International transfer pricing : the Australian approach and lessons for Canada

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.

Gold coating of silica and zinc oxide nanoparticles by the surface reduction of gold(I) chloride

The possibility of a surface inner sphere electron transfer mechanism leading to the coating of gold via the surface reduction of gold(I) chloride on metal and semi-metal oxide nanoparticles was investigated. Silica and zinc oxide nanoparticles are known to have very different surface chemistry, potentially leading to a new class of gold coated nanoparticles. Monodisperse silica nanoparticles were synthesised by the well known Stöber protocol in conjunction with sonication. The nanoparticle size was regulated solely by varying the amount of ammonia solution added. The presence of surface hydroxyl groups was investigated by liquid proton NMR. The resultant nanoparticle size was directly measured by the use of TEM. The synthesised silica nanoparticles were dispersed in acetonitrile (MeCN) and added to a bis acetonitrile gold(I) co-ordination complex [Au(MeCN)2]+ in MeCN. The silica hydroxyl groups were deprotonated in the presence of MeCN generating a formal negative charge on the siloxy groups. This allowed the [Au(MeCN)2]+ complex to undergo ligand exchange with the silica nanoparticles, which formed a surface co-ordination complex with reduction to gold(0), that proceeded by a surface inner sphere electron transfer mechanism. The residual [Au(MeCN)2]+ complex was allowed to react with water, disproportionating into gold(0) and gold(III) respectively, with gold(0) being added to the reduced gold already bound on the silica surface. The so-formed metallic gold seed surface was found to be suitable for the conventional reduction of gold(III) to gold(0) by ascorbic acid. This process generated a thin and uniform gold coating on the silica nanoparticles. This process was modified to include uniformly gold coated composite zinc oxide nanoparticles (Au@ZnO NPs) using surface co-ordination chemistry. AuCl dissolved in acetonitrile (MeCN) supplied chloride ions which were adsorbed onto ZnO NPs. The co-ordinated gold(I) was reduced on the ZnO surface to gold(0) by the inner sphere electron transfer mechanism. Addition of water disproportionated the remaining gold(I) to gold(0) and gold(III). Gold(0) bonded to gold(0) on the NP surface with gold(III) was reduced to gold(0) by ascorbic acid (ASC), which completed the gold coating process. This gold coating process of Au@ZnO NPs was modified to incorporate iodide instead of chloride. ZnO NPs were synthesised by the use of sodium oxide, zinc iodide and potassium iodide in refluxing basic ethanol with iodide controlling the presence of chemisorbed oxygen. These ZnO NPs were treated by the addition of gold(I) chloride dissolved in acetonitrile leaving chloride anions co-ordinated on the ZnO NP surface. This allowed acetonitrile ligands in the added [Au(MeCN)2]+ complex to surface exchange with adsorbed chloride from the dissolved AuCl on the ZnO NP surface. Gold(I) was then reduced by the surface inner sphere electron transfer mechanism. The presence of the reduced gold on the ZnO NPs allowed adsorption of iodide to generate a uniform deposition of gold onto the ZnO NP surface without the use of additional reducing agents or heat.

Incipient neurovulnerability and neuroprotection in early psychosis : a proton spectroscopy study of the anterior hippocampus at 3Tesla

Programmed cell death (PCD) and progenitor cell generation (of glial and in some brain areas also neuronal fate) in the CNS is an active process throughout life and is generally not associated with gliosis which means that PCD can be pathologically silent. The striking discovery that progenitor cell generation (of glial and in some brain areas neuronal fate) is widespread in the adult CNS (especially the hippocampus) suggest a much more dynamic scenario than previously thought and transcends the dichotomy between neurodevelopmental and neurodegenerative models of schizophrenia and related disorders. We suggest that the regulatory processes that control the regulation of PCD and the generation of progenitor cells may be disturbed in the early phase of psychotic disorders underpinning a disconnectivity syndrom at the onset of clinically overt disorders. An ongoing 1H-MRS study of the anterior hippocampus at 3 Tesla in mostly drug-naive first-episode psychosis patients suggests no change in NAA, but significant increases in myo-inositol and lactate. The data suggests that neuronal integrity in the anterior hippocampus is still intact at the early stage of illness or mainly only functionally impaired. However the increase in lactate and myo-inositol may reflect a potential disturbance of generation and PCD of progenitor cells (of glial and in selected brain areas also neuronal fate) at the onset of psychosis. If true the use of neuroprotective agents such as lithium or eicosapentaenoic acid (which inhibit PCD and support cell generation)in the early phase of psychotic disorders may be a potent treatment avenue to explore.

Social ties as key knowledge transfer agents between Indonesian and Australian universities : Perspectives from an Indonesian university

As two neighbouring countries, the number of transnational programs between Indonesian and Australian universities is significant. However, little is known about how transnational programs can facilitate knowledge transfer between the partner universities, which is often assumed by the Indonesian universities. Based on a case study regarding a dual degree program between an Indonesian and an Australian university, this paper outlines preliminary findings concerning the role of social ties between the staff of the two partner universities in creating positive inter-university dynamics that is vital for successful knowledge transfer. Using an inter-organisational knowledge transfer theoretical framework, social ties between the staff of the two universities are viewed as an important agent in facilitating knowledge transfer by building trust between the partners, moderating the perception about risk in the partnership, and creating a more equal power relation between the universities. Based on this study, Australian lecturers of Indonesian background and Indonesian lecturers who are alumni of Australian universities are important to initially establish these social ties. While face-to-face contact is still perceived as the ideal means of transferring knowledge and building trust among the Indonesian university staff, those who have stronger social ties with their Australian counterparts tend to use ICT-based communication to acquire knowledge from the Australian university compared to those who have more limited social ties with their Australian counterparts. This paper concludes with some implications for building positive social ties between Indonesian and Australian university staff to strengthen the knowledge transfer process.

