over a state’s approach to the ethical and practical demands of its foreign policy.

Expertise and the making of world heritage policy

This paper contributes to two emergent areas of scholarship: first, the role of expertise within the domain of cultural heritage practice; and second, international heritage institutions and their processes of governance. It does so by exploring expertise within the context of World Heritage Committee meetings. These forums of international heritage policy formulation have undergone significant changes in recent years, with larger geopolitical forces increasingly shaping process and decisions. This paper foregrounds the idea of these annual meetings as ‘locales’ in order to explore the inflows of expertise that help constitute authoritative decision-making, how expert knowledge is crafted for and by bureaucratic structure, and how the interplay between technical knowledge and politics via an ‘aesthetics of expertise’ bears upon future directions. In offering such an analysis, the paper seeks to add nuance and conceptual depth to our understanding of international conservation policy and the regulatory, governmental practices of organisations such as UNESCO.

A conceptual model for graphical authentication

Reasons for the adoption of smart cards and biometric authentication mechanisms have been discussed in the past, yet many organisations are still resorting to traditional methods of authentication. Passwords possess several encumbrances not the least of which includes the difficulty some users have in remembering them. Often users inadvertently write difficult passwords down near the workstation, which negates any security password authentication, may provide and opens the floodgates to identity theft. In the current mainstream authentication paradigm, system administrators must ensure all users are educated on the need for a password policy, and implement it strictly. This paper discusses a conceptual framework for an alternative authentication paradigm. The framework attempts to reduce complexity for the user as well as increase security at the network and application levels.

The future of the United Nations

TOPICS
The purpose of the UN
The methods the UN uses to promote international security
The problems with UN efforts to promote peace
UN reform
Future dynamics of the UN

Healthy markets - healthy people/ : reforming health care in Cambodia

Health care reform has been described as a global epidemic. This thesis deals with nature and experience of health care reform in developing countries. Increasing privatisation, economic transition, and structural adjustment have provided the context for health system changes. Different approaches to reform have been developed by international organisations such as the World Bank, WHO and UNICEF. What has driven national health care reforms? Are such policies really appropriate to developing countries? Has a consensus now emerged in relation to international health policy? Has a new health care ‘model’ appeared? The study of health care reform in Cambodia is a timely opportunity to investigate the implementation of health care reform under extreme conditions. These conditions include a legacy of genocide, long-term conflict, political isolation, and economic transition. This case study uses both qualitative and quantitative methods and multiple sources of data to analyse the reform program. The study reinforces the conclusion that, under conditions of extreme poverty, market based reforms are likely to have limited positive impact. Rather, understanding the cultural conditions that determine demand, delivering health care of a satisfactory quality, providing appropriate incentives for health practitioners, and supporting services with adequate public funding are the prerequisites for improved service delivery and utilisation. Cambodia's strategy of integrated district health service development and universal population coverage may provide an instructive example of reform. Emerging policy issues identified by this case study include the fundamental role of equity in service provision, the influence of the social determinants of health and illness and interest in the appropriate use of evidence in international health policy-making.

Neoliberalising learning : generating alternate futures consciousness

Both educators and education policies have long claimed a role in preparing students for ‘the future’. This has been referred to as the rhetoric of futures in education, as the notion of a future is assumed, abstract and not articulated (Bateman 2010). Recent research indicates that teachers give little attention to futures thinking in interpreting and enacting curriculum documents. Only when their ‘futures consciousness’ was increased were they able to generate explicit alternate futures scenarios and make connections with learners (Bateman 2012). In light of international education policy agendas pressing countries to adopt economic competitiveness in national curriculum policies, the ‘future’ vision looks narrow and constrained. We argue that current educational reforms in Australia provide little scope to address the concept of multiple futures, which are significant in enabling citizens to shape and contribute in personal, local and global contexts.