A nation’s role in addressing base erosion and profit shifting : balancing sovereignty with international collaboration and coordination

The notion of sovereignty is central to any international tax issue. While a nation is free to design its tax laws as it sees fit and raise revenue in accordance with the needs of its citizens, it is not possible to undertake such a task in isolation. In a world of cross-border investments and business transactions, all tax regimes impact on one another. Tax interactions between sovereign states cannot be avoided. Ultimately, the interactions mean that a nation must decide whether to engage in both collaboration and coordination with other nations and supranational bodies alike or maintain an individualised stance in relation to its tax policy. Whatever the decision, there is arguably an exercise in national sovereignty in some form. In the context of an international tax regime, whether that regime is interpreted broadly as meaning international norms generally adopted by nations around the world or domestic regimes legislating for cross-border transactions, rhetoric around national fiscal sovereignty takes on many different forms. At one end of the spectrum it is relied upon by financial secrecy jurisdictions (tax havens) as a defence to their position on the basis that ‘other’ nations cannot interfere with the fiscal sovereignty of a jurisdiction. At the other end of the spectrum, it is argued that profit shifting and international tax avoidance if not stopped is, in and of itself, a threat to a nation’s fiscal sovereignty on the basis that it threatens the ability to tax and raise the revenue needed. This paper considers a modern conceptualisation of sovereignty along with its role within international tax coordination and collaboration to argue that a move towards a more unified approach to addressing international base erosion and profit shifting may be the ultimate exercise of national fiscal sovereignty. By using the current transfer pricing regime as a case study, this paper posits that it is not merely enough to have international agreement on allocation rules to be applied, but that the ultimate exercise of national sovereignty is political agreement with other states to ensure that it is governments which determine the allocational basis of worldwide profits to be taxed. In doing so, it is demonstrated that the arm’s length pricing requirement of the current transfer pricing regime, rather than providing governments with the ability to determine the location of profits, is providing multinational entities with the ultimate power to determine that location. If left unchecked, this will eventually erode a nation’s ability to capture the required tax revenue and, as a consequence, may be deemed a failure by nation states to exercise their fiscal sovereignty.

Small acts of resistance : the role of intergenerational collaborative drawing in early childhood teaching and learning

This chapter focuses on ‘intergenerational collaborative drawing’, a particular process of drawing whereby adults and children draw at the same time on a blank paper space. Such drawings can be produced for a range of purposes, and based on different curriculum or stimulus subjects. Children of all ages, and with a range of physical and intellectual abilities are able to draw with parents, carers and teachers. Intergenerational collaborative drawing is a highly potent method for drawing in early childhood contexts because it brings adults and children together in the process of thinking and theorizing in order to create visual imagery and this exposes in deep ways to adults and children, the ideas and concepts being learned about. For adults, this exposure to a child’s thinking is a far more effective assessment tool than when they are presented with a finished drawing they know little about. This chapter focuses on drawings to examine wider issues of learning independence and how in drawing, preferred schema in the form of hand-out worksheets, the suggestive drawings provided by adults, and visual material seen in everyday life all serve to co-opt a young child into making particular schematic choices. I suggest that intergenerational collaborative drawing therefore serves to work as a small act of resistance to that co-opting, in that it helps adults and children to collectively challenge popular creativity and learning discourses.

Strategic capability development : a multi-level case study of the role of knowledge integration within product innovation

Capability development is at the heart of creating competitive advantage. This thesis intends to conceptualise Strategic Capability Development as a renewal of an organisation's existing capability in line with the requirements of the market. It followed and compared four product innovation projects within Iran Khodro Company (IKCO), an exemplar of capability development within the Iranian Auto industry. Findings show that the maturation of strategic capability at the organisational level has occurred through a sequence of product innovation projects and by dynamically shaping the learning and knowledge integration processes in accordance with emergence of the new structure within the industry. Accordingly, Strategic Capability Development is conceptualised in an interpretive model. Such findings are useful for development of an explanatory model and a practical capability development framework for managing learning and knowledge across different product innovation projects.

Mapping Australian journalism culture : results from a survey of journalists’ role perceptions

Research on journalists’ characteristics, values, attitudes and role perceptions has expanded manifold since the first large-scale survey in the United States in the 1970s. Scholars around the world have investigated the work practices of a large variety of journalists, to the extent that we now have a sizeable body of evidence in this regard. Comparative research across cultures, however, has only recently begun to gain ground, with scholars interested in concepts of journalism culture in an age of globalisation. As part of a wider, cross-cultural effort, this study reports the results of a survey of 100 Australian journalists in order to paint a picture of the way journalists see their role in society. Such a study is important due to the relative absence of large-scale surveys of Australian journalists since Henningham’s (1993) seminal work. This paper reports some important trends in the Australian news media since the early 1990s, with improvements in gender balance and journalists now being older, better educated, and holding more leftist political views. In locating Australian journalism culture within the study’s framework, some long-held assumptions are reinforced, with journalists following traditional values of objectivity, passive reporting and the ideal of the fourth estate.

