The traditional rationale of the arm’s length approach to transfer pricing : should the separate accounting model be maintained for modern multinational entities?

This article examines the current transfer pricing regime to consider whether it is a sound model to be applied to modern multinational entities. The arm's length price methodology is examined to enable a discussion of the arguments in favour of such a regime. The article then refutes these arguments concluding that, contrary to the very reason multinational entities exist, applying arm's length rules involves a legal fiction of imagining transactions between unrelated parties. Multinational entities exist to operate in a way that independent entities would not, which the arm's length rules fail to take into account. As such, there is clearly an air of artificiality in applying the arm's length standard. To demonstrate this artificiality with respect to modern multinational entities, multinational banks are used as an example. The article concluded that the separate entity paradigm adopted by the traditional transfer pricing regime is incongruous with the economic theory of modern multinational enterprises.

Gas sensing characteristics of Fe-doped tungsten oxide thin films

This study reports on the gas sensing characteristics of Fe-doped (10 at.%) tungsten oxide thin films of various thicknesses (100–500 nm) prepared by electron beam evaporation. The performance of these films in sensing four gases (H2, NH3, NO2 and N2O) in the concentration range 2–10,000 ppm at operating temperatures of 150–280 °C has been investigated. The results are compared with the sensing performance of a pure WO3 film of thickness 300 nm produced by the same method. Doping of the tungsten oxide film with 10 at.% Fe significantly increases the base conductance of the pure film but decreases the gas sensing response. The maximum response measured in this experiment, represented by the relative change in resistance when exposed to a gas, was ΔR/R = 375. This was the response amplitude measured in the presence of 5 ppm NO2 at an operating temperature of 250 °C using a 400 nm thick WO3:Fe film. This value is slightly lower than the corresponding result obtained using the pure WO3 film (ΔR/R = 450). However it was noted that the WO3:Fe sensor is highly selective to NO2, exhibiting a much higher response to NO2 compared to the other gases. The high performance of the sensors to NO2 was attributed to the small grain size and high porosity of the films, which was obtained through e-beam evaporation and post-deposition heat treatment of the films at 300 °C for 1 h in air.

Effect of magnesium depletion and potassium and chlorothiazide on intracellular pH in the rat, studied by 31P NMR

1. Both dietary magnesium depletion and potassium depletion (confirmed by tissue analysis) were induced in rats which were then compared with rats treated with chlorothiazide (250 mg/kg diet) and rats on a control synthetic diet. 2. Brain and muscle intracellular pH was measured by using a surface coil and [31P]-NMR to measure the chemical shift of inorganic phosphate. pH was also measured in isolated perfused hearts from control and magnesium-deficient rats. Intracellular magnesium status was assessed by measuring the chemical shift of β-ATP in brain. 3. There was no evidence for magnesium deficiency in the chlorothiazide-treated rats on tissue analysis or on chemical shift of β-ATP in brain. Both magnesium and potassium deficiency, but not chlorothiazide treatment, were associated with an extracellular alkalosis. 4. Magnesium deficiency led to an intracellular alkalosis in brain, muscle and heart. Chlorothiazide treatment led to an alkalosis in brain. Potassium deficiency was associated with a normal intracellular pH in brain and muscle. 5. Magnesium depletion and chlorothiazide treatment produce intracellular alkalosis by unknown mechanism(s).

Visual route recognition with a handful of bits

In this paper we use a sequence-based visual localization algorithm to reveal surprising answers to the question, how much visual information is actually needed to conduct effective navigation? The algorithm actively searches for the best local image matches within a sliding window of short route segments or 'sub-routes', and matches sub-routes by searching for coherent sequences of local image matches. In contract to many existing techniques, the technique requires no pre-training or camera parameter calibration. We compare the algorithm's performance to the state-of-the-art FAB-MAP 2.0 algorithm on a 70 km benchmark dataset. Performance matches or exceeds the state of the art feature-based localization technique using images as small as 4 pixels, fields of view reduced by a factor of 250, and pixel bit depths reduced to 2 bits. We present further results demonstrating the system localizing in an office environment with near 100% precision using two 7 bit Lego light sensors, as well as using 16 and 32 pixel images from a motorbike race and a mountain rally car stage. By demonstrating how little image information is required to achieve localization along a route, we hope to stimulate future 'low fidelity' approaches to visual navigation that complement probabilistic feature-based techniques.

