Transfer pricing and multinational financial institutions : the case for replacing arm’s length price with a unitary approach

The international tax system, designed a century ago, has not kept pace with the modern multinational entity rendering it ineffective in taxing many modern businesses according to economic activity. One of those modern multinational entities is the multinational financial institution (MNFI). The recent global financial crisis provides a particularly relevant and significant example of the failure of the current system on a global scale. The modern MNFI is increasingly undertaking more globalised and complex trading operations. A primary reason for the globalisation of financial institutions is that they typically ‘follow-the-customer’ into jurisdictions where international capital and international investors are required. The International Monetary Fund (IMF) recently reported that from 1995-2009, foreign bank presence in developing countries grew by 122 per cent. The same study indicates that foreign banks have a 20 per cent market share in OECD countries and 50 per cent in emerging markets and developing countries. Hence, most significant is that fact that MNFIs are increasingly undertaking an intermediary role in developing economies where they are financing core business activities such as mining and tourism. IMF analysis also suggests that in the future, foreign bank expansion will be greatest in emerging economies. The difficulties for developing countries in applying current international tax rules, especially the current traditional transfer pricing regime, are particularly acute in relation to MNFIs, which are the biggest users of tax havens and offshore finance. This paper investigates whether a unitary taxation approach which reflects economic reality would more easily and effectively ensure that the profits of MNFIs are taxed in the jurisdictions which give rise to those profits. It has previously been argued that the uniqueness of MNFIs results in a failure of the current system to accurately allocate profits and that unitary tax as an alternative could provide a sounder allocation model for international tax purposes. This paper goes a step further, and examines the practicalities of the implementation of unitary taxation for MNFIs in terms of the key components of such a regime, along with their their implications. This paper adopts a two-step approach in considering the implications of unitary taxation as a means of improved corporate tax coordination which requires international acceptance and agreement. First, the definitional issues of the unitary MNFI are examined and second, an appropriate allocation formula for this sector is investigated. To achieve this, the paper asks first, how the financial sector should be defined for the purposes of unitary taxation and what should constitute a unitary business for that sector and second, what is the ‘best practice’ model of an allocation formula for the purposes of the apportionment of the profits of the unitary business of a financial institution.

Exploring sustainability themes in engineering accreditation and curricula

Purpose This paper aims to present key findings from an inquiry into engineering accreditation and curricula renewal. The research attempted to ascertain conceptions of requisite sustainability themes among engineering academics and professionals. The paper also reflects on the potential role of professional engineering institutions (PEIs) in embedding sustainability through their programme accreditation guidelines and wider implications in terms of rapid curricula renewal. Design/methodology/approach This research comprised an International Engineering Academic Workshop held during the 2010 International Symposium on Engineering Education in Ireland, on “accreditation and sustainable engineering”. This built on the findings of a literature review that was distributed prior to the workshop. Data collection included individual questionnaires administered during the workshop, and notes scribed by workshop participants. Findings The literature review highlighted a wide range of perspectives across and within engineering disciplines, regarding what sustainability/sustainable development (SD) themes should be incorporated into engineering curricula, and regarding language and terminology. This was also reflected in the workshop discussions. Notwithstanding this diversity, clusters of sustainability themes and priority considerations were distilled from the literature review and workshop. These related to resources, technology, values, ethics, inter- and intra-generational equity, transdisciplinarity, and systems and complex thinking. Themes related to environmental and economic knowledge and skills received less attention by workshop participants than represented in the literature. Originality/value This paper provides an appreciation of the diversity of opinion regarding priority sustainability themes for engineering curricula, among a group of self-selected engineering academics who have a common interest in education for SD. It also provides some insights and caveats on how these themes might be rapidly integrated into engineering curricula.

Sex, love and abuse : discourses on domestic violence and sexual assault

Sex, Love and Abuse intervenes in a timely way on some important issues that have become 'elephants in the room' for academic and policy considerations around sexual violence and abuse. In so doing, this book draws upon a range of literatures and novel empirical sources to encourage critical thinking about the relationship between sex, love and abuse, examining crimes including sexual assault, pornography, child sexual abuse and domestic violence. This provocative book seeks to destabilize essentialist understandings of these phenomena with a view to identifying the subtle and complex nature of relationships, which often defy easy explanation and categorisation. Focusing on theories, public discourses and moral ideals, Hayes connects romantic love, intimacy and harm in a unique philosophical analysis, exploring abuse in relationships and how such abuse is fostered.

