Double tax agreements and the international allocation of business income in Australia

Increasingly, the effectiveness of the present system of taxation of international businesses is being questioned. The problem associated with the taxation of such businesses is twofold. A system of international taxation must be a fair and equitable system, distributing profits between the relevant jurisdictions and, in doing so, avoiding double taxation. At the same time, the prevention of fiscal evasion must be secured. In an attempt to achieve a fair and equitable system Australia adopts unilateral, bilateral and multilateral measures to avoid double taxation and restrict the avoidance of tax. The first step in ascertaining the international allocation of business income is to consider the taxation of business income according to domestic law, that is, the unilateral measures. The treatment of international business income under the Australian domestic law, that is, the Income Tax Assessment Act 1936 (Cth) and Income Tax Assessment Act 1997 (Cth), will depend on two concepts, first, whether the taxpayer is a resident of Australia and secondly, whether the income is sourced in Australia. After the taxation of business profits has been determined according to domestic law it is necessary to consider the applicability of the bilateral measures, that is, the Double Tax Agreements (DTAs) to which Australia is a party, as the DTAs will override the domestic law where there is any conflict. Australia is a party to 40 DTAs with another seven presently being negotiated. The preamble to Australia's DTAs provides that the purpose of such agreements is 'to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income'. Both purposes, for different reasons, are equally important. It has been said that: The taxpayer hopes the treaty will prevent the double taxation of his income; the tax gatherer hopes the treaty will prevent fiscal evasion; and the politician just hopes. The first purpose, the avoidance of double taxation, is achieved through the provision of rules whereby the Contracting States agree to the classification of income and the allocation of that income to a particular State. In this sense DTAs do not allocate jurisdiction to tax but rather provide an arrangement whereby the States agree to restrict their substantive law. The restriction is either through the non-taxing of the income or via the provision of a tax credit.

Bridging the gap: Wellness differences between high and low SES Australian adolescents

Aims Wellness assessments can determine adolescent lifestyle behaviors. A better understanding of wellness differences between high and low SES adolescents could assist policy makers to develop improved strategies to bridge the gap between these two groups. The aim of this investigation was to explore wellness differences between high and low SES adolescents. Methods In total, 241 (125 high and 116 low SES) adolescents completed the 5-Factor Wellness Inventory (5F-Wel). The 5F-Wel comprises 97 items contributing to 17 subscales, 5 dimensions, 4 contexts, total wellness, and a life satisfaction index, with scores ranging from 0-100. Independent sample t-tests were performed with Levene’s test of equality for variances, which checked the assumption of homogeneity of variances. Results Overall, 117 (94%) and 112 (97 %) high and low SES participants had complete data and were included in the analysis. The high SES group scored higher for total wellness (M = 81.09, SE = .61) than the low SES group (M = 75.73, SE = .99). This difference was significant t (186) = 4.635, p < .05, with a medium effect size r = .32. The high SES group scored higher on 23 of 27 scales (21 scales, p < .05), while the low SES group scored higher on the remaining 3 scales (all non-significant). Conclusion These results contribute empirical data to the body of literature, indicating a large wellness discrepancy between high and low SES youth. Deficient areas can be targeted by policymakers to assist in bridging the gap between these groups.

Effect of Reynolds numbers on flow past four square cylinders in an in-line square configuration for different gap spacings

In this paper two-dimensional (2-D) numerical investigation of flow past four square cylinders in an in-line square configuration are performed using the lattice Boltzmann method. The gap spacing g=s/d is set at 1, 3 and 6 and Reynolds number ranging from Re=60 to 175. We observed four distinct wake patterns: (i) a steady wake pattern (Re=60 and g=1) (ii) a stable shielding wake pattern (80≤Re≤175 and g=1) (iii) a wiggling shielding wake pattern (60≤Re≤175 and g=3) (iv) a vortex shedding wake pattern (60≤Re≤175 and g=6) At g=1, the Reynolds number is observed to have a strong effect on the wake patterns. It is also found that at g=1, the secondary cylinder interaction frequency significantly contributes for drag and lift coefficients signal. It is found that the primary vortex shedding frequency dominates the flow and the role of secondary cylinder interaction frequency almost vanish at g=6. It is observed that the jet between the gaps strongly influenced the wake interaction for different gap spacing and Reynolds number combination. To fully understand the wake transformations the details vorticity contour visualization, power spectra of lift coefficient signal and time signal analysis of drag and lift coefficients also presented in this paper.