Consultant engagement for computer system selection: a pro-active client role in small enterprises

Because of their limited number of senior positions and fewer alternative career paths, small businesses have a more difficult time attracting and retaining skilled information systems (IS) staff and are thus dependent upon external expertise. Small businesses are particularly dependent on outside expertise when first computerizing. Because small businesses suffer from severe financial constraints. it is often difficult to justify the cost of custom software. Hence. for many small businesses, engaging a consultant to help with identifying suitable packaged software and related hardware, is their first critical step toward computerization. This study explores the importance of proactive client involvement when engaging a consultant to assist with computer system selection in small businesses. Client involvement throughout consultant engagement is found to be integral to project success and frequently lacking due to misconceptions of small businesses regarding their role. Small businesses often overestimate the impact of consultant and vendor support in achieving successful computer system selection and implementation. For consultant engagement to be successful, the process must be viewed as being directed toward the achievement of specific organizational results where the client accepts responsibility for direction of the process.

The role of Non-Government Organisations (NGOS) in practising editorial photography in a globalised media environment

The news media industry has changed dramatically into a global business with ever-increasing attention being devoted to entertainment and celebrity across the last 10–20 years. There has also been a growing reliance on images produced by citizens (citizen photojournalism), by media outlets and publishers. It is widely acknowledged that in tandem these changes have shrunk publication opportunities for professional photographers undertaking editorial projects. As a result, photographers are increasingly relying on non-government organisations (NGOs) to gain access to photographing issues and events in developing countries and to expand their economic and portfolio opportunities. This increase in photographers working for and alongside NGOs has given rise to a new genre of editorial photography which I call NGO Reportage. By way of a case study, an exploration of this new genre reveals important issues for photographers working with NGOs and examines the constructed narratives of images contained within these emerging practices.

A nation's role in addressing base erosion and profit shifting : sovereignty in relation to transfer pricing

The notion of sovereignty is central to any international tax issue. While a nation is free to design its tax laws as it sees fit and raise revenue in accordance with the needs of its citizens, it is not possible to undertake such a task in isolation. Tax interactions between sovereign states cannot be avoided. Ultimately, the interactions mean that a nation must decide whether or engage in both collaboration and co ordination with other nations and supranational bodies alike or maintain a unilateral stance in relation to its tax policy. This article considers a modern conceptualisation of sovereignty to argue that a move towards a more unified approach to addressing international base erosion and profit sharing may be the ultimate exercise of national fiscal sovereignty.

Social tagging, guppy effect and the role of interference : a quantum-inspired model for tags combination

Social tagging systems are shown to evidence a well known cognitive heuristic, the guppy effect, which arises from the combination of different concepts. We present some empirical evidence of this effect, drawn from a popular social tagging Web service. The guppy effect is then described using a quantum inspired formalism that has been already successfully applied to model conjunction fallacy and probability judgement errors. Key to the formalism is the concept of interference, which is able to capture and quantify the strength of the guppy effect.

Making quality teachers : the role of an explicit values-based pedagogy

There is little conjecture that quality teaching is essential to student achievement and well-being. Whilst much has been written about the importance of quality teaching, including the link to pre-service teacher education, to date there has been little investigation into specific pedagogical practices that can enhance quality teaching dimensions within a pre-service teacher education programme. This paper reports on a small-scale qualitative research study, undertaken in an Australian university, which linked the fields of quality teaching, pre-service teacher education and values education. The study followed the journey of five pre-service teacher education students as they undertook their second field experience unit where the focus was centred on the values-based pedagogy of Philosophy in the Classroom. The research findings, collected via interviews, demonstrated that an explicit values-based pedagogy can have a positive impact on the development of quality teaching dimensions. This new knowledge has potential for further research into examining the ways quality teaching dimensions are gained and practised by pre-service teacher education students and these findings and recommendations are discussed in this paper.

Experiential role of artefacts in cooperative design

The role of material artefacts in supporting distributed and co-located work practices has been well acknowledged within HCI and CSCW research. In this paper, we show that in addition to their ecological, coordinative and organizational support, artefacts also play an 'experiential' role. In this case, artefacts not only improve efficiency or have a purely functional role (e.g. allowing people to complete tasks quickly), but the materiality, use and manifestations of these artefacts bring quality and richness to people's performance and help them make better sense of their everyday lives. In a domain such as industrial design, such artefacts play an important role for supporting creativity and innovation. Based on our ethnographic fieldwork on understanding cooperative design practices of industrial design students and researchers, we describe several experiential practices that are supported by design-related artefacts such as sketches, drawings, physical models and explorative prototypes -- used and developed in designers' everyday work. Our main intention in carrying out this kind of research is to develop technologies to support designers' everyday practices. We believe that with the emergence of ubiquitous computing, there is a growing need to focus on the personal, social and creative side of people's everyday experiences. By focusing on the experiential practices of designers, we can provide a much broader view in the design of new interactive technologies.