Mining and (sustainable) local communities : transforming Ravensthorpe, Western Australia

This chapter examines local community experiences, understandings and changes attending the presence of mining activity, in particular as occurred in the Shire of Ravensthorpe in the South West of Western Australia (WA). It does so by drawing on an extensive ethnographic study spanning the development, opening, and closure of BHP Billiton’s Ravensthorpe Nickel Operation (RNO). Given that the negative consequences of mining activity are most evident and complex at the local level, it is crucial that we understand and address how communities (and the individuals and families who are both part of and are shaped by communities) experience the impacts of mining. Though difficult to measure, social and cultural dimensions of mining at the local scale, as this chapter demonstrates, are central to our understanding of mining as a curse or cure.

Nanoscale surface and interface engineering : why plasma-aided?

This contribution provides arguments why and in which cases low-temperature plasmas should be used for nanoscale surface and interface engineering and discusses several advantages offered by plasma-based processes and tools compared to neutral gas fabrication routes. Relevant processes involve nanotexturing (etching, sputtering, nanostructuring, pre-patterning, etc.) and composition/structure control at nanoscales (phases, layering, elemental presence, doping, functionalization, etc.) and complex combinations thereof. A case study in p-Si/n-Si solar cell junction exemplifies a successful use of inductively coupled plasma-assisted RF magnetron sputtering for nanoscale fabrication of a bi-layered stack of unconventionally doped highly-crystalline silicon nanofilms with engineered high-quality interfaces.

Sense of home, sense of place : a morpho-typological comparative study of Florida and Queensland

Cities in the 21st century have become layered and complex systems not only in terms of physical form, but also social and cultural structure. Consolidated tools to analyze the urban environment have today to be improved including a strong interdisciplinary perspective in order to understand and manage the unprecedented complexity our cities are facing. Redevelopments, new estates, internal and external migrations are all dynamics which are deeply modifying the built environment directly or indirectly also affecting local identity, culture and social structure. This paper investigates the relationship between urban form and social behaviors, with particular attention to the perception of the built environment and its use by long term residents, recent migrants as well as tourists. A comparative study is suggested between South East Queensland and Florida; this two regions share common features such as subtropical climate, similar lifestyle, leisure cities and canal estates. Neighborhoods on the Gold and Sunshine Coasts have been designed using the communities of Florida, such as Celebration or Seaside, as models. These regions share also significant migration processes, similar social problems and high crime rates, which directly affect the local economies. Comparing Florida and SEQ could provide an understanding of different strategies adopted and how urban development and lifestyle can be managed maintaining social equity and security. This study, investigates people’s perception of built form and how this affects the use of public space. The relationship between built environment and social behaviour has been previously investigated, for example by environmental psychology; the innovation proposed by this research is to study the perception of place in leisure cities at multiple levels. Locals, migrants and tourists have different understanding of the built form in the same location; this understanding affects the use of space and the attitude to visit or avoid some precincts. The research methodology integrates traditional morpho-typological investigations with qualitative methods; data are collected in the first phase through online surveys about perception of urban forms. Findings guide then the selection of neighbourhoods to be investigated in detail through questionnaires and Nolli maps, specifying morphological regions as well as recurrent building typologies. A final phase includes interviews with selected stakeholders. Major urban projects are discussed addressing how they are used and perceived by locals, migrants or tourists; the comparison between SEQ and Florida allows the identification of strategies to address migration issues in both regions with particular attention to urban form and placemaking dynamics.

