The allocation of taxing rights of ship and aircraft leasing profits under Australia's tax treaties

The Australian Federal Commissioner of Taxation recently released Draft Taxation Ruling TR 2008/D3 with the stated purpose of clarifying ‘what profits derived from the leasing of ships or aircraft fall within the ship and aircraft articles of each of Australia’s tax treaties’. In particular, TR 2008/D3 explains the taxing rights over different types of leasing profits, such as a full basis lease in respect of any transport by a ship operated in international traffic and bareboat leases which are ancillary to the lessor transport operations of ships in international traffic. This article outlines the Commissioner’s views on the application of the standard ships and aircraft articles in the tax treaties to which it is a party as well as considering the major variations on the standard adoption. In doing so, guidance is provided as to the allocation of taxing rights of ship and aircraft leasing profits under Australia’s tax treaties.

The taxation of international maritime leasing profits : has the commissioners ship come in?

In light of McDermott Industries (AUST) Pty Ltd v Commissioner of Taxation, and Draft Taxation Ruling TR 2006/D8, this article considers the current Australian taxation position of profits arising from the cross-border leasing of vessels in the maritime industry. It focuses on the tax treaties to which Australia is a party, in particular the application of the business profits provisions of those treaties, and the deemed existence of a permanent establishment where substantial equipment, owned by a fiscal non-resident, is used within Australian waters.

Violation of labour rights in the ship-breaking yards of Bangladesh

Ship-breaking started as an industry in Bangladesh in the early 1970s. This industry is not technically organized, and the management is also primitive and unsound. Although specific information is not available, it is estimated that about 700 workers have been killed and, at the same time, a total of 10,000 workers have been injured in explosions at the ship-breaking yards over the last three decades. This process continues unabated in the absence of specific legislation for regulating ship-breaking industries in Bangladesh. Against this backdrop, this paper identifies the major issues relating to enforcement of labour rights in the ship-breaking yards of Bangladesh.

Jacobian-free Newton-Krylov methods with GPU acceleration for computing nonlinear ship wave patterns

The nonlinear problem of steady free-surface flow past a submerged source is considered as a case study for three-dimensional ship wave problems. Of particular interest is the distinctive wedge-shaped wave pattern that forms on the surface of the fluid. By reformulating the governing equations with a standard boundary-integral method, we derive a system of nonlinear algebraic equations that enforce a singular integro-differential equation at each midpoint on a two-dimensional mesh. Our contribution is to solve the system of equations with a Jacobian-free Newton-Krylov method together with a banded preconditioner that is carefully constructed with entries taken from the Jacobian of the linearised problem. Further, we are able to utilise graphics processing unit acceleration to significantly increase the grid refinement and decrease the run-time of our solutions in comparison to schemes that are presently employed in the literature. Our approach provides opportunities to explore the nonlinear features of three-dimensional ship wave patterns, such as the shape of steep waves close to their limiting configuration, in a manner that has been possible in the two-dimensional analogue for some time.

Ship Motion Control : Course Keeping and Roll Stabilisation Using Rudder and Fins

Motion control systems have a significant impact on the performance of ships and marine structures allowing them to perform tasks in severe sea states and during long periods of time. Ships are designed to operate with adequate reliability and economy, and in order to achieve this, it is essential to control the motion. For each type of ship and operation performed (transit, landing a helicopter, fishing, deploying and recovering loads, etc.), there are not only desired motion settings, but also limits on the acceptable (undesired) motion induced by the environment. The task of a ship motion control system is therefore to act on the ship so it follows the desired motion as closely as possible. This book provides an introduction to the field of ship motion control by studying the control system designs for course-keeping autopilots with rudder roll stabilisation and integrated rudder-fin roll stabilisation. These particular designs provide a good overview of the difficulties encountered by designers of ship motion control systems and, therefore, serve well as an example driven introduction to the field. The idea of combining the control design of autopilots with that of fin roll stabilisers, and the idea of using rudder induced roll motion as a sole source of roll stabilisation seems to have emerged in the late 1960s. Since that time, these control designs have been the subject of continuous and ongoing research. This ongoing interest is a consequence of the significant bearing that the control strategy has on the performance and the issues associated with control system design. The challenges of these designs lie in devising a control strategy to address the following issues: underactuation, disturbance rejection with a non minimum phase system, input and output constraints, model uncertainty, and large unmeasured stochastic disturbances. To date, the majority of the work reported in the literature has focused strongly on some of the design issues whereas the remaining issues have been addressed using ad hoc approaches. This has provided an additional motivation for revisiting these control designs and looking at the benefits of applying a contemporary design framework, which can potentially address the majority of the design issues.

