Thin capitalisation – the multinational tax avoidance strategy the budget forgot

We have already seen major amendments to Australia’s tax regime to tackle base erosion and profit shifting (BEPS). Several more significant measures were announced in the federal budget, most notably the diverted profits tax, aimed at multinationals which shift tax to a lower taxing jurisdiction. Yet to date, a very simple tax minimisation strategy has been largely ignored in the ongoing reforms and was ignored in the federal budget. Excessive debt loading is a problem that not been afforded the same attention as other aggressive tax planning strategies adopted by multinationals.

What if tax reform was a fundamental human right?

As an election looms in Australia, the tax debate continues unabated. Self-interest abounds. When we remove self-interest, we are often reduced to standard design principles for a taxation system. Lost in this discussion is the fundamental purpose of tax, which is to finance government expenditure. Most would argue that tax revenue should be sufficient to meet basic economic and social needs of the community. But how does a community determine what these basic economic and social needs should be? One way is by using a human rights framework. This can provide guidance for both developing and developed countries considering tax reform.

Fundamental Tax Legislation [24th Edition]

Fundamental Tax Legislation 2016 contains the essential provisions from the primary legislation that affects Australia's taxation system. Updated and expanded for changes which occurred in 2015, this volume is an indispensable reference for undergraduate and postgraduate students of taxation. The Year in Review section has been updated to summarise the main legislative developments in taxation over the previous 12 months, a listing of the passage of tax related legislation during the last year and the inclusion of reference statistics (such as CPI quarterly figures and individual tax rates for residents and foreign residents). Also fully updated and revised to reflect the changes in 2015 is the Tax Rates and Tables section, which contains an accessible summary of the main tax rates and tables that students will need to refer to for their tax studies.

Ferrolysis induced soil transformation by natural drainage in Vertisols of sub-humid South India

In sub-humid South India, recent studies have shown that black soil areas (Vertisols and vertic Intergrades), located on flat valley bottoms, have been rejuvenated through the incision of streambeds, inducing changes in the pedoclimate and soil transformation. Joint pedological, geochemical and geophysical investigations were performed in order to better understand the ongoing processes and their contribution to the chemistry of local rivers. The seasonal rainfall causes cycles of oxidation and reduction in a perched watertable at the base of the black soil, while the reduced solutions are exported through a loamy sand network. This framework favours a ferrolysis process, which causes low base saturation and protonation of clay, leading to the weathering of 2:1 then 1:1 clay minerals. Maximum weathering conditions occur at the very end of the wet season, just before disappearance of the perched watertable. Therefore, the by-products of soil transformation are partially drained off and calcareous nodules, then further downslope, amorphous silica precipitate upon soil dehydration. The ferrolysed area is fringing the drainage system indicating that its development has been induced by the streambed incision. The distribution of C-14 ages of CaCO3 nodules suggests that the ferrolysis process started during the late Holocene, only about 2 kyr B.P. at the studied site and about 5 kyr B.P. at the watershed outlet. The results of this study are applied to an assessment of the physical erosion rate (4.8x10(-3) m/kyr) since the recent reactivation of the erosion process. (C) 2010 Elsevier B.V. All rights reserved.

Tax Reform and Payout Policy:Do Shareholder Clienteles or Payout Policy Adjust?

Changes in taxation of corporate dividends offer excellent opportunities to study dividend clientele effects. We explore payout policies and ownership structures around a major tax reform that took place in Finland in 2004. Consistent with dividend clienteles affecting firms’ dividend policy decisions, we find that Finnish firms altered their dividend policies based on the changed tax incentives of their largest shareholders. While firms adjust their payout policies, our results also indicate that ownership structures of Finnish firms also changed around the 2004 reform, consistent with shareholder clienteles adjusting to the new tax system.

