Interjurisdictional allocation of multinational banking income : aligning taxation principles with economic activity

This thesis argues that one type of multinational entity – the multinational bank – poses particularly significant challenges to the international tax regime in terms of its current profit allocation rules. Multinational banks are a unique subset of multinational entities, and as a consequence of their unique traits, the traditional international tax regime foes not yield an optimal interjurisdictional allocation of taxing rights. The opportunity for tax minimisation, achievable because of the unique traits, and realised through exploitation of the traditional source and transfer pricing regime, results in a jurisdictional distribution of taxing rights which does not reflect economic reality. There are two distinct ways in which the traditional international tax regime fails to reflect economic activity. The first way that economic activity may not be reflected in the distribution of the taxing rights to income from multinational banking is through the application of traditional source rules. The traditional sources rules allocate income where transactions are completed rather than where the intermediation services are arranged. As a result of their unique commercial role as financial intermediaries, by separating intermediary economic activity from legal transactions with third parties, multinational banks may distort the true location of the activity giving rise to income. The second way in which the traditional tax regime may fail to reflect economic activity is through the traditional transfer pricing regime requiring related or internal transaction to be undertaken at an arm’s length price. The arm’s length pricing requirement is theoretically deficient in its failure to recognise the highly integrated nature of multinational banking. In practice, the arm’s length pricing requirement is also difficult, if not impossible, to apply to multinational banks because of the requirement of comparability. The difficulties associated with the current model have resulted in a subtle move by multinational banks towards global formulary apportionment. This thesis concludes that, for the international taxation of multinational banks, the current source regime should be replaced with a system that allocates profits for tax purposes on the basis of income source, with source determined using a unitary taxation or global formulary apportionment system. It is argued that global formulary apportionment is a theoretically superior model that provides both jurisdiction to tax and allocated profits on the basis of the economic activity that generates the income.

Islamisation of Bosnia : early Islamic influence on Bosnian society

This Masters thesis examines the process of the Islamisation of Bosnia from the eighth century to the end of the fifteenth century. This era of early Islamic influence has not previously been systematically studied, and remains an area little understood by many medievalists. The major foci of the analysis are the pre-Ottoman era and early Ottoman periods. This thesis raises the following research questions: When and how did the first Islamisation of the Balkan Slavs (including Bosnians) occur? How did Islam influence Bosnian society and culture, and where were the Bosnian Muslim settlements established? This thesis includes a detailed historical investigation that makes use of a range of bibliographic materials. These consist of fragmentary works, archival and administrative documents and other relevant factography collected from a research field trip to Bosnia between June 27 and July 24, 2003. The main findings reveal the complexity of this culturo-religious process in terms of both the early Islamic influence and contemporary cultural diversity. While different theoretical approaches to cultural representation and social space assist in exploring the hybrid nature of Bosniak identity, the primary and secondary data analyses highlight the significance of the phenomenon of the early Islamisation of Bosnia

The privatisation experience in banking and insurance in Australia

The role of ownership in performance of financial institutions is under-examined yet remains a topical issue. Whilst ownership changes in the banking sector have been evaluated in several studies, the link with other sectors has not been a focus of in depth analysis. A controlled comparison of performance between privatising banks and insurance firms in Australia is undertaken via a ‘meso’ approach of pairing privatising with comparator private institutions across the event period. Performance is evaluated using commercial CAMEL indicators and applying Wilcoxon rank tests (Otchere and Chan 2003) which provide statistically robust findings in the small annual data samples available around the privatisation event. Performance of privatising and private institutions is found to be quite similar before and after the event. For the privatising banks, some indicator medians improved to commercial levels (CBA) or were mostly unchanged (Colonial). By contrast one of the privatising insurance institutions (Suncorp) was found to outperform the private insurance comparator while there was little difference for the other (GIO).

A comparative study of banking in China and India, non-performing loans and the level playing field

It has become common in the literature to compare India and China, two remarkably growing economies, but these comparisons often do not take into account the institutional differences between these two countries. We have in this paper done a comparative analysis of banking institutions in China and India taking into accounts the contentious issue of nonperforming loans along with the issue of use of banks to provide countervailable subsidies to exporting organizations. Our research shows that the efficiency differences between banks in these two countries can be directly related to institutional difference and any comparative study between these countries not taking into consideration these institutional differences may lead to misleading results.