Ship roll damping control

The technical feasibility of roll motion control devices has been amply demonstrated for over 100 years. Performance, however, can still fall short of expectations because of difficulties associated with control system designs, which have proven to be far from trivial due to fundamental performance limitations and large variations of the spectral characteristics of wave-induced roll motion. This tutorial paper presents an account of the development of various ship roll motion control systems together with the challenges associated with their design. It discusses the assessment of performance and the applicability of different mathematical models, and it surveys the control methods that have been implemented and validated with full scale experiments. The paper also presents an outlook on what are believed to be potential areas of research within this topic.

Constrained predictive control of ship fin stabilizers to prevent dynamic stall

In moderate to high sea states, the effectiveness of ship fin stabilizers can severely deteriorate due to nonlinear effects arising from unsteady hydrodynamic characteristics of the fins: dynamic stall. These nonlinear effects take the form of a hysteresis, and they become very significant when the effective angle of attack of the fins exceeds a certain threshold angle. Dynamic stall can result in a complete loss of control action depending on how much the fins exceed the threshold angle. When this is detected, it is common to reduce the gain of the controller that commands the fins. This approach is cautious and tends to reduce performance when the conditions leading to dynamic stall disappear. An alternative approach for preventing the effects while keeping high performance, consists of estimating the effective angle of attack and set a conservative constraint on it as part of the control objectives. In this paper, we investigate the latter approach, and propose the use of a model predictive control (MPC) to prevent the development of these nonlinear effects by considering constraints on both the mechanical angle of the fins and the effective angle of attack.

Nonlinear container ship model for the study of parametric roll resonance

Parametric roll is a critical phenomenon for ships, whose onset may cause roll oscillations up to +-40 degrees, leading to very dangerous situations and possibly capsizing. Container ships have been shown to be particularly prone to parametric roll resonance when they are sailing in moderate to heavy head seas. A Matlab/Simulink parametric roll benchmark model for a large container ship has been implemented and validated against a wide set of experimental data. The model is a part of a Matlab/Simulink Toolbox (MSS, 2007). The benchmark implements a 3rd-order nonlinear model where the dynamics of roll is strongly coupled with the heave and pitch dynamics. The implemented model has shown good accuracy in predicting the container ship motions, both in the vertical plane and in the transversal one. Parametric roll has been reproduced for all the data sets in which it happened, and the model provides realistic results which are in good agreement with the model tank experiments.

Energy-based nonlinear control of ship roll gyro-stabiliser with precession angle constraints

In this paper, we consider a passivity-based approach for the design of a control law of multiple ship-roll gyro-stabiliser units. We extend previous work on control of ship roll gyro-stabilisation by considering the problem within a nonlinear framework. In particular, we derive an energy-based model using the port-Hamiltonian theory and then design an active precession controller using passivity-based control interconnection and damping assignment. The design considers the possibility of having multiple gyro-stabiliser units, and the desired potential energy of the system (in closed loop) is chosen to behave like a barrier function, which allows us to enforce constraints on the precession angle of the gyros.

Damping structure selection in nonlinear ship manoeuvring models

This paper presents the application of a statistical method for model structure selection of lift-drag and viscous damping components in ship manoeuvring models. The damping model is posed as a family of linear stochastic models, which is postulated based on previous work in the literature. Then a nested test of hypothesis problem is considered. The testing reduces to a recursive comparison of two competing models, for which optimal tests in the Neyman sense exist. The method yields a preferred model structure and its initial parameter estimates. Alternatively, the method can give a reduced set of likely models. Using simulated data we study how the selection method performs when there is both uncorrelated and correlated noise in the measurements. The first case is related to instrumentation noise, whereas the second case is related to spurious wave-induced motion often present during sea trials. We then consider the model structure selection of a modern high-speed trimaran ferry from full scale trial data.