Convergence in the gender wage gap in Australia over the 1980s : identifying the role of counteracting forces via the Juhn, Murphy and Pierce decomposition

The paper utilises the Juhn Murphy and Pierce (1991) decomposition to shed light on the pattern of slow male-female wage convergance in Australia over the 1980s. The analysis allows one to distinguish between the role of wage structure and genderspecific effects. The central question addressed is whether rising wage inequality counteracted the forces of increased female investment in labour market skills, i.e. education and experience. The conclusion is that in contrast to the US and the UK, Australian women do not appear to have been swimming against a tide of adverse wage structure changes.

Projecting the trend in the Canadian gender wage gap 2001-2031: Will an increase in female education acquisition and commitment be enough?

The paper projects the gender wage gap for 25-64 year-olds in Canada over the period 2001-2031. The empirical analysis uses the Survey of Labour and Income Dynamics together with Statistics Canada demographic projections. The methodology combines the population projections with assumptions relating to the evolution of educational attainment in order to first project the future distribution of human capital skills and, based on these projections, the future size of the gender wage gap. The projections suggest continued gender wage convergence produced by changing skills characteristics. However, a substantial pay gap will remain in 2031.

Labour market institutions and the gender wage gap in Britain and Australia, 1973–90

The importance of wage structure is frequently interpreted as indirect evidence of the role played by labour market institutions. The current paper follows in this tradition, examining the role of wage structure in explaining the trend in the gender wage gap over the period 1973–91 for both Australia and the UK. The focus is upon whether changes in wage structure (and associated gender wage gap) both across country and over time are compatible with institutional explanations. Combining comparisons both cross-country and over time yields a more stringent, albeit indirect, test of the role of institutions.

The gender wage gap in Australia - The path of future convergence

The paper attempts to project the future trend of the gender wage gap in Australia up to 2031. The empirical analysis utilises the Income Distribution Survey (1996) together with Australian Bureau of Statistics (ABS) demographic projections. The methodology combines the ABS projections with assumptions relating to the evolution of educational attainment in order to project the future distribution of human capital skills and consequently the future size of the gender wage gap. The analysis suggests that female relative pay will continue to rise up to 2031. However, gender wage convergence will be relatively slow, with a substantial gap remaining in 2031.

Projecting the U.S. gender wage gap 2000–40

This paper projects the gender wage gap for 25–64 year old Americans for the period 2000–40. The analysis uses data from the Panel Survey of Income Dynamics (PSID) for 1995 and 1996 together with the U.S. Census Bureau demographic projections. The method combines the population projections with assumptions regarding the evolution of educational attainment in order to first project the future distribution of skills and, based on these projections, the future size of the gender wage gap. The main set of projections suggests that changing skill characteristics—specifically educational attainment—will continue to close the gender wage gap. However, even in 2040, a substantial pay gap of at least 75 percent of the size of that in 1995 will remain.

Projections of the future path of the gender wage gap in Great Britain

Purpose – The paper attempts to project the future trend of the gender wage gap in Great Britain up to 2031. Design/methodology/approach – The empirical analysis utilises the British Household Panel Study Wave F together with Office for National Statistics (ONS) demographic projections. The methodology combines the ONS projections with assumptions relating to the evolution of educational attainment in order to project the future distribution of human capital skills and consequently the future size of the gender wage gap. Findings – The analysis suggests that gender wage convergence will be slow, with little female progress by 2031 unless there is a large rise in returns to female experience. Originality/value – The paper has projected the pattern of male and female skill acquisition together with the associated trend in wages up to 2031.

Closing the gap between copyright and designs : an age of enlightnement or state of confusion?

The arena of intellectual property encompasses streams that often interrelate and overlap in protecting different aspects of intellectual property. Australian commentators suggest that ‘one of the most troublesome areas in the entire field of intellectual property has been the relationship between copyright protection for artistic works under the Copyright Act 1968 (Cth) and protection for registered designs under the Designs Act 1906 (Cth).’ [McKeough, J., Stewart, A., & Griffith, P. (2004). Intellectual property in Australia (3rd ed.). Chatswood, NSW: Butterworths.] [Ricketson, S., Richardson, M., & Davison, M. (2009). Intellectual property: Cases, materials and commentary (4th ed.). Chatswood, NSW: LexisNexis Butterworths.] This overlap has caused much confusion for both creators of artistic works and industrial designs, as there is an uncertainty of whether protection against infringement is afforded under the Copyright Act 1988 (Cth) or whether the Designs Act 2003 (Cth) will apply. In Australia, there is limited precedent that examines the crossover between copyright and designs. Essentially, the cases that have tested this issue remain unclear as to whether a design applied industrially will invoke copyright protection. The cases demonstrate that there is an inconsistency in this area despite the aims of the new provisions of the Designs Act 2003 (Cth) to close the loopholes between copyright and designs. This paper will discuss and evaluate the relationship between copyright protection for artistic works and protection for registered designs with respect to the Designs Act 2003 (Cth).

