The inherent international tax regime and its constraints on Australia's sovereignty

On 1 November 2011 the Minister for Financial Services and Superannuation, the Honourable Bill Shorten MP, announced that Australia would be undertaking a reform of the ‘transfer pricing rules in the income tax law and Australia’s future tax treaties to bring them into line with international best practice, improving the integrity and efficiency of the tax system.’ Mr Shorten stated that the reason for the reform was that ‘recent court decisions suggest our existing transfer pricing rules may be interpreted in a way that is out-of-kilter with international norms.’ Further, he stated that ‘the Government has asked the Treasury to review how the transfer pricing rules can be improved, including but not limited to how to be more in line with international best practice.’ He urged all interested parties to participate in this consultation process. On 16 March 2012, an Exposure Draft and accompanying Explanatory Memorandum outlining the proposed amendments to implement the first stage of the transfer pricing reforms were released. Within the proposed changes is the explicit embedding of the use of the OECD’s Model Tax Convention on Income and on Capital and Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations to help determine the arm’s length price. Does this mean that Australia engages in an international tax regime?

Gender differences in recreational and transport cycling : a cross-sectional mixed-methods comparison of cycling patterns, motivators, and constraints

Background: Gender differences in cycling are well-documented. However, most analyses of gender differences make broad comparisons, with few studies modeling male and female cycling patterns separately for recreational and transport cycling. This modeling is important, in order to improve our efforts to promote cycling to women and men in countries like Australia with low rates of transport cycling. The main aim of this study was to examine gender differences in cycling patterns and in motivators and constraints to cycling, separately for recreational and transport cycling. Methods: Adult members of a Queensland, Australia, community bicycling organization completed an online survey about their cycling patterns; cycling purposes; and personal, social and perceived environmental motivators and constraints (47% response rate). Closed and open-end questions were completed. Using the quantitative data, multivariable linear, logistic and ordinal regression models were used to examine associations between gender and cycling patterns, motivators and constraints. The qualitative data were thematically analysed to expand upon the quantitative findings. Results: In this sample of 1862 bicyclists, men were more likely than women to cycle for recreation and for transport, and they cycled for longer. Most transport cycling was for commuting, with men more likely than women to commute by bicycle. Men were more likely to cycle on-road, and women off-road. However, most men and women did not prefer to cycle on-road without designed bicycle lanes, and qualitative data indicated a strong preference by men and women for bicycle-only off-road paths. Both genders reported personal factors (health and enjoyment related) as motivators for cycling, although women were more likely to agree that other personal, social and environmental factors were also motivating. The main constraints for both genders and both cycling purposes were perceived environmental factors related to traffic conditions, motorist aggression and safety. Women, however, reported more constraints, and were more likely to report as constraints other environmental factors and personal factors. Conclusion: Differences found in men’s and women’s cycling patterns, motivators and constraints should be considered in efforts to promote cycling, particularly in efforts to increase cycling for transport.

Creating new possibilities : using design processes to overcome constraints

This paper describes how a team from a large company, when faced with a challenge to develop new customers in fast growing international markets, carried out the exploration of the needs of new clients in the largely unexplored market space of a developing country. This team used design methods and processes to identify the latent needs of new customers in situations of major economic, geographical, cultural and financial constraints. This encapsulation of the life experiences of potential customers is used extensively in some new product development, but is largely novel to business practices and in processes of developing new services. This research links with the sub-theme of discovering creativity in necessity and highlights the potential benefits of design methodologies to create new possibilities for better accessibility of the company’s products to new clients, with future implications for organizational strategy. The overall theme of Design for the Colloquium encourages exploration of the ways and means of developing new ideas for new business with better outcomes, using design concepts and design technologies.

Analysis of the damping properties of high-transmission-ratio Cycloidal drives

Cycloidal drives are widely used in today’s industries for drives where large reduction ratios are required. Drive-train dynamics plays an important role in their design. This paper presents a new methodology for assessing damping characteristics of Cycloidal drives and compares the natural frequencies obtained from experiments and theoretical/numerical calculations using Fast-Fourier-Transforms.