Non-combinatorial library screening reveals subsite cooperativity and identifies new high-efficiency substrates for kallikrein-related peptidase 14

An array of substrates link the tryptic serine protease, kallikrein-related peptidase 14 (KLK14), to physiological functions including desquamation and activation of signaling molecules associated with inflammation and cancer. Recognition of protease cleavage sequences is driven by complementarity between exposed substrate motifs and the physicochemical signature of an enzyme's active site cleft. However, conventional substrate screening methods have generated conflicting subsite profiles for KLK14. This study utilizes a recently developed screening technique, the sparse matrix library, to identify five novel high-efficiency sequences for KLK14. The optimal sequence, YASR, was cleaved with higher efficiency (k(cat)/K(m)=3.81 ± 0.4 × 10(6) M(-1) s(-1)) than favored substrates from positional scanning and phage display by 2- and 10-fold, respectively. Binding site cooperativity was prominent among preferred sequences, which enabled optimal interaction at all subsites as indicated by predictive modeling of KLK14/substrate complexes. These simulations constitute the first molecular dynamics analysis of KLK14 and offer a structural rationale for the divergent subsite preferences evident between KLK14 and closely related KLKs, KLK4 and KLK5. Collectively, these findings highlight the importance of binding site cooperativity in protease substrate recognition, which has implications for discovery of optimal substrates and engineering highly effective protease inhibitors.

Tephrochronology of marine sediments around the Island of Montserrat, Lesser Antilles volcanic arc

The recent history of the Soufrière Hills Volcano, Montserrat, Lesser Antilles volcanic arc, is reconstructed using data obtained from recently drilled submarine cores.Tephra layers in these cores preserve a record of the volcanic history of Montserrat back to ~250 ka on the basis of micropaleontology and stable isotope stratigraphy. Stratigraphic relationships identified in the cores collected in 2002 and 2005 document the fate of both pyroclastic flows entering the ocean to the east of Montserrat and carbonate-rich turbidites sourced from the carbonate platformssurrounding the islands of the Lesser Antilles. Using oxygen isotope stratigraphy, micropalaeontological analysis and Carbon-14 dating, it can be shown that three significant volcanic events, including the on-going eruption, have occurred over the last 12 ka. Preceding this was a time of volcanic quiescence, with three carbonate-rich turbidite events being documented in many of the cores. Our data suggest that these events occurred during Marine Isotope Stage 2, following the Last Glacial Maximum (LGM) and onset of post-glacial sea level rise.

Risk management and injury prevention : competencies, behaviours, and attitudes to safety in the construction industry

Work in the Australian construction industry is fraught with risk and the potential for serious harm. The industry is consistently placed within the three most hazardous industries to work along with other industries such as mining and transport (National Occupational Health and Safety Commission, 2003). In the 2001 to 2002 period, construction work killed 39 people and injured 13,250 more. Hence, more effort is required to reduce the injury rate and maximise the value of the rehabilitation/back-to-work process.

Comparative study on adsorption of two cationic dyes by milled sugarcane bagasse

Adsorptions of Rhodamine B (RhB) and Basic Blue 9 (BB9, also known as methylene blue) by sugarcane bagasse of different surface areas were compared in this study. There was a small gain in the amount of dye removed by increasing bagasse surface area from 0.57 m2/g to 1.81 m2/g. BB9 adsorption was less sensitive to surface area change than RhB adsorption. Adsorption capacity of 250 mg/L RhB on 1 g/L bagasse was 65.5 mg/g compared to a value of 30.7 mg/g obtained with BB9 under the same conditions. Increasing adsorption temperature (from 30 °C to 50 °C) while having no effect on RhB adsorption, slightly decreased BB9 adsorption by ~4%. The differences in adsorption performances between these dyes have been related to the molecular structure of the dyes and the surface chemistry of bagasse.

