896 resultados para implications where Commissioner of Taxation a party to proceedings
Resumo:
It is now well known that pesticide spraying by farmers has an adverse impact on their health. This is especially so in developing countries where pesticide spraying is undertaken manually. The estimated health costs are large. Studies to date have examined farmers’ exposure to pesticides, the costs of ill-health and their determinants based on information provided by farmers. Hence, some doubt has been cast on the reliability of such studies. In this study, we rectify this situation by conducting surveys among two groups of farmers. Farmers who perceive that their ill-health is due to exposure to pesticides and obtained treatment and farmers whose ill-health have been diagnosed by doctors and who have been treated in hospital for exposure to pesticides. In the paper, cost comparisons between the two groups of farmers are made. Furthermore, regression analysis of the determinants of health costs show that the quantity of pesticides used per acre per month, frequency of pesticide use and number of pesticides used per hour per day are the most important determinants of medical costs for both samples. The results have important policy implications.
Resumo:
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.
Resumo:
In 1995, the Federal Commissioner of Taxation released Taxation Ruling TR 95/35 in an attempt to comprehensively address the appropriate capital gains tax treatment of a receipt of compensation, awarded either by the courts or via a settlement. The ruling was in response to the numerous, somewhat contradictory, court decisions of the early 1990s. Despite the release of TR 95/35, there still appears to be a lack of consensus as to the appropriate treatment of such awards. It has been suggested that the only way a taxpayer can, with any certainty, determine their liability is to obtain a private binding ruling, a far from satisfactory situation. In an attempt to clarify what the capital gains tax consequences of a compensation receipt should be, this article examines the Australian position and explores the comparative jurisprudence of the United Kingdom and Canada to ascertain whether the Australian attitude is consistent with these international jurisdictions. This article concludes that while the jurisdictions, through differing approaches, achieve a similar result, there is still a need to address the uncertainties that remain.
Resumo:
In response to developments in international trade and an increased focus on international transfer-pricing issues, Canada’s minister of finance announced in the 1997 budget that the Department of Finance would undertake a review of the transfer-pricing provisions in the Income Tax Act. On September 11, 1997, the Department of Finance released draft transfer-pricing legislation and Revenue Canada released revised draft Information Circular 87-2R. The legislation was subsequently amended and included in Bill C-28, which received first reading on December 10, 1997. The new rules are intended to update Canada’s international transfer-pricing practices. In particular, they attempt to harmonize the standards in the Income Tax Act with the arm’s-length principle established in the OECD’s transfer pricing guidelines. The new rules also set out contemporaneous documentation requirements in respect of cross-border related-party transactions, facilitate administration of the law by Revenue Canada, and provide for a penalty where transfer prices do not comply with the arm’s-length principle. The Australian tax authorities have similarly reviewed and updated their transfer-pricing practices. Since 1992, the Australian commissioner of taxation has issued three rulings and seven draft rulings directly relating to international transfer pricing. These rulings outline the selection and application of transfer pricing methodologies, documentation requirements, and penalties for non-compliance. The Australian Taxation Office supports the use of advance pricing agreements (APAs) and has expanded its audit strategy by conducting transfer-pricing risk assessment reviews. This article presents a detailed review of Australia’s transfer-pricing policy and practices, which address essentially the same concerns as those at which the new Canadian rules are directed. This review provides a framework for comparison of the approaches adopted in the two jurisdictions. The author concludes that although these approaches differ in some respects, ultimately they produce a similar result. Both regimes set a clear standard to be met by multinational enterprises in establishing transfer prices. Both provide for audits and penalties in the event of noncompliance. And both offer the alternative of an APA as a means of avoiding transfer-pricing disputes with Australian and Canadian tax authorities.