Waving or drowning? Managing resource constraints in entrepreneurial firm with bricolage as a response to the global financial crisis

These are challenging times for new entrepreneurial firms. The development of the Global Financial Crisis shook the very foundations of global markets and institutions that most firms relied on to do business (Claessens, et al., forthcoming). In the midst of institutional flux and resource constraints, entrepreneurial firms, which have been shown to make a range of contributions to the economy (van Praag & Versloot 2007) faced increasing constraints. The Australian Federal Government quickly implemented the Green Loan program in response to the financial crisis. Unfortunately, the green loans program was flawed with obsolete processes and information (Faulkner, 2011), further constraining new firms. Prior research provides few clues regarding how resource-constrained entrepreneurial firms deal with these institutional flaws within institutional change and how they might overcome these challenges and prosper. One promising theory that evaluates behavioural responses to constraints and institutional flaws is bricolage (Levi Strauss, 1967). Bricolage aligns with notions of resourcefulness: defined here as “making do by applying combinations of the resources at hand to new problems and opportunities” (Baker and Nelson 2005: 333). Using three case studies, we consider how institutional flaws impact firm behaviours and illustrate the use of bricolage in attempts to reinforce, shape and change the GL program further extending bricolage domains of Baker and Nelson (2005).

Impact of wind power development on transmission planning at Midwest ISO

The Midwest Independent Transmission System Operator (MISO) has experienced significant amounts of wind power development within the last decade. The MISO footprint spans the majority of the upper Midwest region of the country, from the Dakotas to Indiana and as far east as Michigan. These areas have a rich wind energy resource. States in the MISO footprint have passed laws or set goals that require load serving entities to supply a portion of their load using renewable energy. In order to meet these requirements, significant investments are needed to build the transmission infrastructure necessary to deliver the power from these often remote wind energy resources to the load centers. This paper presents some of the transmission planning related work done at MISO which was largely influenced by current and future needs for increased wind power generation in the footprint. Specifically, topics covered are generator interconnection, long-term planning coordination, and cost-allocation for new transmission lines.

Long term transmission planning to meet renewable energy targets in Australia

Australia is rich in renewable energy resources such as wind, solar and geothermal. Geographical diversity of these renewable resources combined with developing climate change policies poses a great challenge for the long term interconnection planning. Intermittency of wind and solar potentially driving the development of new transmission lines bring additional complexity to power system operations and planning. This paper provides an overview of generation and transmission planning studies in Australia to meet 20% renewable energy target by 2020. Appraisal of the effectiveness of dispersed energy storage, non schedulable peaking plants, wide area controls and demand management techniques to aid the penetration of renewables is presented in this paper

Innovative planning approaches for generator interconnection group study

Today, a large number of wind generator interconnection requests have been queued and are being processed. The generator interconnection group study is a way to reduce the generator interconnection cycle time and increase interconnection certainty. However, it is very challenging to identify the “best” transmission upgrades for a large group of generator interconnections. It is also very important to differentiate the constraints caused by each generator interconnection request and identify their responsibilities for transmission upgrades. This paper outlines some innovative study approaches that can be used in a group study with large numbers of generator interconnection requests in a constrained area. Improved study methods are introduced, and a summary and conclusions are derived from the study.

Could BFFB mode breath aerosol play a role in H5N1 transmission?

Recent findings concerning exhaled aerosol size distributions and the regions in the respiratory tract in which they are generated could have significant implications for human to human spread of lower respiratory tract-specific infections. Even in healthy people, measurable quantities of aerosol are routinely generated from the Lower Respiratory Tract (LRT) during breathing(1-3). We have found that there at least three modes in the exhaled aerosol size distribution of healthy adults(4) (see Figure 1). These modes each have a characteristic size and arise from different parts of the respiratory tract. The respiratory bronchioles produce aerosol during breathing, the larynx during speech and the oral cavity also during speech. The model of the resulting droplet size distribution is therefore called the Bronchial Laryngeal Oral (B.L.O.) tri-modal model of expired aerosol.