A comparative study of banking in China and India, nonperforming loans and the level playing field

It has become common in literature to compare India and China two remarkably growing economies but these comparisons often do not take into account the institutional differences between two countries. We have in this paper done a comparative analysis of banking institutions in China and India taking into accounts the contentious issue of nonperforming loans along with the issue of use of banks to provide countervailable subsidies to exporting organizations. Our research shows that the efficiency differences between banks in these two countries can be directly related to institutional difference between two countries and any comparative study between two countries not taking into consideration these institutional differences may lead to misleading results.

Dot.Com rise as an indicator of business growth and economic progress : a retrospective view on telecom and banking sectors in Australia and India

In the year 2000, businesses in banking and telecom sectors worldwide re-engineered their value chain by extending their services by adapting ebusiness through dot.com launches. Subsequently, their validity became questionable with the spate of dot.com crashes and the IT stock meltdown. This book takes a retrospective view, indicating that e-business, as measured by dot.com growth trends, was a positive indicator for business growth in the sector and overall economic growth as it stimulated the respective economies. The book details an inductive analysis that studied if dot.com floats suggested any positive market capitalisation (broadly regarded as a measure of profitability) for the organisations, within two sectors, in two economies. In addition, there is detailed content analysis of global business trends, drivers, theories, sector/economy perspectives, achieved progress and instrumental cases. The book will be a view in retrospect for economists, business analysts, students of ebusiness and management (particularly MBA); academics and researchers.

Social cognitive theory in mobile banking innovations

This paper examines the behavior Australian youths have toward mobile banking. Social cognitive theory is the theoretical framework in which a conceptual model is empirically tested. The conceptual model includes five constructs (media, modeling, outcome expectancy, learning orientation and entrepreneurial orientation), which are proposed to influence an individual’s intention to adopt mobile banking. The conceptual model is tested in a sample of Australian youths and the analysis supports a portion of the proposed conceptual model. The findings support the link between the media and an individual’s entrepreneurial orientation with their intention to adopt mobile banking. The paper demonstrates how social cognitive theory is a useful foundation to understand the external and internal stimuli that influence an individual’s desire to adopt mobile banking.

Mobile banking innovations and entrepreneurial adoption decisions

This paper examines an individual’s entrepreneurial adoption decisions to use mobile banking for both business and social reasons. A conceptual model based on social cognitive theory is developed to explain an individual’s propensity to adopt mobile banking. The theoretical framework examines how advertising, experience, perceived risk, learning inclination, and entrepreneurial proclivity influence a person’s intention to use mobile banking. This paper stresses the role of financial risk in determining a person’s intention to use mobile banking and whether their entrepreneurial nature is influenced by their experience and advertising they are subjected to about the advantages or disadvantages of mobile banking. This paper ties together research on technological innovation with entrepreneurship and learning studies. The author stresses the importance for financial institutions to market the innovativeness of mobile banking whilst addressing security concerns. The impact of a person’s social environment through personal contacts and acquaintances underpins social cognitive theory and helps to understand the motives for a person adopting mobile banking. The paper integrates mobile banking literature with current thinking on the importance of entrepreneurship and learning influences to how a person adopts a technological innovation.

Islamic gardens between restoration and replacement

Architecture is considered the visible reflection of the local character of contexts. Therefore, conserving the architectural heritage is becoming one of the critical concepts in life, especially with the rapid change and transformation characterizing the globalization era. As a vital part of the broader context of the architecture; landscape architecture is also considered an effective tool of societies’ self representation. Gardens reflect a very special relationship between the man and nature and represent the history of the state of societies in which they were developed. Islamic gardens are one of the historic gardens having a special charm of their own. Gardens associated with Islamic period over several hundred years, are designed according to certain ideological principles employing certain physical elements shown in the west as well as the east. They represent an ideological continuity which is unique in its spread and development over a wide range of geographical and cultural regions. The Islamic architectural heritage is usually well protected. In the restoration process, the historic buildings are returned back to their original conditions. However, with the changing nature of gardens; it is sometimes hard to track back their original state. In that case, in order to conserve those gardens; it is important to study the design principles upon which the physical elements were chosen. In this paper, the principles of design of the original Islamic gardens will be reviewed through a quantitative analysis of a questionnaire. These principles will be compared to the current situation of the garden of Humayun’s Tomb built in the Mughal era in India, after its conservation in 2003.