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.

Realizing benefits from enterprise architecture : a measurement model

Enterprise architecture (EA) management has become an intensively discussed approach to manage enterprise transformations. Despite the popularity and potential of EA, both researchers and practitioners lament a lack of knowledge about the realization of benefits from EA. To determine the benefits from EA, we explore the various dimensions of EA benefit realization and report on the development of a validated and robust measurement instrument. In this paper, we test the reliability and construct validity of the EA benefit realization model (EABRM), which we have designed based on the DeLone & McLean IS success model and findings from exploratory interviews. A confirmatory factor analysis confirms the existence of an impact of five distinct and individually important dimensions on the benefits derived from EA: EA artefact quality, EA infrastructure quality, EA service quality, EA culture, and EA use. The analysis presented in this paper shows that the EA benefit realization model is an instrument that demonstrates strong reliability and validity.

Semantic service discovery in the service ecosystem

Electronic services are a leitmotif in ‘hot’ topics like Software as a Service, Service Oriented Architecture (SOA), Service oriented Computing, Cloud Computing, application markets and smart devices. We propose to consider these in what has been termed the Service Ecosystem (SES). The SES encompasses all levels of electronic services and their interaction, with human consumption and initiation on its periphery in much the same way the ‘Web’ describes a plethora of technologies that eventuate to connect information and expose it to humans. Presently, the SES is heterogeneous, fragmented and confined to semi-closed systems. A key issue hampering the emergence of an integrated SES is Service Discovery (SD). A SES will be dynamic with areas of structured and unstructured information within which service providers and ‘lay’ human consumers interact; until now the two are disjointed, e.g., SOA-enabled organisations, industries and domains are choreographed by domain experts or ‘hard-wired’ to smart device application markets and web applications. In a SES, services are accessible, comparable and exchangeable to human consumers closing the gap to the providers. This requires a new SD with which humans can discover services transparently and effectively without special knowledge or training. We propose two modes of discovery, directed search following an agenda and explorative search, which speculatively expands knowledge of an area of interest by means of categories. Inspired by conceptual space theory from cognitive science, we propose to implement the modes of discovery using concepts to map a lay consumer’s service need to terminologically sophisticated descriptions of services. To this end, we reframe SD as an information retrieval task on the information attached to services, such as, descriptions, reviews, documentation and web sites - the Service Information Shadow. The Semantic Space model transforms the shadow's unstructured semantic information into a geometric, concept-like representation. We introduce an improved and extended Semantic Space including categorization calling it the Semantic Service Discovery model. We evaluate our model with a highly relevant, service related corpus simulating a Service Information Shadow including manually constructed complex service agendas, as well as manual groupings of services. We compare our model against state-of-the-art information retrieval systems and clustering algorithms. By means of an extensive series of empirical evaluations, we establish optimal parameter settings for the semantic space model. The evaluations demonstrate the model’s effectiveness for SD in terms of retrieval precision over state-of-the-art information retrieval models (directed search) and the meaningful, automatic categorization of service related information, which shows potential to form the basis of a useful, cognitively motivated map of the SES for exploratory search.

Ureaplasma parvum : understanding the complexities of intra-amniotic infection in an ovine model