Passenger transmission and productiveness of transit lines with high loads

Deterministic transit capacity analysis applies to planning, design and operational management of urban transit systems. The Transit Capacity and Quality of Service Manual (1) and Vuchic (2, 3) enable transit performance to be quantified and assessed using transit capacity and productive capacity. This paper further defines important productive performance measures of an individual transit service and transit line. Transit work (p-km) captures the transit task performed over distance. Passenger transmission (p-km/h) captures the passenger task delivered by service at speed. Transit productiveness (p-km/h) captures transit work performed over time. These measures are useful to operators in understanding their services’ or systems’ capabilities and passenger quality of service. This paper accounts for variability in utilized demand by passengers along a line and high passenger load conditions where passenger pass-up delay occurs. A hypothetical case study of an individual bus service’s operation demonstrates the usefulness of passenger transmission in comparing existing and growth scenarios. A hypothetical case study of a bus line’s operation during a peak hour window demonstrates the theory’s usefulness in examining the contribution of individual services to line productive performance. Scenarios may be assessed using this theory to benchmark or compare lines and segments, conditions, or consider improvements.

Spectrum sensing, detection and optimisation in cognitive radio for non-stationary primary user signals

Cognitive radio is an emerging technology proposing the concept of dynamic spec- trum access as a solution to the looming problem of spectrum scarcity caused by the growth in wireless communication systems. Under the proposed concept, non- licensed, secondary users (SU) can access spectrum owned by licensed, primary users (PU) so long as interference to PU are kept minimal. Spectrum sensing is a crucial task in cognitive radio whereby the SU senses the spectrum to detect the presence or absence of any PU signal. Conventional spectrum sensing assumes the PU signal as ‘stationary’ and remains in the same activity state during the sensing cycle, while an emerging trend models PU as ‘non-stationary’ and undergoes state changes. Existing studies have focused on non-stationary PU during the transmission period, however very little research considered the impact on spectrum sensing when the PU is non-stationary during the sensing period. The concept of PU duty cycle is developed as a tool to analyse the performance of spectrum sensing detectors when detecting non-stationary PU signals. New detectors are also proposed to optimise detection with respect to duty cycle ex- hibited by the PU. This research consists of two major investigations. The first stage investigates the impact of duty cycle on the performance of existing detec- tors and the extent of the problem in existing studies. The second stage develops new detection models and frameworks to ensure the integrity of spectrum sensing when detecting non-stationary PU signals. The first investigation demonstrates that conventional signal model formulated for stationary PU does not accurately reflect the behaviour of a non-stationary PU. Therefore the performance calculated and assumed to be achievable by the conventional detector does not reflect actual performance achieved. Through analysing the statistical properties of duty cycle, performance degradation is proved to be a problem that cannot be easily neglected in existing sensing studies when PU is modelled as non-stationary. The second investigation presents detectors that are aware of the duty cycle ex- hibited by a non-stationary PU. A two stage detection model is proposed to improve the detection performance and robustness to changes in duty cycle. This detector is most suitable for applications that require long sensing periods. A second detector, the duty cycle based energy detector is formulated by integrat- ing the distribution of duty cycle into the test statistic of the energy detector and suitable for short sensing periods. The decision threshold is optimised with respect to the traffic model of the PU, hence the proposed detector can calculate average detection performance that reflect realistic results. A detection framework for the application of spectrum sensing optimisation is proposed to provide clear guidance on the constraints on sensing and detection model. Following this framework will ensure the signal model accurately reflects practical behaviour while the detection model implemented is also suitable for the desired detection assumption. Based on this framework, a spectrum sensing optimisation algorithm is further developed to maximise the sensing efficiency for non-stationary PU. New optimisation constraints are derived to account for any PU state changes within the sensing cycle while implementing the proposed duty cycle based detector.

The inherent international tax regime and its constraints on Australia's sovereignty

Neither an international tax, nor an international taxing body exists. Rather, there are domestic taxing rules adopted by jurisdictions which, coupled with double tax treaties, apply to cross-border transactions and international taxation issues. International bodies such as the OECD and UN, which provide guidance on tax issues, often steer and supplement these domestic adoptions but have no binding international taxing powers. These pragmatic realities, together with the specific use of the word ‘regime’ within the tax community, lead many to argue that an international tax regime does not exist. However, an international tax regime should be defined no differently to any other area of international law and when we step outside the confines of tax law to consider the definition of a ‘regime’ within international relations it is possible to demonstrate that such a regime is very real. The first part of this article, by defining an international tax regime in a broader and more traditional context, also outlining both the tax policy and principles which frame that regime, reveals its existence. Once it is accepted that an international tax regime exists, it is possible to consider its adoption by jurisdictions and subsequent constraints it places on them. Using the proposed changes to transfer pricing laws as the impetus for assessing Australia’s adoption of the international tax regime, the constraints on sovereignty are assessed through a taxonomy of the level adoption. This reveals the subsequent constraints which flow from the broad acceptance of an international tax regime through to the specific adoption of technical detail. By undertaking this analysis, the second part of this article demonstrates that Australia has inherently adopted an international tax regime, with a move towards explicit adoption and a clear embedding of its principles within the domestic tax legislation.

