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.

Extending the Workers' Compensation Act 1987 (N.S.W.) to include independent contractors and to allow more highly paid workers to insure fully their income, with particular reference to engineers

In mid-1987, the existing workers’ compensation system in New South Wales was replaced by a new Scheme, called ‘WorkCover’. While WorkCover solved a number of the financial problems that had plagued its predecessor, its enactment created other issues. Furthermore, WorkCover has failed to deal with a number of gaps in providing compensation for occupational injuries, most notably those suffered by independent contractors. By combining a study of aspects of industrial law and industrial relations, this thesis will examine some of those problems and gaps, in particular: (a) Should WorkCover be amended to enable independent contractors to come within its ambit? (b) Should there be additional insurance cover available (known as ‘top-up’ insurance) to insure those parts of workers’ wages presently left unprotected by WorkCover? (c) Should workers be permitted to take out another form of ‘top-up’ insurance to increase the quantum of death cover presently provided by the Scheme? (d) Should independent contractors who arc permitted to enter WorkCover also be permitted to obtain the extended cover set out in (b) and (c) above? Where appropriate, the thesis compares WorkCover to the workers’ compensation schemes in other Australian jurisdictions. It develops each of the matters referred to above by referring to the results of the writer’s survey of members of the Institution of Engineers (NSW Branch) which was conducted in May and June 1991.

Income distribution in Australia 1986

This thesis focuses on the distribution of income across income units, as defined by the Australian Bureau of Statistics, in Australia in 1986. An examination of the conceptual issues involved in analysing income distribution is followed by a description of the various statistical and normative inequality measures that may be used to determine the level of inequality. Previous Australian studies is reported on before analysing the 1986 Income Distribution Survey. The analysis focuses on the summary statistical measures of the Gini coefficient the coefficient of variation and the percentile shares. In addition, the contribution of income of various population sub-groups to overall inequality is examined to provide insight into the sources of inequality. To this end, the Gini coefficient is decomposed using a method developed by Fodder (1991), whereby the population is divided into a number of subgroups based on one socio-demographic characteristic at a time. The exact effects of a percentage change in income for a particular sub-group to overall inequality, as well as the elasticity of the Gini coefficient with respect to a sub-group can be computed. The decomposition is undertaken using both the unadjusted and the equivalent gross weekly income. Policy considerations and conclusions regarding the level of inequality as existed in 1986 are suggested in the final chapter.

Trade liberalization and income inequality : a theoretical analysis

[No Abstract]

Estimating income and price elasticities of imports for Fiji in a cointegration framework

This paper estimates an import demand model for Fiji using the recently developed bounds testing approach to cointegration for the period 1972 to 1999. To estimate the long-run elasticities, we use three approaches: the autoregressive distributed lag (ARDL) model, the dynamic ordinary least squares (DOLS) approach and the fully modified ordinary least squares technique. Our results indicate a long-run cointegration relationship among the variables when import volume is the dependent variable. We find that the coefficient on income is elastic while the coefficient on relative prices (import price relative to domestic price) is unitary elastic in the long run. The error correction mechanism reveals that after any shock(s) to the determinants of import demand equilibrium is attained after 2 1/2 years.

Crime rates, male youth unemployment and real income in Australia: evidence from Granger causality tests

This article applies Granger causality tests to examine the relationship between seven different categories of property crime and violent crime against the person, male youth unemployment and real male average weekly earnings in Australia from 1964 to 2001 within a cointegration and vector error correction framework. It is found that fraud, homicide and motor vehicle theft are cointegrated with male youth unemployment and real male average weekly earnings. However, there is no evidence of a long-run relationship between either break and enter, robbery, serious assault or stealing with male youth unemployment and real male average weekly earnings.

Temporal causality and the dynamics of exports, human capital and real income in China

This article employs cointegration and error-correction modelling to test the causal relationship between real income, exports and human capital stock using data for China over the period 1960 to 1999. We find that real exports, human capital and real income are cointegrated when real exports is the dependent variable, but are not cointegrated when human capital or real income are the dependent variable. In the short-run we find evidence of bi-directional Granger causality between human capital and real exports, unidirectional Granger causality running from real income to human capital and neutrality between real exports and real income.