Ship roll motion control

The technical feasibility of roll motion control devices has been amply demonstrated for over 100 years. Performance, however, can still fall short of expectations because of deficiencies in control system designs, which have proven to be far from trivial due to fundamental performance limitations. This tutorial paper presents an account of the development of various ship roll motion control systems and the challenges associated with their design. The paper discusses how to assess performance, the applicability of different models, and control methods that have been applied in the past.

Analysis of ship roll gyrostabiliser control

The use of dedicated spinning wheels that generate gyroscopic forces for reducing the roll motion of ships was considered and tested over 100 years ago. These devices, known as gyrostabilisers, presented a remarkable performance, but they fell into disuse due to their relatively large size and, primarily, due to the inability of the control systems to maintain performance over an extended envelope of sea states and sailing conditions (speed and heading relative to the waves). To date, advances in materials, mechanical design, electrical drives, and computer control systems have resulted in a revitalized interest in gyro-stabilisers for ships. This paper revisits the modelling of the coupled vessel-gyrostabiliser and delves into the associated gyrostabiliser control design problem. It also describes design trade-offs and potential performance limitations. A simulation study based on a navy patrol vessel is presented.

What is the apparent angle of a Kelvin ship wave pattern?

While the half-angle which encloses a Kelvin ship wave pattern is commonly accepted to be 19.47 degrees, recent observations and calculations for sufficiently fast-moving ships suggest that the apparent wake angle decreases with ship speed. One explanation for this decrease in angle relies on the assumption that a ship cannot generate wavelengths much greater than its hull length. An alternative interpretation is that the wave pattern that is observed in practice is defined by the location of the highest peaks; for wakes created by sufficiently fast-moving objects, these highest peaks no longer lie on the outermost divergent waves, resulting in a smaller apparent angle. In this paper, we focus on the problems of free surface flow past a single submerged point source and past a submerged source doublet. In the linear version of these problems, we measure the apparent wake angle formed by the highest peaks, and observe the following three regimes: a small Froude number pattern, in which the divergent waves are not visible; standard wave patterns for which the maximum peaks occur on the outermost divergent waves; and a third regime in which the highest peaks form a V-shape with an angle much less than the Kelvin angle. For nonlinear flows, we demonstrate that nonlinearity has the effect of increasing the apparent wake angle so that some highly nonlinear solutions have apparent wake angles that are greater than Kelvin's angle. For large Froude numbers, the effect on apparent wake angle can be more dramatic, with the possibility of strong nonlinearity shifting the wave pattern from the third regime to the second. We expect our nonlinear results will translate to other more complicated flow configurations, such as flow due to a steadily moving closed body such as a submarine.

Validation of a container ship model for parametric rolling

The objective of this work is to formulate a nonlinear, coupled model of a container ship during parametric roll resonance, and to validate the model using experimental data.

Shape up or ship out : can we enhance productivity in coastal aquaculture to compete with other uses?

Coastal resources are coming under increasing pressure from competition between recreational, commercial and conservation uses. This is particularly so in coastal areas adjacent to major population centres. Given high recreational and conservation values in such areas, economic activities need to be highly efficient in order to persist. Management of these industries must therefore also encourage efficient production and full utilisation of the areas available. In order to achieve this, managers must first understand the level and drivers of productivity, and how these can be influenced. In this study, by way of illustration, the focus was on the Sydney rock oyster industry within Queensland's Moreton Bay, a multiple use marine park with high recreational and conservation value adjacent to Australia's third largest city. Productivity of the oyster industry in Moreton Bay is currently low compared to historic levels, and management has an objective of reversing this trend. It is unclear whether this difference is due to oyster farmers' business choices and personal characteristics or whether varying environmental conditions in the Moreton Bay limit the capacity of the oyster industry. These require different management responses in order to enhance productivity. The study examined different productivity measures of the oyster industry using data envelopment analysis (DEA) to determine where productivity gains can be made and by how much. The findings suggest that the industry is operating at a high level of capacity utilisation, but a low level of efficiency. The results also suggest that both demographic and environmental conditions affect technical efficiency in the Bay, with water characteristics improvements and appropriate training potentially providing the greatest benefits to the industry. Methods used in this study are transferable to other industries and provide a means by which coastal aquaculture may be managed to ensure it remains competitive with other uses of coastal resources.