Studies on removal of metal ions and sulphate reduction using rice husk and Desulfotomaculum nigrificans with reference to remediation of acid mine drainage

The utility of rice husk as an adsorbent for metal ions such as iron, zinc and copper from acid mine water was assessed. The adsorption isotherms exhibited Langmuirian behavior and were endothermic in nature. The free energy values for adsorption of the chosen metal ions onto rice husk were found to be highly negative attesting to favorable interaction. Over 99% Fe3+, 98% of Fe2+ and Zn2+ and 95% Cu2+ uptake was achieved from acid mine water, with a concomitant increase in the pH value by two units using rice husk. The remediation studies carried out on acid mine water and simulated acid mine water pretreated with rice husk indicated successful growth of Desulfotomaculum nigrificans (D. nigrificans). The amount of sulphate bioreduction in acid mine water at an initial pH of 5.3 was enhanced by D. nigrificans from 21% to 40% in the presence of rice husk filtrate supplemented with carbon and nitrogen. In simulated acid mine water with fortified husk filtrate, the sulphate reduction was even more extensive, with an enhancement to 73%. Concurrently, almost 90% Fe2+, 89% Zn2+ and 75% Cu2+ bioremoval was attained from simulated acid mine water. Metal adsorption by rice husk was confirmed in desorption experiments in which almost complete removal of metal ions from the rice husk was achieved after two elutions using 1 M HCl. The possible mechanisms of metal ion adsorption onto rice husk and sulphate reduction using D. nigrificans are discussed.

Tax havens and their impacts on the non-haven countries

Tax havens have attracted increasing attention from the authorities of non-haven countries. The financial crisis exacerbates the negative attitude to tax havens. Offshore zones are now under strong pressure from the international, both financial and political institutions. Thus, the thesis will focus on the current problem of the modern economy, namely tax havens and their impact on the non-haven countries. This thesis will be based on the several articles, in particular “Tax Competition With Parasitic Tax Havens” by Joel Slemrod and John D. Wilson (University of Michigan, 2009) and “Do Havens Divert Economic Activity” by James R. Hines Jr., C. Fritz Foley and Mihir A. Desai (Ross School of Business, 2005). This paper provides two completely different and contradictory viewpoints on the problem of coexisting tax havens and non-haven countries. There are two models, examined in this work, present two important researches. The first one will be concentrated on the positive effect from tax havens whereas the last model will be focused on the completely negative effect from offshore jurisdictions. The first model gives us a good explanation and proof of its statement why tax havens can positively influence on nearby high-tax countries. It describes that the existence of offshore jurisdictions can stimulate the growth of operations and facilitates economic activity in non-haven countries. In contrast to above mentioned, the model with quite opposite view was presented. This economic model and its analysis confirms the undesirability of the existence of offshore areas. Taking into consideration, that the jurisdictions choose their optimal policy, the elimination of offshores will have positive impact on the rest of countries. The model proofs the statement that full or partial elimination of tax havens raises the equilibrium level of the public good and increases country welfare. According to the following study, it can be concluded that both of the models provide telling arguments to prove their assertions. Thereby both of these points of view have their right to exist. Nevertheless, the ongoing debate concerning this issue still will raise a lot of questions.

A model for static foam drainage

A model for static foam drainage, based on the pentagonal dodecahedral shape of bubbles, that takes into account the surface mobility of both films and Plateau border walls has been developed. The model divides the Plateau borders into nearly horizontal and nearly vertical categories and assigns different roles to them. The films are assumed to drain into all the adjacent Plateau borders equally. The horizontal Plateau borders are assumed to receive liquid from films and drain into vertical Plateau borders, which in turn form the main component for gravity drainage. The model yields the liquid holdup values for films, horizontal Plateau borders and vertical Plateau borders as functions of height and time. The model has been tested on static foams whose cumulative drainage was measured as a function of time. The experimental data on the effect of foam height, initial holdup, surface viscosity, etc. can be explained by the model quantitatively.

