The case for unitary taxation with formulary apportionment in the finance sector and the effect on developing nations

In 2013 the OECD released its 15 point Action plan to deal with base erosion and profit shifting (BEPS). In that plan it was recognised that BEPS has a significant effect on developing countries. This is because the lack of tax revenue can lead to a critical underfunding of public investment that would help promote economic growth. To this end, the BEPS project is aimed at ensuring an inclusive approach to take into account not only views of the G20 and OECD countries but also the perspective of developing nations. With this focus in mind and in the context of developing nations, the purpose of this article is to consider a possible solution to profit shifting which occurs under the current transfer pricing regime, with that solution being unitary taxation with formulary apportionment. It does so using the finance sector as a specific case for application. Multinational financial institutions (MNFIs) play a significant role in financing activities of their clients in developing nations. Consistent with the ‘follow-the-client’ phenomenon which explains financial institution expansion, these entities are increasingly profiting from activities associated with this growing market. Further, not only are MNFIs persistent users of tax havens but also, more than other industries, have opportunities to reduce tax through transfer pricing measures. This article establishes a case for an industry specific adoption of unitary taxation with formulary apportionment as a viable alternative to the current regime. It argues that such a model would benefit not only developed nations but also developing nations which are currently suffering the effects of BEPS. In doing so, it considers the practicalities of such an implementation by examining both definitional issues and a possible formula for MNFIs. This article argues that, while there would be implementation difficulties to overcome, the current domestic models of formulary apportionment provide important guidance as to how the unitary business and business activities of MNFIs should be defined as well as factors that should be included in an allocation formula, along with the appropriate weighting. While it would be difficult for developing nations to adopt such a regime, it is argued that it would be no more difficult than addressing issues they face with the current transfer pricing regime. As such, this article concludes that unitary taxation with formulary apportionment is a viable industry specific alternative for MNFIs which would assist developing nations and aid independent fiscal soundness.

Developing green procurement framework for construction projects in Malaysia

With the current emerging development pattern in Malaysia, Malaysian government has enthusiastically promoted green procurement approach that will help the construction project being green. Previous studies highlighted that the concept of green procurement is still very new to the Malaysian construction industry, and this increases the needs for further research in this area. This paper addresses the needs of guidelines for stakeholders to procure environmentally-friendly construction. Currently, there is a limited practical guideline for stakeholders to procure green projects. This paper discusses the progress to date of a research project aimed at developing a green procurement framework for construction projects in the Malaysian construction industry. This framework will guide the stakeholders to plan the green procurement implementation to procure a construction projects. Through literature and expert opinion, this paper explores the list of green practices within procurement practices which becomes the basis to develop a survey instrument that will be used in the later part of this study. The paper will shed useful information for construction researchers and practitioners in exploring the green procurement concept for construction industry in Malaysia.

The design and implementation of an Information Accountability Framework for eHealth systems

This tutorial primarily focuses on the implementation of Information Accountability (IA) protocols defined in an Information Accountability Framework (IAF) in eHealth systems. Concerns over the security and privacy of patient information are one of the biggest hindrances to sharing health information and the wide adoption of eHealth systems. At present, there are competing requirements between healthcare consumers' (i.e. patients) requirements and healthcare professionals' (HCP) requirements. While consumers want control over their information, healthcare professionals want access to as much information as required in order to make well-informed decisions and provide quality care. This conflict is evident in the review of Australia's PCEHR system and in recent studies of patient control of access to their eHealth information. In order to balance these requirements, the use of an Information Accountability Framework devised for eHealth systems has been proposed. Through the use of IA protocols, so-called Accountable-eHealth systems (AeH) create an eHealth environment where health information is available to the right person at the right time without rigid barriers whilst empowering the consumers with information control and transparency. In this half-day tutorial, we will discuss and describe the technical challenges surrounding the implementation of the IAF protocols into existing eHealth systems and demonstrate their use. The functionality of the protocols and AeH systems will be demonstrated, and an example of the implementation of the IAF protocols into an existing eHealth system will be presented and discussed.

