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.

A variable diffusivity model for the drying of spherical food particulates

An investigation of the drying of spherical food particles was performed, using peas as the model material. In the development of a mathematical model for drying curves, moisture diffusion was modelled using Fick’s second law for mass transfer. The resulting partial differential equation was solved using a forward-time central-space finite difference approximation, with the assumption of variable effective diffusivity. In order to test the model, experimental data was collected for the drying of green peas in a fluidised bed at three drying temperatures. Through fitting three equation types for effective diffusivity to the data, it was found that a linear equation form, in which diffusivity increased with decreasing moisture content, was most appropriate. The final model accurately described the drying curves of the three experimental temperatures, with an R2 value greater than 98.6% for all temperatures.

A SiC-based matrix converter topology for inductive power transfer system

Typical inductive power transfer (IPT) systems employ two power conversion stages to generate a high-frequency primary current from low-frequency utility supply. This paper proposes a matrix-converter-based IPT system, which employs high-speed SiC devices to facilitate the generation of high-frequency current through a single power conversion stage. The proposed matrix converter topology transforms a three-phase low-frequency voltage system to a high-frequency single-phase voltage, which, in turn, powers a series compensated IPT system. A comprehensive mathematical model is developed and power losses are evaluated to investigate the efficiency of the proposed converter topology. Theoretical results are presented with simulations, which are performed in MATLAB/Simulink, in comparison to a conventional two-stage converter. Experimental evident of a prototype IPT system is also presented to demonstrate the applicability of the proposed concept.

Capital cost model for Robert evaporators

ROBERT EVAPORATORS in Australian sugar factories are traditionally constructed with 44.45 mm outside diameter stainless steel tubes of ~2 m length for all stages of evaporation. There are a few vessels with longer tubes (up to 2.8 m) and smaller and larger diameters (38.1 and 50.8 mm). Queensland University of Technology is undertaking a study to investigate the heat transfer performance of tubes of different lengths and diameters for the whole range of process conditions typically encountered in the evaporator set. Incorporation of these results into practical evaporator designs requires an understanding of the cost implications for constructing evaporator vessels with calandrias having tubes of different dimensions. Cost savings are expected for tubes of smaller diameter and longer length in terms of material, labour and installation costs in the factory. However these savings must be considered in terms of the heat transfer area requirements for the evaporation duty, which will likely be a function of the tube dimensions. In this paper a capital cost model is described which provides a relative cost of constructing and installing Robert evaporators of the same heating surface area but with different tube dimensions. Evaporators of 2000, 3000, 4000 and 5000 m2 are investigated. This model will be used in conjunction with the heat transfer efficiency data (when available) to determine the optimum tube dimensions for a new evaporator at a specified evaporation duty. Consideration is also given to other factors such as juice residence time (and implications for sucrose degradation and control) and droplet de-entrainment in evaporators of different tube dimensions.

Workflow patterns as a means to model task succession in games – a preliminary case study

Over about the last decade, people involved in game development have noted the need for more formal models and tools to support the design phase of games. It is argued that the present lack of such formal tools is currently hindering knowledge transfer among designers. Formal visual languages, on the other hand, can help to more effectively express, abstract and communicate game design concepts. Moreover, formal tools can assist in the prototyping phase, allowing designers to reason about and simulate game mechanics on an abstract level. In this paper we present an initial investigation into whether workflow patterns – which have already proven to be effective for modeling business processes – are a suitable way to model task succession in games. Our preliminary results suggest that workflow patterns show promise in this regard but some limitations, especially in regard to time constraints, currently restrict their potential.

A model for estimating grid side harmonics of matrix converter based bi-directional IPT systems

Matrix converter (MC) based bi-directional inductive power transfer (BD-IPT) systems are gaining popularity as an efficient and reliable technique with single stage grid integration as opposed to two stage grid integration of conventional grid connected BD-IPT systems. However MCs are invariably rich in harmonics and thus affect both power quality and power factor on the grid side. This paper proposes a mathematical model through which the grid side harmonics of MC based BD-IPT systems can accurately be estimated. The validity of the proposed mathematical model is verified using simulated results of a 3 kW BD-IPT system and results suggest that the MC based BD-IPT systems have a better power factor with higher power quality over conventional grid connected rectifier based systems.

Myeloma-induced alloreactive T cells arising in myeloma-infiltrated bones include double-positive CD8+CD4+ T cells : evidence from myeloma-bearing mouse model

The graft-versus-myeloma (GVM) effect represents a powerful form of immune attack exerted by alloreactive T cells against multiple myeloma cells, which leads to clinical responses in multiple myeloma transplant recipients. Whether myeloma cells are themselves able to induce alloreactive T cells capable of the GVM effect is not defined. Using adoptive transfer of T naive cells into myeloma-bearing mice (established by transplantation of human RPMI8226-TGL myeloma cells into CD122(+) cell-depleted NOD/SCID hosts), we found that myeloma cells induced alloreactive T cells that suppressed myeloma growth and prolonged survival of T cell recipients. Myeloma-induced alloreactive T cells arising in the myeloma-infiltrated bones exerted cytotoxic activity against resident myeloma cells, but limited activity against control myeloma cells obtained from myeloma-bearing mice that did not receive T naive cells. These myeloma-induced alloreactive T cells were derived through multiple CD8(+) T cell divisions and enriched in double-positive (DP) T cells coexpressing the CD8alphaalpha and CD4 coreceptors. MHC class I expression on myeloma cells and contact with T cells were required for CD8(+) T cell divisions and DP-T cell development. DP-T cells present in myeloma-infiltrated bones contained a higher proportion of cells expressing cytotoxic mediators IFN-gamma and/or perforin compared with single-positive CD8(+) T cells, acquired the capacity to degranulate as measured by CD107 expression, and contributed to an elevated perforin level seen in the myeloma-infiltrated bones. These observations suggest that myeloma-induced alloreactive T cells arising in myeloma-infiltrated bones are enriched with DP-T cells equipped with cytotoxic effector functions that are likely to be involved in the GVM effect.

