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.

Inequality, fiscal capacity and the political regime: lessons from the post-communist transition

Using panel data for twenty-seven post-communist economies between 1987-2003, we examine the nexus of relationships between inequality, fiscal capacity (defined as the ability to raise taxes efficiently) and the political regime. Investigating the impact of political reform we find that full political freedom is associated with lower levels of income inequality. Under more oligarchic (authoritarian) regimes, the level of inequality is conditioned by the state’s fiscal capacity. Specifically, oligarchic regimes with more developed fiscal systems are able to defend the prevailing vested interests at a lower cost in terms of social injustice. This empirical finding is consistent with the model developed by Acemoglu (2006). We also find that transition countries undertaking early macroeconomic stabilisation now enjoy lower levels of inequality; we confirm that education fosters equality and the suggestion of Commander et al (1999) that larger countries are prone to higher levels of inequality.

"Rentier States" or the Relationship between Regime Stability and Exercising Power in Post-Soviet Central Asia

The paper intends to give an insight into the relations of the economic and political systems of the Central Asian republics using the theoretical framework of the "rentier economy" and "rentier state" approach. The main findings of the paper are that two (Kazakhstan and Turkmenistan) of the five states examined are commodity export dependent “full-scale” rentier states. The two political systems are of a stable neo-patrimonial regime character, while the Kyrgyz Republic and Tajikistan, poor in natural resources but dependent on external rents, may be described as "semi-rentier" states or "rentier economies". They are politically more instable, but have an altogether authoritarian, oligarchical “clan-based” character. Uzbekistan with its closed economy, showing tendencies of economic autarchy, is also a potentially politically unstable clan-based regime. Thus, in the Central Asian context, the rentier state or rentier economy character affects the political stability of the actual regimes rather than having a direct impact on whether power is exercised in an autocratic or democratic way.

Regime jurídico do alojamento local: a problemática dos imóveis arrendados de particulares e dos respetivos rendimento não declarados

Dissertação de Mestrado, Fiscalidade, Escola Superior de Gestão, Hotelaria e Turismo, Universidade do Algarve, 2016

Transport simulation : beyond traditional approaches

In recent years, the transport simulation of large road networks has become far more rapid and detailed, and many exciting developments in this field have emerged. In this perspective, the authors describe the simulation of automobile, pedestrian and rail traffic, coupled to new applications, such as the embedding of traffic simulation into driving simulators, to give a more realistic environment of driver behavior surrounding the subject vehicle.

The function of property in creating an effective legal regime for trade in environmental offsets

Market-based environmental regulation is becoming increasingly common within international and national frameworks. Environmental offset and trading regimes are part of the market-based instrument revolution. This paper proposes that environmental market mechanisms could be used to introduce an ethic of land holder responsibility. In order for market based regimes to attract sufficient levels of stakeholder engagement, participants within such scheme require an incentive to participate and furthermore need to feel a sense of security about investing in such processes. A sense of security is often associated with property based interests. This paper explores the property related issues connected with environmental offset and trading scheme initiatives. Relevant property-related considerations include land tenure considerations, public versus private management of land choices, characteristics and powers associated with property interests, theories defining property and the recognition of legal proprietal interests. The Biodiversity Banking Scheme in New South Wales is then examined as a case study followed by a critique on the role of environmental markets.

A review of non-traditional occupational therapy practice placement education : a focus on role-emerging and project placements

Practice placement education has been recognised as an integral and critical component of the training of occupational therapy students. Although there is an extensive body of literature on clinical education and traditional practice placement education models, there has been limited research on alternative placements.-------- This paper reviews the literature on various practice placement education models and presents a contemporary view on how it is currently delivered. The literature is examined with a particular focus on the increasing range of practice placement education opportunities, such as project and role-emerging placements. The drivers for non-traditional practice placement education include shortages of traditional placement options, health reform and changing work practices, potential for role development and influence on practice choice. The benefits and challenges of non-traditional practice placement education are discussed, including supervision issues, student evaluation, professional and personal development and the opportunity to practise clinical skills.--------- Further research is recommended to investigate occupational therapy graduates' perceptions of role-emerging and project placements in order to identify the benefits or otherwise of these placements and to contribute to the limited body of knowledge of emerging education opportunities.

Schools and Diversity, 2nd ed.

Schools and diversity aims to address the need for schools and teachers to provide quality education for all students in rapidly changing social contexts. Community and student voices are telling schools that traditional education is too authoritarian and restrictive. Students do not feel valued and respected in their school community. Schools are obliged to respond to this critique with more democratic and relevant policies and processes that connect all students with their learning futures. This text is about developing a more inclusive approach to education which aims to identify and dismantle actual and potential sources of exclusion that limit opportunities and outcomes for all students.

Business model construction : the importance of regime of appropriability strategies

To date, most theories of business models have theorized value capture assuming that appropriability regimes were exogenous and that the firm would face a unique, ideal-typical appropriability regime. This has led theory contributions to focus on governance structures to minimize transaction costs, to downplay the interdepencies between value capture and value creation, and to ignore revenue generation strategies. We propose a reconceptualization of business models value capture mechanisms that rely on assumptions of endogeneity and multiplicity of appropriability regimes. This new approach to business model construction highlights the interdependencies and trade-offs between value creation and value capture offered by different types and combinations of appropriability regimes. The theory is illustrated by the analysis of three cases of open source software business models

Vitamin D in health and disease : an insight into traditional functions and new roles for the 'sunshine vitamin'

Vitamin D is unique among the vitamins in that humans can synthesize it via the action of UV radiation upon the skin. This combined with its ability to act on specific target tissues via Vitamin D Receptor’s (VDR) make its classification as a steroid hormone more appropriate. While Vitamin D deficiency is a recognized problem in some northern latitude countries, recent studies have shown even in sunny countries such as Australia, vitamin D deficiency may be more prevalent than first thought. Vitamin D is most well known for its role in bone health, however, the discovery of VDR’s on a wide variety of tissue types has also opened up roles for vitamin D far beyond traditional bone health. These include possible associations with autoimmune diseases such as multiple sclerosis and inflammatory bowel diseases, cancer, cardiovascular diseases and muscle strength. Firstly, this paper presents an overview of the two sources of vitamin D: exposure to ultraviolet-B radiation and food sources of vitamin D, with particular focus on both Australian and international studies on dietary vitamin D intake and national fortification strategies. Secondly, the paper reviews recent epidemiological and experimental evidence linking vitamin D and its role in health and disease for the major conditions linked to suboptimal vitamin D, while identifying significant gaps in the research and possible future directions for research.