Can slide positivity rates predict malaria transmission?

Background: Malaria is a significant threat to population health in the border areas of Yunnan Province, China. How to accurately measure malaria transmission is an important issue. This study aimed to examine the role of slide positivity rates (SPR) in malaria transmission in Mengla County, Yunnan Province, China. Methods: Data on annual malaria cases, SPR and socio-economic factors for the period of 1993 to 2008 were obtained from the Center for Disease Control and Prevention (CDC) and the Bureau of Statistics, Mengla, China. Multiple linear regression models were conducted to evaluate the relationship between socio-ecologic factors and malaria incidence. Results: The results show that SPR was significantly positively associated with the malaria incidence rates. The SPR (beta = 1.244, p = 0.000) alone and combination (SPR, beta = 1.326, p < 0.001) with other predictors can explain about 85% and 95% of variation in malaria transmission, respectively. Every 1% increase in SPR corresponded to an increase of 1.76/100,000 in malaria incidence rates. Conclusion: SPR is a strong predictor of malaria transmission, and can be used to improve the planning and implementation of malaria elimination programmes in Mengla and other similar locations. SPR might also be a useful indicator of malaria early warning systems in China.

One-year delayed effect of fog on malaria transmission : a time-series analysis in the rain forest area of Mengla County, south-west China

Background: Malaria is a major public health burden in the tropics with the potential to significantly increase in response to climate change. Analyses of data from the recent past can elucidate how short-term variations in weather factors affect malaria transmission. This study explored the impact of climate variability on the transmission of malaria in the tropical rain forest area of Mengla County, south-west China. Methods: Ecological time-series analysis was performed on data collected between 1971 and 1999. Auto-regressive integrated moving average (ARIMA) models were used to evaluate the relationship between weather factors and malaria incidence. Results: At the time scale of months, the predictors for malaria incidence included: minimum temperature, maximum temperature, and fog day frequency. The effect of minimum temperature on malaria incidence was greater in the cool months than in the hot months. The fog day frequency in October had a positive effect on malaria incidence in May of the following year. At the time scale of years, the annual fog day frequency was the only weather predictor of the annual incidence of malaria. Conclusion: Fog day frequency was for the first time found to be a predictor of malaria incidence in a rain forest area. The one-year delayed effect of fog on malaria transmission may involve providing water input and maintaining aquatic breeding sites for mosquitoes in vulnerable times when there is little rainfall in the 6-month dry seasons. These findings should be considered in the prediction of future patterns of malaria for similar tropical rain forest areas worldwide.

Informational constraints on the emergence of passing direction in the team sport of futsal

This study investigated compound spatial and temporal measures of interpersonal interactions purported to constrain the emergence of affordances for passing direction in the team sport of futsal. For this purpose, attacker–defender interactions in 37 sequences of play from a futsal competition in which 24 male professional players participated (M=30.04 years, SD=4.10) were filmed and analysed using TACTO software. Relative angle data were used as measures to study coordination tendencies that emerged between players during performance. Results showed that the direction for a pass emerged from relative angles between: (1) the vector from a ball carrier to ball receiver and the vector from the ball carrier to the nearest defender (70°) (p<0.01) and (2) the vector from a ball carrier to ball receiver and the vector from the ball carrier to a ball receiver's nearest defender (31°) (p < 0.01). Furthermore, passing direction was also constrained by temporal information from the emergence of both angles, since the pass was performed to attacker–defender dyads with the highest velocities of these angles (p < 0.05). Results suggested that decisions on selecting the direction of a pass in the team sport of futsal emerged at critical values of these key compound motion measures.