Resumo:
Given the increasing vehicle numbers and expanding road construction in developing countries, the importance of safe road user behaviour is critical. Road traffic crashes (RTC) are a significant problem in Pakistan, however the factors that contribute to RTC in Pakistan are not well-researched. Fatalistic beliefs are a potential barrier to the enhancement of road safety, especially participation in health-promoting and injury prevention behaviours, and also contribute to risk-taking. Fatalistic beliefs relating to road safety have been found in some developing countries, although again research is scarce and indicates that the nature and extent of fatalism differs in each country. Qualitative research was undertaken with a range of drivers, religious orators, police and policy makers to explore associations between fatalism, risky road use and associated issues. Findings indicate that fatalistic beliefs are pervasive in Pakistan, are strongly linked with religion, present a likely barrier to road safety messages and contribute to risky road use. Fatalism appears to be a default attribution of RTC and the intensity of belief in fate surpasses the kinds of fatalism noted in the limited existing literature. These findings have importance to developing road safety countermeasures in countries where fatalistic beliefs are strong.
Resumo:
The decision of Lai v Soineva [2011] QSC 247 in relation to the operation of standard conditions in the Queensland REIQ contract highlights a very practical issue often overlooked in the heat of a transaction .The point is relatively simple. In this instance ,the case concerned the interpretation of the printed "Building and Pest Inspection Clause" but is of relevance to the printed "Finance Clause" in the same contract as the wording and principles are identical. It highlights the issue of knowing well what is in the standard contract and not making assumptions. The case also highlights the cost to a party of dithering in making an election in a time of the essence environment
Resumo:
Related-party (RP) transactions are said to be commonly used opportunistically in business and contribute to corporate failures. While periodic disclosure is widely accepted as an effective means of monitoring such transactions, research is scant, particularly in countries where business dealings may be more susceptible to corruption. This study investigates the nature and extent of corporate RP disclosures across six countries in the Asia-Pacific region. The key finding indicates that companies in countries with stronger regulatory enforcement, shareholders’ protection, and control for corruption, have more transparent RP disclosures. This evidence potentially contributes to reforms aimed at strengthening RP disclosure and compliance.
Resumo:
This paper proposes how ecological dynamics, a theory focusing on the performer-environment relationship, provides a basis for understanding skill acquisition in sport. From this perspective, learners are conceptualized as complex, neurobiological systems in which inherent self-organisation tendencies support the emergence of adaptive behaviours under a range of interacting task and environmental constraints. Intentions, perceptions and actions are viewed as intertwined processes which underpin functional movement solutions assembled by each learner during skill acquisition. These ideas suggest that skill acquisition programmes need to sample information from the performance environment to guide behaviour in practice tasks. Skill acquisition task protocols should allow performers to use movement variability to explore and create opportunities for action, rather than constraining them to passively receiving information. This conceptualisation also needs to characterize the design of talent evaluation tests, which need to faithfully represent the perception-action relationships in the performance environment. Since the dynamic nature of changing task constraints in sports cannot be predicted over longer timescales, an implication is that talent programmes should focus on developing performance expertise in each individual, rather than over-relying on identification of expert performers at specific points in time.
Resumo:
1. Stream ecosystem health monitoring and reporting need to be developed in the context of an adaptive process that is clearly linked to identified values and objectives, is informed by rigorous science, guides management actions and is responsive to changing perceptions and values of stakeholders. To be effective, monitoring programmes also need to be underpinned by an understanding of the probable causal factors that influence the condition or health of important environmental assets and values. This is often difficult in stream and river ecosystems where multiple stressors, acting at different spatial and temporal scales, interact to affect water quality, biodiversity and ecosystem processes. 2. In this article, we describe the development of a freshwater monitoring programme in South East Queensland, Australia, and how this has been used to report on ecosystem health at a regional scale and to guide investments in catchment protection and rehabilitation. We also discuss some of the emerging science needs to identify the appropriate scale and spatial arrangement of rehabilitation to maximise river ecosystem health outcomes and, at the same time, derive other benefits downstream. 3. An objective process was used to identify potential indicators of stream ecosystem health and then test these across a known catchment land-use disturbance gradient. From the 75 indicators initially tested, 22 from five indicator groups (water quality, ecosystem metabolism, nutrient cycling, invertebrates and fish) responded strongly to the disturbance gradient, and 16 were subsequently recommended for inclusion in the monitoring programme. The freshwater monitoring programme was implemented in 2002, funded by local and State government authorities, and currently involves the assessment of over 120 sites, twice per year. This information, together with data from a similar programme on the region's estuarine and coastal marine waters, forms the basis of an annual report card that is presented in a public ceremony to local politicians and the broader community. 4. Several key lessons from the SEQ Healthy Waterways Programme are likely to be transferable to other regional programmes aimed at improving aquatic ecosystem health, including the importance of a shared common vision, the involvement of committed individuals, a cooperative approach, the need for defensible science and effective communication. 5. Thematic implications: this study highlights the use of conceptual models and objective testing of potential indicators against a known disturbance gradient to develop a freshwater ecosystem health monitoring programme that can diagnose the probable causes of degradation from multiple stressors and identify the appropriate spatial scale for rehabilitation or protection. This approach can lead to more targeted management investments in catchment protection and rehabilitation, greater public confidence that limited funds are being well spent and better outcomes for stream and river ecosystem health.
