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.

Which Women are More Likely to be Abused? Public Housing, Cohabitation and Separated/Divorced Women.

Data collected at Canadian public housing estates in eastern Ontario are used here to analyze two hypotheses. Overall these women report more violence than do otherwise situated women in other general surveys. More specifically, complex theoretical models were designed to generate two hypotheses for further analysis: First, that separated/divorced women are more likely to be abused within public housing than married women. Second, that cohabiting women will report violence victimization at a higher rate than separated, divorced, or married women. Some support for both hypotheses were found, and the theoretical models are used to discuss these findings.

Governing Prostitution: New Formations, Old Agendas

Recent governmentality literature distinguishes between government from above and government “from below” in an attempt to avoid “top-down” analyzes of state-centered government and to acknowledge the multiple and diverse ways in which the governance is achieved. By analyzing key shifts and changes in the regulation of prostitution in the UK in the last three decades, it is possible to complicate the distinction between the two modes of government. Whilst some writers highlight the ways in which government from above and below become increasingly blurred, this article argues that although the agendas and modes of government from above and below are difficult to disentangle, the effects on sex workers are not. Regulation remains rooted within coercive and punitive state-centered criminal justice responses, even though organizations “from below” may well be the very organizations tasked by the state with carried out those responses.

Explaining internationalisation of small to medium sized enterprises within the Queensland food and beverage industry

The prevalence of International New Ventures (INVs) has increased during the past twenty years. Nevertheless, to date there has been no general consensus within the literature on an explanation as to the rapid internationalisation of some firms. Do they follow a similar process to other firms that internationalise based on a more ‘measured’ incremental sequential process of internationalisation. This paper proposes and tests an innovation diffusion model of the internationalisation of small firm INVs and others by drawing on key innovation diffusion models from the literature. The results of this analysis indicate that the synthesised model of export adoption is effective in explaining the internationalisation process of INVs and other firms within the Queensland Food and Beverage Industry. Significantly, the features of the original innovation diffusion models developed in the consumer behaviour literature, which had limited examination within the internationalisation literature, were confirmed. This includes the ability of firms, or specifically decision-makers, to skip stages based on previous experience.

More food banks than MacDonalds : the future of civil society?

The title of this paper came out of a conversation I had on a recent trip to Canada. I had gone there because I wanted to spend a bit of time seeing how non-government organisations in Canada were faring in this age of re inventing government. Osborne and Gaebler (1992) I wanted to try and understand whether there were any lessons in the Canadian experience, that might be relevant for Australia. As I hope to demonstrate while there are both similarities and differences, the questions facing both nations have a remarkable correspondence.

Coping with aggressive driving : driver accounts of how they manage themselves and others to reduce conflict on the road

Dealing with the aggression of other drivers on the road is an important skill given that driving is a common activity for adults in highly motorised countries. Even though incidents of extreme aggression on the road (such as assault) are reportedly rare, milder forms, some of them dangerous (such as tailgating or deliberately following too closely) are apparently common, and may be increasing. At the very least, this is likely to render the driving environment more stressful, and at worst elevates the risk of crashing by increasing both the level of risky driving behaviours and the likelihood of responses that escalate the situation. Thus the need for drivers to manage incidents of conflict is likely to become increasingly important. However, little research examines how drivers manage their own or others’ aggressive driving behaviour. Recently greater attention has been paid to driver cognitions, especially the attributions that drivers make about other drivers, that then might influence their own driving responses, particularly aggressive or risky ones. The study reported below was the first in a larger exploration of aggressive driving that focussed on driver cognitions, emotions and underlying motivations for aggressive behaviours on the road. Qualitative, in-depth interviews of drivers (n = 30, aged 18-49 years) were subjected to thematic analysis to investigate driver experiences with aggressive driving. Two main themes were identified from these accounts: driver management of self; and driver attempts to influence or manage other drivers. This paper describes the subthemes falling under the management of self main theme. These subthemes were labelled ‘being magnanimous’, ‘chilling out’, ‘slowing down’, and ‘apology/acknowledgment’. ‘Being magnanimous’ referred to situations where the respondent perceived him/herself to be a recipient of another’s aggressive driving and made a deliberate choice not to respond. However, a characteristic of this sub-theme was that this choice was underpinned by the adoption of morally superior stance, or sense of magnanimity. ‘Chilling out’ was a more general response to both the milder aggressive behaviours of other drivers and the general frustrations of driving. ‘Slowing down’ referred to reducing one’s speed in response to the perceived aggressive driving, often tailgating, of another. This subtheme appeared to consist of two separate underlying motivations. One of these was a genuine concern for one’s own safety while the other was more aimed at “getting back” at the other driver. ‘Apology’ referred to how drivers modified their more negative reactions and responses when another driver made gestures that acknowledged their having made a mistake, indicated an apology, or acknowledged the recipient driver. These sub-themes are discussed in relation to their implications for understanding aggressive driving and intervening to reduce it.