Temporal causality between human capital and real income in cointegrated VAR processes : empirical evidence from China, 1960-1999

This article examines the causal relationship between human capital and real income using data for China from 1960 to 1999. In the long run there is unidirectional Granger causality running from human capital to real income, while in the short run there is unidirectional Granger causality running from real income to human capital

Temporal causality and the dynamics of democracy, emigration and real income in Fiji

This study is the first to explore temporal causality between democracy, emigration and real income in Fiji within a multivariate cointegration model. We find three long run relationships between democracy, emigration and real income. In the long run there is evidence that migration and democracy Granger cause real GDP in Fiji; real GDP and democracy Granger cause migration from Fiji and that real GDP and migration Granger cause democracy in Fiji. In the short run we find unidirectional Granger causality running from migration to real GDP and from democracy to real GDP, but neutrality between democracy and migration in the short run. We also extend the analysis to examine the degree of exogeneity of the variables beyond the sample period through considering the decomposition of variance and impulse response functions.

Electricity consumption, employment and real income in Australia evidence from multivariate Granger causality tests

This paper examines the relationship between electricity consumption, employment and real income in Australia within a cointegration and causality framework. We find that electricity consumption, employment and real income are cointegrated and that in the long-run employment and real income Granger cause electricity consumption, while in the short run there is weak unidirectional Granger causality running from income to electricity consumption and from income to employment.

Variations in vascular access flows in haemodialysis can depend on needle orientation

Introduction: While using the Transonic Qc[TM] machine to assess access flow in arteriovenous fistulae (AVF), we observed that when compared to antegrade arterial needle insertion, retrograde arterial needle insertion could regularly produce lower access flow measurements. This study sought to explore this phenomenon.

Method: 23 patients entered and 20 finished the study. Patient selection criteria included: functioning AVF and an adequate AVF length for either retrograde or antegrade arterial needle insertion. After ensuring stable and similar blood pressures, 3 flow measurements were taken during the first 2 hours on the same dialysis day of 3 consecutive weeks using antegrade needle insertion then were repeated on 3 further consecutive weeks using retrograde insertion.

Results: Overall, access flows measured with retrograde insertion were significantly lower by a mean difference of 107.15 ml/min (57-484 ml/min) than the flows measured with antegrade needle placement. In 5/20, 3 recorded minimal difference and 2 had a higher access flows during retrograde insertion. No recirculation was observed during either antegrade or retrograde needle insertion. The paired t-test showed that there was significant difference between the antegrade versus retrograde mean measurements (p = 0.005).

Conclusion: Although the sample size is small and the number of measurements limited, we conclude that access flows may be greater with an antegrade arterial orientation compared to flows recorded with a retrograde orientation. The phenomenon behind this conclusion is yet to be investigated. We suggest that when using the Transonic Qc[TM] access measurement device the arterial needle should always be in the same direction for each measurement for each individual patient.

Sustainable living environment for urban low-income households in Malaysia : key factors for maintenance

Urbanisation is predicted to continuously increase every year. Demand for urban shelter will rise and hence this will force governments to act, within their capability, to provide affordable housing in order to maintain social and economic stability. Some industrialized countries have demonstrated full state support from planning and implementation through to continuing maintenance in order to create and sustain a healthy living environment for urban low-in-come households. For developing countries, this might be more difficult. Ensuring adequate maintenance to provide housing quality over the long term is proving even more problematic than simply providing housing. The question is how housing in developing countries can be made sustainable in order to provide a better living environment in the long term. This study focuses on key issues of residential living environments for urban low-cost housing in Malaysia in relation to housing maintenance management. Drawing from extensive primary research and a series of interviews, this exploratory study identifies factors that must be considered by policy makers in order to provide a decent and sustainable living environment for the urban lower-income group. The outcome suggests that current systems of maintenance management - offsetting maintenance to developers or the housing communities themselves, is not working well. The government may need to continue to support low cost housing through maintenance in order to prevent deterioration of accommodation that could become future slums.