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.

Newstead House : the social history, culture and architecture of a bygone era

Historic house museums form a significant component of the built heritage and social history of a country. They vary from the elaborate mansions of the wealthy to modest dwellings of the working class. Regardless of the original owner's status in society these house museums are vital to an understanding of architecture, culture and society from a bygone era. The Newstead House, the oldest surviving residence, in Brisbane, is the first house to be designated a 'Historic House Museum' in Queensland. It is a representative example of a house that demonstrates the British colonial heritage of 19th century Australia. Originally a modest cottage, on 34 acres of land, the Newstead house was built by a Scottish migrant. The ownership of the house and land changed many times, during the period from 1847 to 1939. During this period a series of prominent residents of Brisbane either owned or rented this residence. They included, an officer of the Royal Navy, politicians, magistrates, merchant ship owners, and a Consul General of the United States of America. As a result, the house went through a series of renovations and extensions to accommodate the needs of its owners and their position in society. This paper aims to investigate the significance of historic museum houses in educating the community on aspects of social history, culture and architecture of 19th century Australia. It will focus on the heritage listed Newstead House as a case study to demonstrate the significance of the house as an artefact and an educational tool.

The significance of owner participation for a successful detached housing development in Malaysia

The detached housing scheme is a unique and exclusive segment of the residential property market in Malaysia. Generally, the product is expensive and for many Malaysians who can afford them, owning a detached house is a once in a lifetime opportunity. In spite of this, most of the owners failed to fully comprehend the specific need of this type of housing scheme, increasing the risk of it being a problematic undertaking. Unlike other types of pre-designed "mass housing" schemes, the detached housing scheme may be built specifically to cater the needs and demands of its owner. Therefore, owner participation during critical development stages is vital to guarantee the success of the development as a whole. In addition, due to its unique design the house would have to individually comply with the requirements and regulations of relevant authorities. Failure by the owner to recognise this will result in delays, penalties, disputes and ultimately cost overruns. These circumstances highlight the need for a research to guide the owner through participation during the critical development stages of a detached house. Therefore, this research aims to develop a guideline to improve owner participation for a successful detached house development in Malaysia. To achieve the aim, questionnaire surveys and semi-structured interviews were employed to collect the detached house owners' and consultants' & contractors' responses through their experiences in developing detached houses in Malaysia. Stratified and random sampling were utilised to gather information from both parties to represent Malaysian detached house participants. The questionnaire responses were analysed through the application of quantitative analysis such as descriptive analysis, factor analysis and structural equation modelling which were substantiated through qualitative analysis procedure such as content analysis. This research had identified that in order to produce a successful outcome detached house owners are required to participate during critical stages of the development. In the planning stage, the owner needs to provide proper specific input to the consultant regarding his/her expectations of the cost for the entire development, its detailed specification and general idea of the internal and external design of the detached house and its compound. In the contracting stage, the owner must make the appropriate choice of selecting the right contractor for the job. This decision may be taken after recommendations from the consultants or from the owner's personal contacts or experiences but it is not recommended for the owner to select a contractor primarily on the basis of the lowest bid. In the completion stage, the owner may need to attend a number of important site meetings to ensure that the progress of the works is according to what had been planned and the completion date is achievable. By having the owners undertake an active role during critical stages of the development, not only the quality and delivery of the development improved but also there is an increase in satisfaction to the owners themselves.

Does sustainable housing construction provide the home owner with a greater investment return?

Over the past 20 years there has been a considerable push at all three tiers of Government and private industry in Australia to improve the energy efficiency and sustainability levels of residential housing. A number of these initiatives have been voluntary, such as solar power and solar heating rebates, with other mandatory measures being incorporated into building standards and codes. Although the importance of energy efficiency and sustainable materials have been widely conveyed both at the academic and public level, it does not always reflect in the residential house purchase decision by typical house buyers, including residential property investors. This paper will analyse a range of housing markets in Brisbane to determine the investment performance of those markets over the past 3 years to determine any significant differences between new residential suburbs and older residential suburbs where houses have not been constructed to the current energy efficiency and sustainability guidelines. The range of suburbs to be analysed will focus on middle to lower high value suburbs, with a particular focus on residential housing in Master Planned Communities to determine if socio-economic factors and development size and scope have an impact of the purchase and investment performance of sustainable houses in comparison to older housing stock. The paper confirms that the residential property market shows a higher capital return for residential property built under stricter sustainability guidelines than similar located and type of property built prior to the BCA 2004 and older style project type homes erected prior to 2000.

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.