Double tax agreements and the international allocation of business income in Australia

Increasingly, the effectiveness of the present system of taxation of international businesses is being questioned. The problem associated with the taxation of such businesses is twofold. A system of international taxation must be a fair and equitable system, distributing profits between the relevant jurisdictions and, in doing so, avoiding double taxation. At the same time, the prevention of fiscal evasion must be secured. In an attempt to achieve a fair and equitable system Australia adopts unilateral, bilateral and multilateral measures to avoid double taxation and restrict the avoidance of tax. The first step in ascertaining the international allocation of business income is to consider the taxation of business income according to domestic law, that is, the unilateral measures. The treatment of international business income under the Australian domestic law, that is, the Income Tax Assessment Act 1936 (Cth) and Income Tax Assessment Act 1997 (Cth), will depend on two concepts, first, whether the taxpayer is a resident of Australia and secondly, whether the income is sourced in Australia. After the taxation of business profits has been determined according to domestic law it is necessary to consider the applicability of the bilateral measures, that is, the Double Tax Agreements (DTAs) to which Australia is a party, as the DTAs will override the domestic law where there is any conflict. Australia is a party to 40 DTAs with another seven presently being negotiated. The preamble to Australia's DTAs provides that the purpose of such agreements is 'to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income'. Both purposes, for different reasons, are equally important. It has been said that: The taxpayer hopes the treaty will prevent the double taxation of his income; the tax gatherer hopes the treaty will prevent fiscal evasion; and the politician just hopes. The first purpose, the avoidance of double taxation, is achieved through the provision of rules whereby the Contracting States agree to the classification of income and the allocation of that income to a particular State. In this sense DTAs do not allocate jurisdiction to tax but rather provide an arrangement whereby the States agree to restrict their substantive law. The restriction is either through the non-taxing of the income or via the provision of a tax credit.

Practical framework for measuring performance of international construction firms

The internationalization of construction companies has become of significant interest as the global construction market continues to be integrated into a more competitive and turbulent business environment. However, due to the complicated and multifaceted nature of international business and performance, there is as yet no consensus on how to evaluate the performance of international construction firms (ICFs). The purpose of this paper, therefore, is to develop a practical framework for measuring the performance of ICFs. Based on the balanced scorecard (BSC), a framework with detailed measures is developed, investigated, and tested using a three-step research design. In the first step, 27 measures under six dimensions (financial, market, customer, internal business processes, stakeholders, and learning and growth) are determined by literature review, interviews with academics, and seminar discussions. Subsequently, a questionnaire survey is conducted to investigate weights of these 27 performance measures. The questionnaire survey also supports the importance of measuring intangible aspects of international construction performance from the practitioner’s viewpoint. Additionally, a case study is described to test the framework’s robustness and usefulness. This is achieved by benchmarking the performance of a Chinese ICF with nine other counterparts worldwide. It is found that the framework provides an effective basis for benchmarking ICFs to effectively monitor their performance and support the development of strategies for improved competitiveness in the international arena. This paper is the first attempt to present a balanced and practically tested framework for evaluating the performance of ICFs. It contributes to the practice of performance measurement and related internationalization in the construction industry in general.

The Rise of the BASIC Group Within the International Climate Regime : The Challenge of Ensuring Equitable Mitigation Obligations

The chapter examines the current emission reduction obligations within the climate regime. It looks at the formation and rise of the BASIC negotiation group within the international climate COP negotiations and examines the role that BASIC nations are now playing shaping international mitigation policy.

Second international workshop on theory and applications of process visualization

The representation of business process models has been a continuing research topic for many years now. However, many process model representations have not developed beyond minimally interactive 2D icon-based representations of directed graphs and networks, with little or no annotation for information overlays. In addition, very few of these representations have undergone a thorough analysis or design process with reference to psychological theories on data and process visualization. This dearth of visualization research, we believe, has led to problems with BPM uptake in some organizations, as the representations can be difficult for stakeholders to understand, and thus remains an open research question for the BPM community. In addition, business analysts and process modeling experts themselves need visual representations that are able to assist with key BPM life cycle tasks in the process of generating optimal solutions. With the rise of desktop computers and commodity mobile devices capable of supporting rich interactive 3D environments, we believe that much of the research performed in computer human interaction, virtual reality, games and interactive entertainment have much potential in areas of BPM; to engage, provide insight, and to promote collaboration amongst analysts and stakeholders alike. We believe this is a timely topic, with research emerging in a number of places around the globe, relevant to this workshop. This is the second TAProViz workshop being run at BPM. The intention this year is to consolidate on the results of last year's successful workshop by further developing this important topic, identifying the key research topics of interest to the BPM visualization community.