Impact of the introduction of machine gaming in Queensland on minor and major bingo

Material for this paper comes from as report commissioned by the Department of Family Services, Aboriginal and Islander Affairs. The report is the result of a multi strategy research project designed to assess the impact of gaming machines on the fundraising capacity of charitable and community organisations in Queensland. The study was conducted during the 1993 calendar year. The first Queensland gaming machine was commissioned on the 11 February, 1992 at 11.30 am in Brisbane at the Kedron Wavell Services Club. Eighteen more clubs followed that week. Six months later there were gaming machines in 335 clubs, and 250 hotels and taverns, representing a state wide total of 7,974 machines in operation. The 10,000 gaming machine was commissioned on the 18 March, 1993 and the 1,000 operational gaming machine site was opened on 18th February, 1994.

Environmental and economic evaluation of N fertilizer rates in a maize crop in Italy : a spatial and temporal analysis using crop models

Crop simulation models have the potential to assess the risk associated with the selection of a specific N fertilizer rate, by integrating the effects of soil-crop interactions on crop growth under different pedo-climatic and management conditions. The objective of this study was to simulate the environmental and economic impact (nitrate leaching and N2O emissions) of a spatially variable N fertilizer application in an irrigated maize field in Italy. The validated SALUS model was run with 5 nitrogen rates scenarios, 50, 100, 150, 200, and 250 kg N ha−1, with the latter being the N fertilization adopted by the farmer. The long-term (25 years) simulations were performed on two previously identified spatially and temporally stable zones, a high yielding and low yielding zone. The simulation results showed that N fertilizer rate can be reduced without affecting yield and net return. The marginal net return was on average higher for the high yield zone, with values ranging from 1550 to 2650 € ha−1 for the 200 N and 1485 to 2875 € ha−1 for the 250 N. N leaching varied between 16.4 and 19.3 kg N ha−1 for the 200 N and the 250 N in the high yield zone. In the low yield zone, the 250 N had a significantly higher N leaching. N2O emissions varied between 0.28 kg N2O ha−1 for the 50 kg N ha−1 rate to a maximum of 1.41 kg N2O ha−1 for the 250 kg N ha−1 rate.

Physical access control administration using building information models

Physical access control systems play a central role in the protection of critical infrastructures, where both the provision of timely access and preserving the security of sensitive areas are paramount. In this paper we discuss the shortcomings of existing approaches to the administration of physical access control in complex environments. At the heart of the problem is the current dependency on human administrators to reason about the implications of the provision or the revocation of staff access to an area within these facilities. We demonstrate how utilising Building Information Models (BIMs) and the capabilities they provide, including 3D representation of a facility and path-finding can reduce possible intentional or accidental errors made by security administrators.

Cytokine responses to carbohydrate ingestion during recovery from exercise-induced muscle injury.

We investigated the effect of carbohydrate ingestion after maximal lengthening contractions of the knee extensors on circulating concentrations of myocellular proteins and cytokines, and cytokine mRNA expression in muscle. Using a cross-over design, 10 healthy males completed 5 sets of 10 lengthening (eccentric) contractions (unilateral leg press) at 120% 1 repetition-maximum. Subjects were randomized to consume a carbohydrate drink (15% weight per volume; 3 g/kg BM) for 3 h after exercise using one leg, or a placebo drink after exercise using the contralateral leg on another day. Blood samples (10 mL) were collected before exercise and after 0, 30, 60, 90, 120, 150, and 180 min of recovery. Muscle biopsies (vastus lateralis) were collected before exercise and after 3 h of recovery. Following carbohydrate ingestion, serum concentrations of glucose (30-90 min and at 150 min) and insulin (30-180 min) increased (P < 0.05) above pre-exercise values. Serum myoglobin concentration increased (similar to 250%; P < 0.05) after both trials. In contrast, serum cytokine concentrations were unchanged throughout recovery in both trials. Muscle mRNA expression for IL-8 (6.4-fold), MCP-1 (4.7-fold), and IL-6 (7.3-fold) increased substantially after carbohydrate ingestion. TNF-alpha mRNA expression did not change after either trial. Carbohydrate ingestion during early recovery from exercise-induced muscle injury may promote proinflammatory reactions within skeletal muscle.