The human Ureaplasma species are the most frequently isolated bacteria from the upper genital tract of pregnant women and can cause clinically asymptomatic, intra-uterine infections, which are difficult to treat with antimicrobials. Ureaplasma infection of the upper genital tract during pregnancy has been associated with numerous adverse outcomes including preterm birth, chorioamnionitis and neonatal respiratory diseases. The mechanisms by which ureaplasmas are able to chronically colonise the amniotic fluid and avoid eradication by (i) the host immune response and (ii) maternally-administered antimicrobials, remain virtually unexplored. To address this gap within the literature, this study investigated potential mechanisms by which ureaplasmas are able to cause chronic, intra-amniotic infections in an established ovine model. In this PhD program of research the effectiveness of standard, maternal erythromycin for the treatment of chronic, intra-amniotic ureaplasma infections was evaluated. At 55 days of gestation pregnant ewes received an intra-amniotic injection of either: a clinical Ureaplasma parvum serovar 3 isolate that was sensitive to macrolide antibiotics (n = 16); or 10B medium (n = 16). At 100 days of gestation, ewes were then randomised to receive either maternal erythromycin treatment (30 mg/kg/day for four days) or no treatment. Ureaplasmas were isolated from amniotic fluid, chorioamnion, umbilical cord and fetal lung specimens, which were collected at the time of preterm delivery of the fetus (125 days of gestation). Surprisingly, the numbers of ureaplasmas colonising the amniotic fluid and fetal tissues were not different between experimentally-infected animals that received erythromycin treatment or infected animals that did not receive treatment (p > 0.05), nor were there any differences in fetal inflammation and histological chorioamnionitis between these groups (p > 0.05). These data demonstrate the inability of maternal erythromycin to eradicate intra-uterine ureaplasma infections. Erythromycin was detected in the amniotic fluid of animals that received antimicrobial treatment (but not in those that did not receive treatment) by liquid chromatography-mass spectrometry; however, the concentrations were below therapeutic levels (<10 – 76 ng/mL). These findings indicate that the ineffectiveness of standard, maternal erythromycin treatment of intra-amniotic ureaplasma infections may be due to the poor placental transfer of this drug. Subsequently, the phenotypic and genotypic characteristics of ureaplasmas isolated from the amniotic fluid and chorioamnion of pregnant sheep after chronic, intra-amniotic infection and low-level exposure to erythromycin were investigated. At 55 days of gestation twelve pregnant ewes received an intra-amniotic injection of a clinical U. parvum serovar 3 isolate, which was sensitive to macrolide antibiotics. At 100 days of gestation, ewes received standard maternal erythromycin treatment (30 mg/kg/day for four days, n = 6) or saline (n = 6). Preterm fetuses were surgically delivered at 125 days of gestation and ureaplasmas were cultured from the amniotic fluid and the chorioamnion. The minimum inhibitory concentrations (MICs) of erythromycin, azithromycin and roxithromycin were determined for cultured ureaplasma isolates, and antimicrobial susceptibilities were different between ureaplasmas isolated from the amniotic fluid (MIC range = 0.08 – 1.0 mg/L) and chorioamnion (MIC range = 0.06 – 5.33 mg/L). However, the increased resistance to macrolide antibiotics observed in chorioamnion ureaplasma isolates occurred independently of exposure to erythromycin in vivo. Remarkably, domain V of the 23S ribosomal RNA gene (which is the target site of macrolide antimicrobials) of chorioamnion ureaplasmas demonstrated significant variability (125 polymorphisms out of 422 sequenced nucleotides, 29.6%) when compared to the amniotic fluid ureaplasma isolates and the inoculum strain. This sequence variability did not occur as a consequence of exposure to erythromycin, as the nucleotide substitutions were identical between chorioamnion ureaplasmas isolated from different animals, including those that did not receive erythromycin treatment. We propose that these mosaic-like 23S ribosomal RNA gene sequences may represent gene fragments transferred via horizontal gene transfer. The significant differences observed in (i) susceptibility to macrolide antimicrobials and (ii) 23S ribosomal RNA sequences of ureaplasmas isolated from the amniotic fluid and chorioamnion suggests that the anatomical site from which they were isolated may exert selective pressures that alter the socio-microbiological structure of the bacterial population, by selecting for genetic changes and altered antimicrobial susceptibility profiles. The final experiment for this PhD examined antigenic size variation of the multiple banded antigen (MBA, a surface-exposed lipoprotein and predicted ureaplasmal virulence factor) in chronic, intra-amniotic ureaplasma infections. Previously defined ‘virulent-derived’ and ‘avirulent-derived’ clonal U. parvum serovar 6 isolates (each expressing a single MBA protein) were injected into the amniotic fluid of pregnant ewes (n = 20) at 55 days of gestation, and amniotic fluid was collected by amniocentesis every two weeks until the time of near-term delivery of the fetus (at 140 days of gestation). Both the avirulent and virulent clonal ureaplasma strains generated MBA size variants (ranging in size from 32 – 170 kDa) within the amniotic fluid of pregnant ewes. The mean number of MBA size variants produced within the amniotic fluid was not different between the virulent (mean = 4.2 MBA variants) and avirulent (mean = 4.6 MBA variants) ureaplasma strains (p = 0.87). Intra-amniotic infection with the virulent strain was significantly associated with the presence of meconium-stained amniotic fluid (p = 0.01), which is an indicator of fetal distress in utero. However, the severity of histological chorioamnionitis was not different between the avirulent and virulent groups. We demonstrated that ureaplasmas were able to persist within the amniotic fluid of pregnant sheep for 85 days, despite the host mounting an innate and adaptive immune response. Pro-inflammatory cytokines (interleukin (IL)-1â, IL-6 and IL-8) were elevated within the chorioamnion tissue of pregnant sheep from both the avirulent and virulent treatment groups, and this was significantly associated with the production of anti-ureaplasma IgG antibodies within maternal sera (p < 0.05). These findings suggested that the inability of the host immune response to eradicate ureaplasmas from the amniotic cavity may be due to continual size variation of MBA surface-exposed epitopes. Taken together, these data confirm that ureaplasmas are able to cause long-term in utero infections in a sheep model, despite standard antimicrobial treatment and the development of a host immune response. The overall findings of this PhD project suggest that ureaplasmas are able to cause chronic, intra-amniotic infections due to (i) the limited placental transfer of erythromycin, which prevents the accumulation of therapeutic concentrations within the amniotic fluid; (ii) the ability of ureaplasmas to undergo rapid selection and genetic variation in vivo, resulting in ureaplasma isolates with variable MICs to macrolide antimicrobials colonising the amniotic fluid and chorioamnion; and (iii) antigenic size variation of the MBA, which may prevent eradication of ureaplasmas by the host immune response and account for differences in neonatal outcomes. The outcomes of this program of study have improved our understanding of the biology and pathogenesis of this highly adapted microorganism.