A matrix converter based Inductive Power Transfer system

Typical Inductive Power Transfer (IPT) systems employ two power conversion stages to generate a high frequency current from low frequency utility supply. This paper proposes a matrix converter based IPT system that facilitates the generation of high frequency current through a single power conversion stage. The proposed matrix converter topology transforms a 3-phase low frequency voltage system to a high frequency single phase voltage which in turn powers a series compensated IPT system. A comprehensive mathematical model is developed to investigate the behavior of the proposed IPT topology. Theoretical results are presented in comparison to simulations, which are performed in Matlab/ Simulink, to demonstrate the applicability of the proposed concept and the validity of the developed model.

Cascaded multilevel converter based bidirectional inductive power transfer (BIPT) system

A typical low power IPT system employs an H-Bridge converter with a simple control strategy to generate a high frequency current from DC power supply. This paper proposes a cascaded multilevel converter for bidirectional IPT (BIPT) systems, which is suitable for low to medium power applications as well as for situations such as PV cells where several individual DC sources are to be utilized. A novel modulation strategy is proposed for the multilevel converter with the aim of minimizing switching losses. Series - Series (SS) compensation circuit is adopted for the IPT system and a mathematical model is presented to minimize the coil losses of the system under varying output power. Theoretical results presented in comparison to the simulations to demonstrate the applicability of the proposed concept and the validity of the developed model. The experimental results show the feasibility of the proposed phase shift modulation.

Theoretical modelling of momentum transfer function of bi-disperse porous media

The aim of this paper is to obtain the momentum transfer coefficient between the two phases, denoted by f and p, occupying a bi-disperse porous medium by mapping the available experimental data to the theoretical model proposed by Nield and Kuznetsov. Data pertinent to plate-fin heat exchangers, as bi-disperse porous media, were used. The measured pressure drops for such heat exchangers are then used to give the overall permeability which is linked to the porosity and permeability of each phase as well as the interfacial momentum transfer coefficient between the two phases. Accordingly, numerical values are obtained for the momentum transfer coefficient for three different fin spacing values considered in the heat exchanger experiments.

Numerical study of turbulent fluid flow and heat transfer in lateral perforated extended surfaces

Numerical study has been performed in this study to investigate the turbulent convection heat transfer on a rectangular plate mounted over a flat surface. Thermal and fluid dynamic performances of extended surfaces having various types of lateral perforations with square, circular, triangular and hexagonal cross sections are investigated. RANS (Reynolds averaged Navier–Stokes) based modified k–ω turbulence model is used to calculate the fluid flow and heat transfer parameters. Numerical results are compared with the results of previously published experimental data and obtained results are in reasonable agreement. Flow and heat transfer parameters are presented for Reynolds numbers from 2000 to 5000 based on the fin thickness.

Free Energy Gap Dependence of the Electron-Transfer Rate from the Inverted to the Normal Region

numerical study of the free energy gap (FEG) dependence of the electron-transfer rate in polar solvents is presented. This study is based on the generalized multidimensional hybrid model, which not only includes the solvent polarization and the molecular vibration modes, but also the biphasic polar response of the solvent. The free energy gap dependence is found to be sensitive to several factors, including the solvent relaxation rate, the electronic coupling between the surfaces, the frequency of the high-frequency quantum vibrational mode, and the magnitude of the solvent reorganization energy. It is shown that in some cases solvent relaxation can play an important role even in the Marcus normal regime. The minimal hybrid model involves a large number of parameters, giving rise to a diverse non-Marcus FEG behavior which is often determined collectively by these parameters. The model gives the linear free energy gap dependence of the logarithmic rate over a substantial range of FEG, spanning from the normal to the inverted regime. However, even for favorable values of the relevant parameters, a linear free energy gap dependence of the rate could be obtained only over a range of 5000-6000 cm(-1) (compared to the experimentally observed range of 10000 cm(-1) reported by Benniston et al.). The present work suggests several extensions/generalizations of the hybrid model which might be necessary to fully understand the observed free energy gap dependence.

Temperature measurements in the boron carbide manufacturing process - A hot model study

Boron carbide is produced in a heat resistance furnace using boric oxide and petroleum coke as the raw materials. The product yield is very low. Heat transfer plays an important role in the formation of boron carbide. Temperature at the core reaches up to 2600 K. No experimental study is available in the open literature for this high temperature process particularly in terms of temperature measurement and heat transfer. Therefore, a laboratory scale hot model of the process has been setup to measure the temperatures in harsh conditions at different locations in the furnace using various temperature measurement devices such as pyrometer and various types of thermocouple. Particular attention was paid towards the accuracy and reliability of the measured data. The recorded data were analysed to understand the heat transfer process inside the reactor and the effect of it on the formation of boron carbide.