Resumo:
We identified the active ingredients in people’s visions of society’s future (“collective futures”) that could drive political behavior in the present. In eight studies (N = 595), people imagined society in 2050 where climate change was mitigated (Study 1), abortion laws relaxed (Study 2), marijuana legalized (Study 3), or the power of different religious groups had increased (Studies 4-8). Participants rated how this future society would differ from today in terms of societal-level dysfunction and development (e.g., crime, inequality, education, technology), people’s character (warmth, competence, morality), and their values (e.g., conservation, self-transcendence). These measures were related to present-day attitudes/intentions that would promote/prevent this future (e.g., act on climate change, vote for a Muslim politician). A projection about benevolence in society (i.e., warmth/morality of people’s character) was the only dimension consistently and uniquely associated with present-day attitudes and intentions across contexts. Implications for social change theories, political communication, and policy design are discussed.
Resumo:
Alcohol-related mortality and morbidity represents a substantial financial burden on communities across the world. Adolescence and young adulthood is a peak period for heavy episodic alcohol consumption, with over a third of all people aged 14-19 years having been at risk of acute alcoholrelated harm at least once in the previous 12 months (Australian Institute of Health and Welfare [AIHW], 2011). Excessive alcohol consumption has long been seen as a male problem; however, a gradual shift towards a social acceptance of female drunkenness has narrowed the gap in drinking quantity and style between men and women (Grucza, Bucholz, Rice, & Bierut, 2008). The presented data point to the vulnerability of women to the consequences of acute alcohol intoxication and indicate that alcohol-related offending by women is on the rise. Taken together, these findings reveal that alcohol-related harms and aggression for young women are becoming more prevalent and problematic. This report addressed these issues from a policing perspective...
Resumo:
This thesis considers whether the Australian Privacy Commissioner's use of its powers supports compliance with the requirement to 'take reasonable steps' to protect personal information in National Privacy Principle 4 of the Privacy Act 1988 (Cth). Two unique lenses were used. First, the Commissioner's use of powers was assessed against the principles of transparency, balance and vigorousness and secondly against alignment with an industry practice approach to securing information. Following a comprehensive review of publicly available materials, interviews and investigation file records, this thesis found that the Commissioner's use of his powers has not been transparent, balanced or vigorous, nor has it been supportive of an industry practice approach to securing data. Accordingly, it concludes that the Privacy Commissioner's use of its regulatory powers is unlikely to result in any significant improvement to the security of personal information held by organisations in Australia.
Resumo:
A review of factors that may impact on the capacity of beef cattle females, grazing semi-extensive to extensive pastures in northern Australia, to conceive, maintain a pregnancy and wean a calf was conducted. Pregnancy and weaning rates have generally been used to measure the reproductive performance of herds. However, this review recognises that reproductive efficiency and the general measures associated with it more effectively describe the economic performance of beef cattle enterprises. More specifically, reproductive efficiency is influenced by (1) pregnancy rate which is influenced by (i) age at puberty; (ii) duration of post-partum anoestrus; (iii) fertilisation failure and (iv) embryo survival; while (2) weight by number of calves per breeding female retained for mating is influenced by (i) cow survival; (ii) foetal survival; and (iii) calf survival; and (3) overall lifetime calf weight weaned per mating. These measures of reproductive efficiency are discussed in depth. Further, a range of infectious and non-infectious factors, namely, environmental, physiological, breed and genetic factors and their impact on these stages of the reproductive cycle are investigated and implications for the northern Australian beef industry are discussed. Finally, conclusions and recommendations to minimise reproductive inefficiencies based on current knowledge are presented.