Drainage and separation factors for static foams containing agglomerates of microbial cells

The presence of cell agglomerates has been found to influence significantly the rates of liquid drainage from static foams. The process of drainage has been modelled by considering the foam to be made of pentagonal dodecahedral bubbles yielding films, nearly horizontal and nearly vertical Plateau borders. The films are assumed to drain into both kinds of Plateau borders equally. The horizontal Plateau borders are assumed to receive liquid from the films and drain into the vertical Plateau borders, which, in turn, form the main flow paths for gravity drainage. The drainage process is assumed to be similar to that for pure liquid until a stage is reached where the size of the cell agglomerates become equivalent to those of films and Plateau borders. Thereafter, a squeezing flow mechanism has been formulated where the aggromerates deform and flow. The model based on the above assumptions has been verified against experimental results and has been found to predict not only drainage data but also the separation of cell agglomerates from broths.

Effect of drainage basin characteristics on the diffuse load of phosphorus and nitrogen.

Tiivistelmä: Valuma-alueen vaikutus fosforin ja typen hajakuormitukseen.

A new model for drainage of static foams

Existing theories of foam drainage assume bubbles as pentagonal dodecahedrons, though a close-packed structure built with cells of this shape is not space-filling. The present work develops a theory for calculating drainage rates based on the more realistic beta-tetrakaidecahedral shape for the bubbles. In contrast with the earlier works, three types of films, and Plateau borders had to be considered in view of the more complex shape used in the present work. The exchange of liquid between Plateau borders was treated in a way different From earlier theories, using the idea that the volume of junctions of Plateau borders is negligible. For foams made of large bubble sizes, the present model performs as well as the previous models, but when bubble size is small, its predictions of drainage rates from static foams are in better agreement with the experimental observations.

Consolidation behavior of clayey soils under radial drainage

For Barren's degree of consolidation, U-r, versus the time factor, T-r, relationship for soils undergoing consolidation with radial drainage for the equal vertical strain condition, a simple method has been developed to determine the value of the coefficient of consolidation with radial drainage c(r). Theoretical log(10)(d(e)(2)/t) versus U-r curves where d(e) is the diameter of influence and r is the real time for the different known value of c(r) have been generated. A method has been developed wherein both the theoretical and experimental behaviors of soils undergoing consolidation with radial drainage can be simultaneously compared and studied on the same plot. The experimental log(10)(d(e)(2)/t) versus U-r curves have been compared with the theoretical curves. Effects of initial compression, secondary compression, and duration of load increment are studied. Simple procedures are presented for calculating the values of c(r) using the experimental log(10)(d(e)(2)/t) versus U-r curves. A comparative study of the coefficient of consolidation and the coefficient of permeability between the cases of vertical and radial drainage has been done.

Water and salt movements in simultaneous flood-irrigation and well-drainage operations

This paper describes a new technology for solonchak soil reclamation in which surface flood irrigation of fresh water and pumped wells drainage of salty groundwater are combined. The comprehensive investigation of water and salt movement has been conducted through field test, laboratory simulation and numerical calculation. The dependence of desalination on irrigation water quantity, drainage quantity, leaching time and other parameters is obtained based on the field tests. The entire desalination process under the flood-irrigation and well-drainage operations was experimentally simulated in a vertical soil column. The water and salt movement has been numerically analysed for both the field and laboratory conditions. The present work indicates that this new technology can greatly improve the effects of desalination.

Second-best tax policy in a growing economy with externalities

This paper investigates the exploitation of environmental resources in a growing economy within a second-best scal policy framework. Agents derive utility from two types of consumption goods one which relies on an environmental input and one which does not as well as from leisure and from environmental amenity values. Property rights for the environmental resource are potentially incomplete. We connect second best policy to essential components of utility by considering the elasticity of substitution among each of the four utility arguments. The results illustrate potentially important relationships between environmental amentity values and leisure. When amenity values are complementary with leisure, for instance when environmental amenities are used for recreation, taxes on extractive goods generally increase over time. On the other hand, optimal taxes on extractive goods generally decrease over time when leisure and environmental amenity values are substitutes. Unders some parameterizations, complex dynamics leading to nonmonotonic time paths for the state variables can emerge.