Structures of life : the role of molecular structures in scientists' work

The visual and multidimensional representations like images and graphical structures related to biology provide great insights into understanding the complexities of different organisms. Especially, life scientists use different representations of molecular structures to answer biological questions and to better understand cellular processes. Combining results from two field studies, we explore the role of molecular structures in life scientists’ current work from a humanfactors perspective. Our main conclusion is that different representations of molecular structures, due to their visual nature, are important for supporting collaboration, constructing new knowledge and supporting scientists’ professional activities in general.

Becoming a pharmacist : the role of curriculum in professional identity formation

Objective To understand how the formal curriculum experience of an Australian undergraduate pharmacy program supports students’ professional identity formation. Methods A qualitative ethnographic study was conducted over four weeks using participant observation and examined the ‘typical’ student experience from the perspective of a pharmacist. A one-week period of observation was undertaken with each of the four year groups (that is, for years one to four) comprising the undergraduate curriculum. Data were collected through observation of the formal curriculum experience using field notes, a reflective journal and informal interviews with 38 pharmacy students. Data were analyzed thematically using an a priori analytical framework. Results Our findings showed that the observed curriculum was a conventional curricular experience which focused on the provision of technical knowledge and provided some opportunities for practical engagement. There were some opportunities for students to imagine themselves as pharmacists, for example, when the lecture content related to practice or teaching staff described their approach to practice problems. However, there were limited opportunities for students to observe pharmacist role models, experiment with being a pharmacist or evaluate their professional identities. While curricular learning activities were available for students to develop as pharmacists e.g. patient counseling, there was no contact with patients and pharmacist academic staff tended to role model as educators with little evidence of their pharmacist selves. Conclusion These findings suggest that the current conventional approach to the curriculum design may not be fully enabling learning experiences which support students in successfully negotiating their professional identities. Instead it appeared to reinforce their identities as students with a naïve understanding of professional practice, making their future transition to professional practice challenging.

The role of parents and non-parents in the supervision of learner drivers in Australia

The purpose of this study was to contrast the role of parental and non-parental (sibling, other family and non-family) supervisors in the supervision of learner drivers in graduated driver licensing systems. The sample consisted of 522 supervisors from the Australian states of Queensland (n = 204, 39%) and New South Wales (n = 318, 61%). The learner licence requirements in these two states are similar, although learners in Queensland are required to accrue 100 h of supervision in a log book while those in New South Wales are required to accrue 120 h. Approximately 50 per cent of the sample (n = 255) were parents of the learner driver while the remainder of the sample were either siblings (n = 72, 13.8%), other family members (n = 153, 29.3%) or non-family (n = 114, 21.8%). Parents were more likely than siblings, other family or non-family members to be the primary supervisor of the learner driver. Siblings provided fewer hours of practice when compared with other supervisor types while the median and mode suggest that parents provided the most hours of practice to learner drivers. This study demonstrates that non-parental supervisors, such as siblings, other family members and non-family, at least in jurisdictions that require 100 or 120 h of practice, are important in facilitating learner drivers to accumulate sufficient supervised driving practice.

Quality Information System: Investigating the conception, role, models and suggesting conceptual and hierarchal models

In the current business world which companies’ competition is very compact in the business arena, quality in manufacturing and providing products and services can be considered as a means of seeking excellence and success of companies in this competition arena. Entering the era of e-commerce and emergence of new production systems and new organizational structures, traditional management and quality assurance systems have been challenged. Consequently, quality information system has been gained a special seat as one of the new tools of quality management. In this paper, quality information system has been studied with a review of the literature of the quality information system, and the role and position of quality Information System (QIS) among other information systems of a organization is investigated. The quality Information system models are analyzed and by analyzing and assessing presented models in quality information system a conceptual and hierarchical model of quality information system is suggested and studied. As a case study the hierarchical model of quality information system is developed by evaluating hierarchical models presented in the field of quality information system based on the Shetabkar Co.

An overview of the role of goethite surfaces in the environment

Goethite, one of the most thermodynamically stable iron oxides, has been extensively researched especially the structure (including surface structure), the adsorption capacity to anions, organic/organic acid (especially for the soil organic carbon) and cations in the natural environment and its potential application in environmental protection. For example, the adsorption of heavy metals by goethite can decrease the concentration of heavy metals in aqueous solution and immobilize; the adsorption to soil organic carbon can decrease the release of carbon and fix carbon. In this present overview, the possible physicochemical properties of the goethite surface contributing to the strong affinity of goethite to nutrients and contaminants in natural environment are reported. Moreover, these chemicals adsorbed by goethite were also summarized and the suggested adsorption mechanism for these adsorbates was elucidated, which will help us understand the role of goethite in natural environment and provide some information about goethite as an absorbent. In addition, the feasibility of goethite used as catalyst carrier and the precursor of NZVI was proposed for removal of environmental pollution.