Institutional specifics and unemployment insurance eligibility in Canada : how sensitive are employment duration effects?

The paper examines the influence of unemployment insurance on the duration of employment spells in Canada using the 1988–90 Labour Market Activity Survey. The primary focus of the paper is to evaluate whether estimated UI effects are sensitive to the degree to which institutional rules and regulations governing UI eligibility and entitlement are explicitly modelled. The key result of the paper is that it is indeed important to allow for institutional detail when estimating unemployment insurance effects. Estimates using simple proxies for eligibility indicate small, often insignificant UI effects. The size and significance of the effects rise as more realistic versions of the variables are adopted. The estimates using the eligibility variables incorporating the greatest level of institutional detail suggest that a jump in the hazard rate by a factor of 2.3 may not be an unreasonable estimate of the effect.

The employment effects of gender discrimination in Australia 1994-95

Interpreting the unexplained component of the gender wage gap as indicative of discrimination, the empirical literature to date has tended to ignore the potential impact wage discrimination may have on employment. Clearly, employment effects will arise if discrimination lowers the female offered wage and the labour supply curve is upward sloping. The empirical analysis employs the ABS Income Distribution Survey 1994–95 and finds evidence of both wage and associated employment effects. The analysis is replicated for the earlier period 1989–90. A comparison across time is of interest given the substantial deregulation of the Australian labour market over the period.

Are employment effects of gender discrimination important? Some evidence from Great Britain

Interpreting the unexplained component of the gender wage gap as indicative of discrimination, the empirical literature to date has tended to ignore the potential impact wage discrimination may have on employment. Employment effects may arise if discrimination lowers the female offered wage and the labour supply curve is upward sloping. The empirical analysis employs the British Household Panel Study and finds evidence of both wage and associated employment effects.

Integrating Intangible Cultural Heritage elements and learning strategy : a case study

Tanzania has a rich and diverse cultural history based on community cultural life. However, at present, young people have limited opportunity to exploit this richness of creative expressions and engage in creative jobs as their future career. Hence, the significant challenge remains: how to integrate Intangible cultural heritage elements and learning strategy as a means of promoting creative jobs for youth. This paper presents a case study on 'Strategies for youth employment in Tanzania: A creative industries approach'. The case study employed mixed methods incorporating questionnaires, interviews and focus groups and was held in Dar-Es-Salaam, Mwanza, Dodoma, Lindi and Morogoro from July to October, 2012. This paper discusses some of the issues and argues that there is no virtual utilization of the intangible cultural heritage knowledge and skills in 'putting education to work' (UNESCO, 2012) for the better prospects of youth. Although the discussion is specific to Tanzania, the case may also apply to other developing countries.

International corporate entrepreneurship among SMEs : a test of Stevenson's notion of entrepreneurial management

Geographical market expansion is included in various definitions of entrepreneurship as it entails the opening up of new markets (for example, Davidsson 2003). Expansion into new international markets and launch of new products in international markets are also consistent with definitions of entrepreneurship which center on the pursuit of opportunities {e.g.\Stevenson, 1983 #922;Gartner, 1993 #931}. Accordingly, the decision by managers of small, internationally active businesses to continue to internationalize can be viewed as an entrepreneurial act. In spite of the fact that both start-ups and existing firms can behave entrepreneurially by expanding into new international markets, the attention of entrepreneurship researchers interested in international activities has largely focused on international new ventures (INVs); that is, business organizations that internationalize from inception (Oviatt, and McDougall 1994; Oviatt, and McDougall 1997). Consequently, pursuit of international opportunities by established small and medium-sized enterprises (SMEs) lacks theoretical understanding and empirical investigation through an entrepreneurship lens. This paper contributes to the body of knowledge at the entrepreneurship-internationalization interface by testing whether Stevenson’s opportunity-based conceptualization of entrepreneurial management (Stevenson 1983; Stevenson and Gumpert 1985; Stevenson and Jarillo 1990) can explain the attainment of continued entrepreneurial outcomes by SMEs operating in foreign markets. We choose Stevenson’s conceptualization as it gauges firm-level characteristics that are theorized to facilitate the pursuit of entrepreneurial opportunities, which arguably is at the heart of SMEs’ continued venturing into international markets.