Middle school social sciences : exploring teachers’ conceptions of essential knowledge

This study examines teachers’ conceptions of essential knowledge in the humanities and social sciences, commonly referred to as "social education", in the middle years of schooling. Social education has long been a highly contested area of the curriculum in Australia. In Queensland, social education comprises the integrated learning area of Studies of Society and Environment (SOSE). However, the new Australian Curriculum marks a return to discipline-based study of history and geography. This phenomenographic study addresses a perceived lack of understanding in the current research literature in Australia of the nature of middle school teachers’ professional knowledge for teaching the social sciences. Teachers are conceptualised in this study as curriculum makers in the classroom and, as such, their conceptions of essential knowledge are significant. Shulman’s (1986, 1987) theory of teachers’ knowledge forms the theoretical foundation of the study, which is contextualised in Federal and State education policies and the literature on the middle phase of schooling. Transcripts of interviews conducted with a group of thirty-one Queensland middle school teachers of SOSE were subjected to phenomenographic analysis, revealing seven qualitatively different categories of description. Essential aspects of knowledge for social education emerging from the study were: (1) discipline-based knowledge; (2) curriculum knowledge; (3) knowledge derived from teaching experience; (4) knowledge of middle years learners; (5) knowledge of integration; (6) knowledge of current affairs; and (7) knowledge invested in teacher identity. The three dimensions of variation that linked and differentiated the categories were: (1) content; (2) inquiry learning; and (3) teacher autonomy. These findings are presented as an outcome space where the categories are grouped as knowledge of the learning area, knowledge of contexts and knowledge of self as teacher. The results of the study suggest that social education teachers’ identity and knowledge of self are critical aspects of their knowledge as curriculum makers. The results illustrate that the professional and personal domains intersect, extending Shulman’s (1986, 1987) original theorisation of teachers’ knowledge into the personal arena. Further, middle years teachers’ conceptions of essential knowledge reveal a practice-based theorisation of knowledge for social education that fits the goals of middle schooling. The research concludes that attention to teacher identity in teacher education and in-service professional development has considerable potential to grow teachers’ knowledge in the social sciences and enhance their capacity for school-based curriculum leadership.