Bridging the gap between tertiary education and work : situated learning in accountancy

In professions such as teaching, health sciences (medicine, nursing), and built environment, significant work-based learning through practica is an essential element before graduation. However, there is no such requirement in professional accounting education. This paper reports the findings of an exploratory qualitative case study of the implementation of a Workplace Learning Experience Program in Accountancy at the Queensland University of Technology (QUT) in Australia. The interview-based study documents the responses of university students and graduates to this program. The study demonstrates that a 100 hour work placement in Accountancy can enhance student learning. It highlights the potential value of the application of sociocultural theories of learning, especially the concept of situated learning involving legitimate peripheral participation (Lave and Wenger 1991). This research adds to a small body of empirical accounting education literature relating to the benefits of work placements prior to graduation. The effectiveness of this short, for credit, unpaid program should encourage other universities to implement a similar work placement program as a form of pre-graduation learning in professional accounting education.

Ratchetting of railhead in the vicinity of the gap of the insulated rail joints

Insulated Rail Joints (IRJs) are designed to electrically isolate two rails in rail tracks to control the signalling system for safer train operations. Unfortunately the gapped section of the IRJs is structurally weak and often fails prematurely especially in heavy haul tracks, which adversely affects service reliability and efficiency. The IRJs suffer from a number of failure modes; the railhead ratchetting at the gap is, however, regarded as the root cause and attended to in this thesis. Ratchetting increases with the increase in wheel loads; in the absence of a life prediction model, effective management of the IRJs for increased wagon wheel loads has become very challenging. Therefore, the main aim of this thesis is to determine method to predict IRJs' service life. The distinct discontinuity of the railhead at the gap makes the Hertzian theory and the rolling contact shakedown map, commonly used in the continuously welded rails, not applicable to examine the metal ratchetting of the IRJs. Finite Element (FE) technique is, therefore, used to explore the railhead metal ratchetting characteristics in this thesis, the boundary conditions of which has been determined from a full scale study of the IRJ specimens under rolling contact of the loaded wheels. A special purpose test set up containing full-scale wagon wheel was used to apply rolling wheel loads on the railhead edges of the test specimens. The state of the rail end face strains was determined using a non-contact digital imaging technique and used for calibrating the FE model. The basic material parameters for this FE model were obtained through independent uniaxial, monotonic tensile tests on specimens cut from the head hardened virgin rails. The monotonic tensile test data have been used to establish a cyclic load simulation model of the railhead steel specimen; the simulated cyclic load test has provided the necessary data for the three decomposed kinematic hardening plastic strain accumulation model of Chaboche. A performance based service life prediction algorithm for the IRJs was established using the plastic strain accumulation obtained from the Chaboche model. The predicted service lives of IRJs using this algorithm have agreed well with the published data. The finite element model has been used to carry out a sensitivity study on the effects of wheel diameter to the railhead metal plasticity. This study revealed that the depth of the plastic zone at the railhead edges is independent of the wheel diameter; however, large wheel diameter is shown to increase the IRJs' service life.

A field experiment in moral suasion and tax compliance focusing on underdeclaration and overdeduction

One of very few field experiments in tax compliance, this study generates a unique data set on Swiss taxpayers’ underdeclaration of income and wealth and overdeduction of tax credits by obtaining exclusive access to tax-return corrections made by the tax administration. Using this commune-level data from Switzerland, it explores the influence on tax compliance of moral suasion, introduced through a treatment in which taxpayers receive a letter containing normative appeals signed by the commune’s fiscal commissioner. This letter also serves to operationalize elements of social identity and (mutual) trust. Interestingly, the results not only echo the earlier finding that moral suasion has barely any effect on taxpayer compliance, but show clear differences between underdeclaration and overdeduction.

Fundamental Tax Legislation [22nd Edition]

This edition includes a revised Year in Review section, which summarises the 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 non-residents). A 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

Simulations of the spontaneous emission of a quantum dot near a gap plasmon waveguide

In this paper we modeled a quantum dot at near proximity to a gap plasmon waveguide to study the quantum dot-plasmon interactions. Assuming that the waveguide is single mode, this paper is concerned about the dependence of spontaneous emission rate of the quantum dot on waveguide dimensions such as width and height. We compare coupling efficiency of a gap waveguide with symmetric configuration and asymmetric configuration illustrating that symmetric waveguide has a better coupling efficiency to the quantum dot. We also demonstrate that optimally placed quantum dot near a symmetric waveguide with 50 nm x 50 nm cross section can capture 80% of the spontaneous emission into a guided plasmon mode.