Entrepreneurial growth : the role of international knowledge acquisition as moderated by firm age

In line with repeated recent calls for research on specific forms of growth rather than on an undifferentiated notion of “total growth,” our study contributes to the understanding of entrepreneurial growth. By this we mean growth through expansion into new geographic markets and/or via the introduction of new products or services. Building on Penrose's theory of the growth of the firm and on the research streams she has in part inspired, we investigate the impact of knowledge acquisition from international markets on entrepreneurial growth both at home and abroad. We further suggest that the effects of international knowledge acquisition on entrepreneurial growth will vary with firm age. Utilizing longitudinal data on 138 small and medium-sized enterprises (SMEs), we find that the acquisition of knowledge from international markets fuels growth through market development, and that this effect is stronger for international expansion than domestic expansion. Our results also show that firm age negatively moderates the relationship between international knowledge acquisition and entrepreneurial growth via the introduction of new products or services. Specifically, international knowledge acquisition has a positive effect on growth via new products/services development in young firms, but a negative effect in mature firms. We assume this reflects changes over time in how international knowledge is managed.

Changing times, persistent paradigms : women and men at work in projects

The Australian economy is currently supported by a resources boom and work opportunities in traditionally male dominated fields of construction and engineering and information technology are at a premium. Yet despite more than 25 years of anti discrimination and equal employment opportunity legislation these industries still employ few women in operational or management roles. This paper investigates the issue of the low representation of women in project management and their different work and career experiences through interviews with male and female project managers.

International acclaim : the role(s) of the international film festival in supporting emerging women’s cinema

International Film Festivals act as important sites for the exhibition of contemporary world cinema. Film festivals represent an increasingly transnational film culture, where audiences, filmmakers, distributors, press, critics and academics come together from all over the world to discover new films, network with one another and debate about the past, present and future of cinema. This research project investigates the role that international film festivals play within the wider international film industry, with a specific focus on emerging women filmmakers. It therefore explores the arena of contemporary women.s cinema at its intersection with the international film festival industry. The significance and original contribution of the research is its intervention in the growing field of film festival studies through a specific investigation of how international film festivals support emerging women filmmakers. The positioning of the research at the intersection of feminist film theory and festival research within the broader context of transnational cinema allows the examination of each festival, the attending filmmakers and their films to be addressed within a more refined and nuanced lens. A core method for the thesis is the close textual analysis of particular emerging women filmmakers. films which are screened at the respective festivals. The research also utilises the qualitative research strategies of the case study and the interview to ¡°seek to understand the context or setting of the participants through visiting this context and gathering information personally¡± (Creswell 2003, 9). The textual analysis is used in dialogue with the interviews and the participant observational data gathering to provide a related context for understanding these films and their cultural meanings, both personally for the filmmaker and transnationally across the festival circuit. The focus of the case studies is the Brisbane International Film Festival, the International Film Festival Rotterdam and the Toronto International Film Festival. These three festivals were chosen for their distinct geographical locations in the Asia Pacific, Europe and North America, as well as for their varying size and influence on the international film festival circuit. Specifically, I investigate the reasons behind why the organisers of a particular festival have chosen a certain woman.s film, how it is then packaged or displayed within the programme, and how all of this impacts on the filmmaker herself. The focus of my research is to investigate film festivals and their .real-life. applications and benefits for the filmmakers being supported, both through the exhibition of their films and through their attendance as festival guests. The research finds that the current generation of emerging women filmmakers has varying levels of experience and success at negotiating the international film festival circuit. Each of the three festivals examined include and promote the films of emerging women filmmakers through a range of strategies, such as specific programming strands dedicated to showcasing emerging talent, financial support through festival funds, providing visibility within the programme, exposure to international audiences and networking opportunities with industry professionals and other filmmakers. Furthermore, the films produced by the emerging women filmmakers revealed a strong focus on women.s perspectives and experiences, which were explored through the interweaving of particular aesthetic and cinematographic conventions.