Critical risk factors affecting the implementation of PPP waste-to-energy projects in China

Since 2003, Mainland China has been promoting the public–private partnership (PPP) procurement model in the waste-to-energy incineration sector to reduce the waste burying rate and improve environmental quality. Five critical risk factors (CRFs) that affect the construction and operation of waste-to-energy incineration projects have been identified from real-life risk events of 14 PPP waste-to-energy incineration plants through content analysis. These risk factors are insufficient waste supply, disposal of non-licensed waste, environmental risk, payment risk, and lack of supporting infrastructure. A recently completed PPP waste-to-energy incineration plant, the Shanghai Tianma project, was investigated to learn from the effective management of CRFs. First-hand data about the Shanghai Tianma project was collected, with a focus on project negotiation and concession agreement. Lessons learned about risk management were acquired. This paper presents a detailed study of the contractual structure, risk sharing scheme, risk response measures to CRFs, and project transfer of a PPP project. The study results will provide governments with management implications to prepare equitable concession agreements and benefit private investors by effectively mitigating and managing risks in future PPP waste-to-energy incineration projects.

Implementation of a chest pain management service improves patient care and reduces length of stay

Objective Chest pain is one of the most common complaints in patients presenting to an emergency department. Delays in management due to a lack of readily available objective tests to risk stratify patients with possible acute coronary syndromes can lead to an unnecessarily lengthy admission placing pressure on hospital beds or inappropriate discharge. The need for a co-ordinated system of clinical management based on enhanced communication between departments, timely and appropriate triage, clinical investigation, diagnosis, and treatment was identified. Methods An evidence-based Chest Pain Management Service and clinical pathway were developed and implemented, including the introduction of after-hours exercise stress testing. Results Between November 2005 and March 2013, 5662 patients were managed according to a Chest Pain Management pathway resulting in a reduction of 5181 admission nights by more timely identification of patients at low risk who could then be discharged. In addition, 1360 days were avoided in high-risk patients who received earlier diagnosis and treatment. Conclusions The creation of a Chest Pain Management pathway and the extended exercise stress testing service resulted in earlier discharge for low-risk patients; and timely treatment for patients with positive and equivocal exercise stress test results. This service demonstrated a significant saving in overnight admissions.

The bias and assumptions in the Aboriginal and Torres Strait Islander Education Action Plan

This presentation argues that “genuine” engagement and consultation is required where Indigenous voice is included within the policy development process for “true” progress to be achieved. With the ever increasing engagement of Aboriginal and Torres Strait Islander people in the decision making processes of Indigenous education, it is anticipated that there will be provision of opportunities for better outcomes and a greater acceptance of the policy within community (Department of Prime Minister and Cabinet, 2014). This presentation is derived from a larger project where the Aboriginal and Torres Strait Islander Education Action Plan (MCEECDYA, 2011) was critically analysed using Fairclough’s (2001) Critical Discourse Analysis framework and Rigney’s (1999) Indigenist Research Principles. Within this study, the underlying assumptions and bias identified within the policy and how it positions Aboriginal and Torres Strait Islander people were articulated. The major findings that emerged from the data included: - a) the homogenous grouping of Aboriginal and Torres Strait Islander people; - b) the maintenance of the prevalent dominant ideology within policy, and finally; - c) the expectation by the power elite of increased engagement and connections by Aboriginal and Torres Strait Islander peoples without consideration of the detrimental effects of past policies and reforms.

A critical analysis of the Aboriginal and Torres Strait Islander Education Action Plan

This study involves the analysis of one of the most recent Indigenous Education policies, the Aboriginal and Torres Strait Islander Education Action Plan 2010-2014 (MCEECDYA, 2011). It examines how the language used within policy positions Aboriginal and Torres Strait Islander peoples. Articulating Rigney's (1999) Indigenist Research Principles with Fairclough's (2001) Critical Discourse Analysis provides a platform for critical dialogues about policy decision-making. In doing so, this articulation enables and emphasises the need for potential policy revision to contribute to the Aboriginal and Torres Strait Islander struggle for self-determination.

Managing the impacts of sugarcane farming on the Great Barrier Reef: An evaluation of the implementation of the Polluter Pays Principle

This report provides an evaluation of the implementation of the Polluter Pays Principle (PPP) – a principle of international environmental law – in the context of pollution from sugarcane farming affecting Australia’s Great Barrier Reef (GBR). The research was part of an experiment to test methods for evaluating the effectiveness of environmental laws. Overall, we found that whilst the PPP is reflected to a limited extent in Australian law (more so in Queensland law, than at the national level), the behaviour one might expect in terms of implementing the principle was largely inadequate. Evidence of a longer term, explicit commitment to the PPP was particularly weak.