Enhancing the capacity of kin caregivers and their families to meet the needs of children left behind

Based on qualitative research of the experiences of 23 kin caregivers and five school personnel, this article explores the role of informal kinship care in addressing the needs of school-age children left behind in rural China. The findings of this study suggest that kin caregivers' child-rearing capacity is limited in the rural context, and they are often overwhelmed by children's diverse and complex needs, particularly their emotional ones. In view of the huge population and their vulnerability, it is imperative for the state to take up its responsibilities and develop specific social work services and other support for children left behind and their families. 根据对23位亲属照顾者和5位学校人员的质性研究，文章探讨在处理中国留守学龄儿童的需要时，非正式亲属照料所担当的角色。研究发现，在农村的亲属照料者的抚养儿童能力有限，而且他们时常在面对儿童众多复杂的需求时应接不暇，问题又以情绪需要尤甚。有见于留守儿童的数目众多和易受伤害，政府急切需要承担相关的责任，为留守儿童及其家庭发展专门的社会工作服务和其他支援。

Connecting theory, practice and place in today’s landscape : an education initiative

Since the establishment of Australia’s earliest formal studies in landscape architecture, landscape planning has been a traditional focus within post-graduate studies at QUT. Study in this area has evolved from an earlier emphasis on applied physical geography through to traditional techniques and processes in visual assessment and management. The emphasis on these techniques has shifted again to a more complex exploration of natural, economic, social and cultural landscapes. Recently, the School has explored more innovative and complex dimensions of human and natural landscapes. This has involved a focus on particular regions under pressure from local social and economic change. These have included the under-threat ‘picturesque’ landscapes of the Blackall Range and the Tweed Valley. Attempts to bridge the institution and the landscape have unearthed, through a studio focus, strong connections with notions of sustainable villages, roadside interpretation, way finding, local economic initiatives, special area creation, cultural heritage brokering and ecological enhancements. These initiatives have spanned both local practice interests and academic pursuits. Central to this exploration is the concept of problem solving through the investigation of the concept of ‘multiple scales’. An open, yet intensive program is being developed with a team of ‘futurist’ practitioners offering a range of experiences and perspectives to students. The program is being increasingly linked to design studios so that landscape planning and landscape design form a fabric of inquiry that works towards reclaiming complex landscapes.

Efficiently capturing large, complex cultural heritage sites with a handheld mobile 3D laser mapping system

Accurate three-dimensional representations of cultural heritage sites are highly valuable for scientific study, conservation, and educational purposes. In addition to their use for archival purposes, 3D models enable efficient and precise measurement of relevant natural and architectural features. Many cultural heritage sites are large and complex, consisting of multiple structures spatially distributed over tens of thousands of square metres. The process of effectively digitising such geometrically complex locations requires measurements to be acquired from a variety of viewpoints. While several technologies exist for capturing the 3D structure of objects and environments, none are ideally suited to complex, large-scale sites, mainly due to their limited coverage or acquisition efficiency. We explore the use of a recently developed handheld mobile mapping system called Zebedee in cultural heritage applications. The Zebedee system is capable of efficiently mapping an environment in three dimensions by continually acquiring data as an operator holding the device traverses through the site. The system was deployed at the former Peel Island Lazaret, a culturally significant site in Queensland, Australia, consisting of dozens of buildings of various sizes spread across an area of approximately 400 × 250 m. With the Zebedee system, the site was scanned in half a day, and a detailed 3D point cloud model (with over 520 million points) was generated from the 3.6 hours of acquired data in 2.6 hours. We present results demonstrating that Zebedee was able to accurately capture both site context and building detail comparable in accuracy to manual measurement techniques, and at a greatly increased level of efficiency and scope. The scan allowed us to record derelict buildings that previously could not be measured because of the scale and complexity of the site. The resulting 3D model captures both interior and exterior features of buildings, including structure, materials, and the contents of rooms.

Facial emotion and identity processing development in 5- to 15-year-old children

Most developmental studies of emotional face processing to date have focused on infants and very young children. Additionally, studies that examine emotional face processing in older children do not distinguish development in emotion and identity face processing from more generic age-related cognitive improvement. In this study, we developed a paradigm that measures processing of facial expression in comparison to facial identity and complex visual stimuli. The three matching tasks were developed (i.e., facial emotion matching, facial identity matching, and butterfly wing matching) to include stimuli of similar level of discriminability and to be equated for task difficulty in earlier samples of young adults. Ninety-two children aged 5–15 years and a new group of 24 young adults completed these three matching tasks. Young children were highly adept at the butterfly wing task relative to their performance on both face-related tasks. More importantly, in older children, development of facial emotion discrimination ability lagged behind that of facial identity discrimination.