The acquisition of an artificial logographic script and bilingual working memory : Evidence for L1-specific orthographic processing skills transfer in Chinese-English bilinguals

Studies of orthographic skills transfer between languages focus mostly on working memory (WM) ability in alphabetic first language (L1) speakers when learning another, often alphabetically congruent, language. We report two studies that, instead, explored the transferability of L1 orthographic processing skills in WM in logographic-L1 and alphabetic-L1 speakers. English-French bilingual and English monolingual (alphabetic-L1) speakers, and Chinese-English (logographic-L1) speakers, learned a set of artificial logographs and associated meanings (Study 1). The logographs were used in WM tasks with and without concurrent articulatory or visuo-spatial suppression. The logographic-L1 bilinguals were markedly less affected by articulatory suppression than alphabetic-L1 monolinguals (who did not differ from their bilingual peers). Bilinguals overall were less affected by spatial interference, reflecting superior phonological processing skills or, conceivably, greater executive control. A comparison of span sizes for meaningful and meaningless logographs (Study 2) replicated these findings. However, the logographic-L1 bilinguals’ spans in L1 were measurably greater than those of their alphabetic-L1 (bilingual and monolingual) peers; a finding unaccounted for by faster articulation rates or differences in general intelligence. The overall pattern of results suggests an advantage (possibly perceptual) for logographic-L1 speakers, over and above the bilingual advantage also seen elsewhere in third language (L3) acquisition.

Mass transfer properties (permeability and mass diffusivity) of four australian hardwood species

Characterization of mass transfer properties was achieved in the longitudinal, radial, and tangential directions for four Australian hardwood species: spotted gum, blackbutt, jarrah, and messmate. Measurement of mass transfer properties for these species was necessary to complement current vacuum drying modeling research. Water-vapour diffusivity was determined in steady state using a specific vapometer. Permeability was determined using a specialized device developed to measure over a wide range of permeability values. Permeability values of some species and material directions were extremely low and undetectable by the mass flow meter device. Hence, a custom system based on volume evolution was conceived to determine very low, previously unpublished, wood permeability values. Mass diffusivity and permeability were lowest for spotted gum and highest for messmate. Except for messmate in the radial direction, the four species measured were less permeable in all directions than the lowest published figures, demonstrating the high impermeability of Australian hardwoods and partly accounting for their relatively slow drying rates. Permeability, water-vapour diffusivity, and associated anisotropic ratio data obtained for messmate were extreme or did not follow typical trends and is consequently the most difficult of the four woods to dry in terms of collapse and checking degradation. © The State of Queensland, Department of Agriculture, Fisheries and Forestry, 2012.

Airborne concentration of Volatile Organic Compounds in school environment in Brisbane

Traffic emissions are considered as a major source of pollutants, particularly ultrafine particles, in the urban environment. There is an increased concern about airborne particles not only because of their environmental effects but also due to their potential adverse health effects on humans. There have been a number of studies related to the number concentration and size distribution of these particles but studies on the chemical composition of aerosols, especially in the school environment, are very limited. Mejia et. al (2011) reviewed studies on the exposure to and impact of air pollutants on school children and found that there were only a handful of studies on this topic. Therefore, the main focus of this research is on an analysis of the chemical composition of airborne particles, as well as source apportionment and the quantification of ambient concentrations of organic pollutants in the vicinity of schools, as a part of “Ultrafine Particles from Traffic Emissions on Children’s Health” (UPTECH) project. The aim of the present study was to find out the concentrations of different Volatile Organic Compounds (VOCs) in both outdoor and indoor locations from six different schools in Brisbane.

Investigating knowledge transfer through transnational programs between Indonesian and Australian universities : A conceptual framework

Globalization stimulated demand for transnational higher education. However, little is known about how transnational programs can facilitate knowledge transfer between the partner universities—something that is often implied in the partnership arrangement. For the purpose of this paper transnational programs will be limited to dual degree programs between Indonesian and Australian universities, which, in recent years have been rising. Nevertheless, the discussion and synthesis may have value to other transnational programs. Situating the knowledge transfer in the wider context of globalization of higher education and the current reforms in Indonesian education, the paper acknowledges the tension between the need to generate revenue and the ideals of facilitating knowledge transfer and capacity development for Indonesian universities. Drawing on a detailed review of research findings in the business and education sector literature, this paper presents a conceptual framework that may be used to analyze knowledge transfer between Indonesian and Australian universities. Such investigations delineate the significant drivers underlying transnational programs for supporting knowledge transfer. The proposed framework incorporates the types of knowledge, knowledge transfer mechanisms, and the processes. It also considers how the inter-university antecedents may affect the potential for knowledge transfer between the universities. A discussion of how the framework may be used to implemented knowledge transfer concludes this paper.

Modeling heat and mass transfer process during convection drying of fruit

Fruit drying is a process of removing moisture to preserve fruits by preventing microbial spoilage. It increases shelf life, reduce weight and volume thus minimize packing, storage, and transportation cost and enable storage of food under ambient environment. But, it is a complex process which involves combination of heat and mass transfer and physical property change and shrinkage of the material. In this background, the aim of this paper to develop a mathematical model to simulate coupled heat and mass transfer during convective drying of fruit. This model can be used predict the temperature and moisture distribution inside the fruits during drying. Two models were developed considering shrinkage dependent and temperature dependent moisture diffusivity and the results were compared. The governing equations of heat and mass transfer are solved and a parametric study has been done with Comsol Multiphysics 4.3. The predicted results were validated with experimental data.