Implementation mechanism: Protection against harassment of women at workplace

Pakistan is widely known and appreciated in the world for its history, Islamic culture and norms. Since the creation of Pakistan, it inherited poverty in its roots. There are many reasons for poverty but one lies on the shoulder of women who are 50% of the total population of Pakistan. On the apex of it, women do not take part in the development of Pakistan because when they step out of their homes, they suffer a lot of problems. These problems are a hurdle in their active participation in development .Government has tried to create an environment for those women, who suffer different problems. Harassment of women at work place is one of those problems which discourage women in taking active part in economic and social development of society. Women Activists, from the last decade, were working for the protection of woman’s right at workplace and they succeeded in formulation of Harassment Act 2010. Since law is ineffective without its proper mechanism of implementation, steps should be taken for its proper implementation mechanism. This article aims to provide information about the provisions of law, related to the harassment of women at workplace with an attempt to explore the effectiveness of its implementation. The study was conducted in twin cities of Pakistan, Islamabad and Rawalpindi. Interviews were conducted with the employees and employers of organizations, educational institutions, women activists, NGOs workers, lawyers, judges and some law enforcement officers. Group discussions were also held with teachers, students of Human rights and religious personalities. This report focuses on the implementation mechanism of new legislation in Pakistan. It also highlights some important facts related to its enforcement.

Implementation of Art1 and Art2 Artificial Neural Networks on Ring and Mesh Architectures

The Artificial Neural Networks (ANNs) are being used to solve a variety of problems in pattern recognition, robotic control, VLSI CAD and other areas. In most of these applications, a speedy response from the ANNs is imperative. However, ANNs comprise a large number of artificial neurons, and a massive interconnection network among them. Hence, implementation of these ANNs involves execution of computer-intensive operations. The usage of multiprocessor systems therefore becomes necessary. In this article, we have presented the implementation of ART1 and ART2 ANNs on ring and mesh architectures. The overall system design and implementation aspects are presented. The performance of the algorithm on ring, 2-dimensional mesh and n-dimensional mesh topologies is presented. The parallel algorithm presented for implementation of ART1 is not specific to any particular architecture. The parallel algorithm for ARTE is more suitable for a ring architecture.

Automated topometric graph generation from floor plan analysis

The world is rich with information such as signage and maps to assist humans to navigate. We present a method to extract topological spatial information from a generic bitmap floor plan and build a topometric graph that can be used by a mobile robot for tasks such as path planning and guided exploration. The algorithm first detects and extracts text in an image of the floor plan. Using the locations of the extracted text, flood fill is used to find the rooms and hallways. Doors are found by matching SURF features and these form the connections between rooms, which are the edges of the topological graph. Our system is able to automatically detect doors and differentiate between hallways and rooms, which is important for effective navigation. We show that our method can extract a topometric graph from a floor plan and is robust against ambiguous cases most commonly seen in floor plans including elevators and stairwells.

Fast matrix transposition computer implementation

Eklundh's (1972) algorithm to transpose a large matrix stored on an external device such as a disc has been programmed and tested. A simple description of computer implementation is given in this note.

An account and analysis of the implementation of various ebook business models at QUT, Australia

QUT (Queensland University of Technology) is a leading university based in the city of Brisbane, Queensland, Australia and is a selectively research intensive university with 2,500 higher degree research students and an overall student population of 45,000 students. The transition from print to online resources is largely completed and the library now provides access to 450,000 print books, 1,000 print journals, 600,000 ebooks, 120,000 ejournals and 100,000 online videos. The ebook collection is now used three times as much as the print book collection. This paper focuses on QUT Library’s ebook strategy and the challenges of building and managing a rapidly growing collection of ebooks using a range of publishers, platforms, and business and financial models. The paper provides an account of QUT Library’s experiences in using Patron Driven Acquisition (PDA) using eBook Library (EBL); the strategic procurement of publisher and subject collections by lease and outright purchase models, the more recent transition to Evidence Based Selection (EBS) options provided by some publishers, and its piloting of etextbook models. The paper provides an in-depth analysis of each of these business models at QUT, focusing on access verses collection development, usage, cost per use, and value for money.