A holistic blended design studio model : a basis for exploring and expanding learning opportunities

While the studio environment has been promoted as an ideal educational setting for project-based disciplines, few qualitative studies have been undertaken in a comprehensive way (Bose, 2007). This study responds to this need by adopting Grounded Theory methodology in a qualitative comparative approach. The research aims to explore the limitations and benefits of a face-to-face (f2f) design studio as well as a virtual design studio (VDS) as experienced by architecture students and educators at an Australian university in order to find the optimal combination for a blended environment to maximize learning. The main outcome is a holistic multidimensional blended model being sufficiently flexible to adapt to various setting, in the process, facilitating constructivist learning through self-determination, self-management, and personalization of the learning environment.

Thinking Critically About Rural Gender Relations: Toward a Rural Masculinity/Male Peer Support Model of Separation/Divorce Sexual Assault

After decades of neglect, a growing number of scholars have turned their attention to issues of crime and criminal justice in the rural context. Despite this improvement, rural crime research is underdeveloped theoretically, and is little informed by critical criminological perspectives. In this article, we introduce the broad tenets of a multi-level theory that links social and economic change to the reinforcement of rural patriarchy and male peer support, and in turn, how they are linked to separation/divorce sexual assault. We begin by addressing a series of misconceptions about what is rural, rural homogeneity and commonly held presumptions about the relationship of rurality, collective efficacy (and related concepts) and crime. We conclude by recommending more focused research, both qualitative and quantitative, to uncover specific link between the rural transformation and violence against women.

Heating effects in nanofocusing metal wedges

This paper investigates theoretically and numerically local heating effects in plasmon nanofocusing structures with a particular focus on the sharp free-standing metal wedges. The developed model separates plasmon propagation in the wedge from the resultant heating effects. Therefore, this model is only applicable where the temperature increments in a nanofocusing structure are sufficiently small not to result in significant variations of the metal permittivity in the wedge. The problem is reduced to a one-dimensional heating model with a distributed heat source resulting from plasmon dissipation in the metal wedge. A simple heat conduction equation governing the local heating effects in a nanofocusing structure is derived and solved numerically for plasmonic pulses of different lengths and reasonable energies. Both the possibility of achieving substantial local temperature increments in the wedge (with a significant self-influence of the heating plasmonic pulses), and the possibility of relatively weak heating (to ensure the validity of the previously developed nanofocusing theory) are demonstrated and discussed, including the future applications of the obtained results. Applicability conditions for the developed model are also derived and discussed.

Is the unigram relevance model term independent? Classifying term dependencies in query expansion

This paper develops a framework for classifying term dependencies in query expansion with respect to the role terms play in structural linguistic associations. The framework is used to classify and compare the query expansion terms produced by the unigram and positional relevance models. As the unigram relevance model does not explicitly model term dependencies in its estimation process it is often thought to ignore dependencies that exist between words in natural language. The framework presented in this paper is underpinned by two types of linguistic association, namely syntagmatic and paradigmatic associations. It was found that syntagmatic associations were a more prevalent form of linguistic association used in query expansion. Paradoxically, it was the unigram model that exhibited this association more than the positional relevance model. This surprising finding has two potential implications for information retrieval models: (1) if linguistic associations underpin query expansion, then a probabilistic term dependence assumption based on position is inadequate for capturing them; (2) the unigram relevance model captures more term dependency information than its underlying theoretical model suggests, so its normative position as a baseline that ignores term dependencies should perhaps be reviewed.