Business transformation management : composition and orchestration of management services

This research develops a better understanding on how large-scale and complex IT-enabled business transformations are managed. Evidence from three global case studies suggest that business transformations can be composed and orchestrated like a jazz band, where improvisation plays a fundamental role to maintain the melody, harmony and rhythm of such initiatives. The thesis details how the jazz metaphor can assist senior management on how to reuse and reconfigure capabilities as services for transforming organizations. To the academic body of knowledge, the thesis provides a study on the use of management services as a theoretical lens to examine Business Transformation Management.

Book review - Richard Goldberg, Medicinal Product Liability and Regulation (Hart Publishing, Oxford, 2013) 214pp

In December 2013, settlement was reached between approximately 100 Australian and New Zealand Thalidomide victims and the company which had acted as the Australian distributor of the infamous drug, thus putting to rest the possibility of litigation. Around the same time, Thalidomide victims in the United Kingdom (UK) launched a similar bid for compensation against the manufacturer and distributor. It is clear that despite a lengthy amount of time having passed ever since the thalidomide disaster commenced in 1962, the controversy over compensation continues. Indeed, the author of Medicinal Product Liability and Regulation (published before the announcement of the British legal claim), Professor Goldberg, notes that claims for resulting birth defects continue to emerge right into the present day. His prescient insight into the contemporary relevance of compensation for pharmaceutical injuries thus makes Medicinal Product Liability and Regulation a very relevant addition to the small body of scholarship that is available on this rather specific and complex issue.

‘It’s about finding a way’ : children, sites of opportunity, and building everyday peace in Colombia

The multiple forms of violence associated with protracted conflict disproportionately affect young people. Literature on conflict-affected children often focuses on the need to provide stability and security through institutions such as schools but rarely considers how young people themselves see these sites as part of their everyday lives. The enduring, pervasive, and complex nature of Colombia’s conflict means many young Colombians face the challenges of poverty, persistent social exclusion, and violence. Such conditions are exacerbated in ‘informal’ barrio communities such as los Altos de Cazucá, just south of the capital Bogotá. Drawing on field research in this community, particularly through interviews conducted with young people aged 10 to 17 this article explores how young people themselves understand the roles of the local school and ngo in their personal conceptualisations of the violence in their everyday lives. The evidence indicates that children use spaces available to them opportunistically and that these actions can and should be read as contributing to local, everyday forms of peacebuilding. The ways in which institutional spaces are understood and used by young people as ‘sites of opportunity’ challenges the assumed illegitimacy of young people’s voices and experiences in these environments.

Creative graduate pathways within and beyond the creative industries

This special issue explores the nuances of graduate creative work, the kinds of value that creative graduates add through work of various types, graduate employability issues for creative graduates, emerging and developing creative career identities and the implications for educators who are tasked with developing a capable creative workforce. Extent literature tends to characterise creative careers as either ‘precarious’ and insecure, or as the engine room of the creative economy. However, in actuality, the creative workforce is far more heterogeneous than either of these positions suggest, and creative careers are far more complex and diverse than previously thought. The task of creative educators is also much more challenging than previously supposed. In this introductory article, we commence by providing a brief overview of the creative labour debates, and the evidence for each position. We present the latest literature in this area that starts to speak to how diverse and complex the landscape of creative work actually is. We then introduce each of the articles in this special issue and indicate how they contribute to a more multi-faceted picture of creative activity, and the lives and career trajectories of graduates from creative degrees.

Incorporating complex train paths to an analysis of absolute capacity

Railways are an important mode of transportation. They are however large and complex and their construction, management and operation is time consuming and costly. Evidently planning the current and future activities is vital. Part of that planning process is an analysis of capacity. To determine what volume of traffic can be achieved over time, a variety of railway capacity analysis techniques have been created. A generic analytical approach that incorporates more complex train paths however has yet to be provided. This article provides such an approach. This article extends a mathematical model for determining the theoretical capacity of a railway network. The main contribution of this paper is the modelling of more complex train paths whereby each section can be visited many times in the course of a train’s journey. Three variant models are formulated and then demonstrated in a case study. This article’s numerical investigations have successively shown the applicability of the proposed models and how they may be used to gain insights into system performance.