An Econometric Analysis of Inter-Firm Labour Mobility

This paper utilizes the Survey of Work History (1981) data to examine the importance of non-random sampling in the context of a model of interfirm labour mobility. The paper adopts Heckman's two-step procedure in order to estimate a three-equation model incorporating an individual's mobility status as endogenously determined. The main conclusion is that in estimating wage equations it is important to consider the role of job mobility and to correct for the effects of sample-selection bias. The results generally accord with those reported by Osberg et al. (1986) in the only previous Canadian study of job mobility in a sample-selection context.

Proteomics science & society : the role of knowledge translation in moving towards clinical applications

Background: Outside the mass-spectrometer, proteomics research does not take place in a vacuum. It is affected by policies on funding and research infrastructure. Proteomics research both impacts and is impacted by potential clinical applications. It provides new techniques & clinically relevant findings, but the possibilities for such innovations (and thus the perception of the potential for the field by funders) are also impacted by regulatory practices and the readiness of the health sector to incorporate proteomics-related tools & findings. Key to this process is how knowledge is translated. Methods: We present preliminary results from a multi-year social science project, funded by the Canadian Institutes of Health Research, on the processes and motivations for knowledge translation in the health sciences. The proteomics case within this wider study uses qualitative methods to examine the interplay between proteomics science and regulatory and policy makers regarding clinical applications of proteomics. Results: Adopting an interactive format to encourage conference attendees’ feedback, our poster focuses on deficits in effective knowledge translation strategies from the laboratory to policy, clinical, & regulatory arenas. An analysis of the interviews conducted to date suggests five significant choke points: the changing priorities of funding agencies; the complexity of proteomics research; the organisation of proteomics research; the relationship of proteomics to genomics and other omics sciences; and conflict over the appropriate role of standardisation. Conclusion: We suggest that engagement with aspects of knowledge translation, such as those mentioned above, is crucially important for the eventual clinical application ofproteomics science on any meaningful scale.

Does occupational aggregation matter in determining the size of the gender wage gap?

The traditional decomposition of the gender wage gap distinguishes between a component attributable to gender differences in productivity-related characteristics and a residual component that is often taken as a measure of discrimination. This study of data from the 1989 Canadian Labour Market Activity Survey shows that when occupation is treated as a productivity-related characteristic, the proportion of the gender wage gap labeled explained increases with the number of occupational classifications distinguished. However, on the basis of evidence that occupational differences reflect the presence of barriers faced by women attempting to enter male-dominated occupations, the authors conclude that occupation should not be treated as a productivity-related characteristic; and in a decomposition of the gender wage gap that treats occupation as endogenously determined, they find that the level of occupational aggregation has little effect on the size of the "explained" component of the gap.

The gender wage gap : a comparison of Australia and Canada

Using data from the 1989 Canadian Labour Market Activity Survey and, for Australia, the 1989-90 Income Distribution Survey, the authors investigate the reasons for the significantly lower gender wage gap in Australia than in Canada. Key similarities and differences between these two countries, the authors argue, make them a good basis for a "natural experiment" to investigate the effects of different labor market institutions. In particular, Australia has a stronger union movement and a greater degree of centralization in wage determination than Canada, and most of its workers are covered by legally binding minimum working conditions. The authors conclude that several differences between the countries in labor market structure-notably, a lower rate of return to education, a lower rate of return to labor market experience, and a lower level of wage inequality in Australia than in Canada- are largely responsible for the smaller gender wage gap in Australia.

From the Editor

In this issue of the Journal, the articles considered reflect the depth of research and practice that is unique to project management discipline. The range of topics addressed includes managing project contracts (Chan et al., “A Comparative Study of the Benefits of Applying Target Cost Contracts Between South Australia and Hong Kong”), managing project complexity (Chronéer and Bergquist, “Managerial Complexity in Process Industrial R&D Projects: A Swedish Study”), identifying early warning signs in complex projects (Williams et al., “Identifying and Acting on Early Warning Signs in Complex Projects”), project risk management (Krane, Olsson, and Rolstadås, “How Project Manager–Project Owner Interaction Can Work Within and Influence Project Risk Management”), exploring decisions regarding outsourcing and alignment of the project management office (Martins and Martins, “Outsourcing Operations in Project Management Offices: The Reality of Brazilian Companies”), and project management practices at strategic and tactical levels of the organization leading to sustainable development (Herazo, Lizarralde, and Paquin, “Sustainable Development in the Building Sector: A Canadian Case Study on the Alignment of Strategic and Tactical Management”).