An interpretation of current progress towards an industry model for Queensland's surveying and mapping industry

A strongly progressive surveying and mapping industry depends on a shared understanding of the industry as it exists, some shared vision or imagination of what the industry might become, and some shared action plan capable of bringing about a realisation of that vision. The emphasis on sharing implies a need for consensus reached through widespread discussion and mutual understanding. Unless this occurs, concerted action is unlikely. A more likely outcome is that industry representatives will negate each other's efforts in their separate bids for progress. The process of bringing about consensual viewpoints is essentially one of establishing an industry identity. Establishing the industry's identity and purpose is a prerequisite for rational development of the industry's education and training, its promotion and marketing, and operational research that can deal .with industry potential and efficiency. This paper interprets evolutionary developments occurring within Queensland's surveying and mapping industry within a framework that sets out logical requirements for a viable industry.

Evaluating the success of large-scale, integrated information systems through the lens of IS-impact and IS-support

This study proceeds from a central interest in the importance of systematically evaluating operational large-scale integrated information systems (IS) in organisations. The study is conducted within the IS-Impact Research Track at Queensland University of Technology (QUT). The goal of the IS-Impact Track is, "to develop the most widely employed model for benchmarking information systems in organizations for the joint benefit of both research and practice" (Gable et al, 2009). The track espouses programmatic research having the principles of incrementalism, tenacity, holism and generalisability through replication and extension research strategies. Track efforts have yielded the bicameral IS-Impact measurement model; the ‘impact’ half includes Organisational-Impact and Individual-Impact dimensions; the ‘quality’ half includes System-Quality and Information-Quality dimensions. Akin to Gregor’s (2006) analytic theory, the ISImpact model is conceptualised as a formative, multidimensional index and is defined as "a measure at a point in time, of the stream of net benefits from the IS, to date and anticipated, as perceived by all key-user-groups" (Gable et al., 2008, p: 381). The study adopts the IS-Impact model (Gable, et al., 2008) as its core theory base. Prior work within the IS-Impact track has been consciously constrained to Financial IS for their homogeneity. This study adopts a context-extension strategy (Berthon et al., 2002) with the aim "to further validate and extend the IS-Impact measurement model in a new context - i.e. a different IS - Human Resources (HR)". The overarching research question is: "How can the impacts of large-scale integrated HR applications be effectively and efficiently benchmarked?" This managerial question (Cooper & Emory, 1995) decomposes into two more specific research questions – In the new HR context: (RQ1): "Is the IS-Impact model complete?" (RQ2): "Is the ISImpact model valid as a 1st-order formative, 2nd-order formative multidimensional construct?" The study adhered to the two-phase approach of Gable et al. (2008) to hypothesise and validate a measurement model. The initial ‘exploratory phase’ employed a zero base qualitative approach to re-instantiating the IS-Impact model in the HR context. The subsequent ‘confirmatory phase’ sought to validate the resultant hypothesised measurement model against newly gathered quantitative data. The unit of analysis for the study is the application, ‘ALESCO’, an integrated large-scale HR application implemented at Queensland University of Technology (QUT), a large Australian university (with approximately 40,000 students and 5000 staff). Target respondents of both study phases were ALESCO key-user-groups: strategic users, management users, operational users and technical users, who directly use ALESCO or its outputs. An open-ended, qualitative survey was employed in the exploratory phase, with the objective of exploring the completeness and applicability of the IS-Impact model’s dimensions and measures in the new context, and to conceptualise any resultant model changes to be operationalised in the confirmatory phase. Responses from 134 ALESCO users to the main survey question, "What do you consider have been the impacts of the ALESCO (HR) system in your division/department since its implementation?" were decomposed into 425 ‘impact citations.’ Citation mapping using a deductive (top-down) content analysis approach instantiated all dimensions and measures of the IS-Impact model, evidencing its content validity in the new context. Seeking to probe additional (perhaps negative) impacts; the survey included the additional open question "In your opinion, what can be done better to improve the ALESCO (HR) system?" Responses to this question decomposed into a further 107 citations which in the main did not map to IS-Impact, but rather coalesced around the concept of IS-Support. Deductively drawing from relevant literature, and working inductively from the unmapped citations, the new ‘IS-Support’ construct, including the four formative dimensions (i) training, (ii) documentation, (iii) assistance, and (iv) authorisation (each having reflective measures), was defined as: "a measure at a point in time, of the support, the [HR] information system key-user groups receive to increase their capabilities in utilising the system." Thus, a further goal of the study became validation of the IS-Support construct, suggesting the research question (RQ3): "Is IS-Support valid as a 1st-order reflective, 2nd-order formative multidimensional construct?" With the aim of validating IS-Impact within its nomological net (identification through structural relations), as in prior work, Satisfaction was hypothesised as its immediate consequence. The IS-Support construct having derived from a question intended to probe IS-Impacts, too was hypothesised as antecedent to Satisfaction, thereby suggesting the research question (RQ4): "What is the relative contribution of IS-Impact and IS-Support to Satisfaction?" With the goal of testing the above research questions, IS-Impact, IS-Support and Satisfaction were operationalised in a quantitative survey instrument. Partial least squares (PLS) structural equation modelling employing 221 valid responses largely evidenced the validity of the commencing IS-Impact model in the HR context. ISSupport too was validated as operationalised (including 11 reflective measures of its 4 formative dimensions). IS-Support alone explained 36% of Satisfaction; IS-Impact alone 70%; in combination both explaining 71% with virtually all influence of ISSupport subsumed by IS-Impact. Key study contributions to research include: (1) validation of IS-Impact in the HR context, (2) validation of a newly conceptualised IS-Support construct as important antecedent of Satisfaction, and (3) validation of the redundancy of IS-Support when gauging IS-Impact. The study also makes valuable contributions to practice, the research track and the sponsoring organisation.

A holistic blended design studio model : Exploring and expanding learning opportunities

This book involves a comprehensive study of the learning environment by adopting Grounded Theory methodology in a qualitative comparative way.It explores the limitations and benefits of a face-to-face and a virtual design studio as experienced by architecture students and educators at an Australian university in order to find the optimal combination for a blended environment to enhance the students’ experience. The main outcome:holistic multidimensional blended learning model,that through the various modalities,provides adaptive capacity in a range of settings.The model facilitates learning through self-determination,self-management,and the personalisation of the learning environment. Another outcome:a conceptual design education framework,provides a basic tool for educators to evaluate existing learning environments and to develop new learning environments with enough flexibility to respond effectively to a highly dynamic and increasingly technological world.The provision of a practical framework to assist design schools to improve their educational settings according to a suitable pedagogy that meets today’s needs and accommodates tomorrow’s changes.

First 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 over- lays. 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 has much potential in areas of BPM; to engage, pro- vide insight, and to promote collaboration amongst analysts and stakeholders alike. This initial visualization workshop seeks to initiate the development of a high quality international forum to present and discuss research in this field. Via this workshop, we intend to create a community to unify and nurture the development of process visualization topics as a continuing research area.

Experimenting with affirmative action : the Coate and Loury Model

Coate and Loury (1993) suggest the impact of affirmative action on a negative stereotype is theoretically ambiguous leading to either: a benign equilibrium in which affirmative action eradicates the negative stereotype and leads to equal proportional representation of the two groups; or alternatively a patronising equilibrium in which the stereotype persists. The current paper examines this theoretical ambiguity within the context of a laboratory experiment. Although benign and patronising equilibria are equally plausible in theory, the laboratory experiments easily replicate most features of the benign equilibrium, but diverge from the theoretically predicted patronising equilibrium.