Double tax agreements and the international allocation of business income in Australia

Increasingly, the effectiveness of the present system of taxation of international businesses is being questioned. The problem associated with the taxation of such businesses is twofold. A system of international taxation must be a fair and equitable system, distributing profits between the relevant jurisdictions and, in doing so, avoiding double taxation. At the same time, the prevention of fiscal evasion must be secured. In an attempt to achieve a fair and equitable system Australia adopts unilateral, bilateral and multilateral measures to avoid double taxation and restrict the avoidance of tax. The first step in ascertaining the international allocation of business income is to consider the taxation of business income according to domestic law, that is, the unilateral measures. The treatment of international business income under the Australian domestic law, that is, the Income Tax Assessment Act 1936 (Cth) and Income Tax Assessment Act 1997 (Cth), will depend on two concepts, first, whether the taxpayer is a resident of Australia and secondly, whether the income is sourced in Australia. After the taxation of business profits has been determined according to domestic law it is necessary to consider the applicability of the bilateral measures, that is, the Double Tax Agreements (DTAs) to which Australia is a party, as the DTAs will override the domestic law where there is any conflict. Australia is a party to 40 DTAs with another seven presently being negotiated. The preamble to Australia's DTAs provides that the purpose of such agreements is 'to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income'. Both purposes, for different reasons, are equally important. It has been said that: The taxpayer hopes the treaty will prevent the double taxation of his income; the tax gatherer hopes the treaty will prevent fiscal evasion; and the politician just hopes. The first purpose, the avoidance of double taxation, is achieved through the provision of rules whereby the Contracting States agree to the classification of income and the allocation of that income to a particular State. In this sense DTAs do not allocate jurisdiction to tax but rather provide an arrangement whereby the States agree to restrict their substantive law. The restriction is either through the non-taxing of the income or via the provision of a tax credit.

An effort towards understanding the sources of impurities in generating nanoparticles via liquid-phase methods

Generating nano-sized materials of a controlled size and chemical composition is essential for the manufacturing of materials with enhanced properties on an industrial scale, as well as for research purposes, such as toxicological studies. Among the generation methods for airborne nanoparticles (also known as aerosolisation methods), liquid-phase techniques have been widely applied due to the simplicity of their use and their high particle production rate. The use of a collison nebulizer is one such technique, in which the atomisation takes place as a result of the liquid being sucked into the air stream and injected toward the inner walls of the nebulizer reservoir via nozzles, before the solution is dispersed. Despite the above-mentioned benefits, this method also falls victim to various sources of impurities (Knight and Petrucci 2003; W. LaFranchi, Knight et al. 2003). Since these impurities can affect the characterization of the generated nanoparticles, it is crucial to understand and minimize their effect.

Asset allocation policy, returns and expenses of superannuation funds : recent evidence based on default options

We examine the asset allocation, returns, and expenses of superannuation funds whose assets are mainly invested in default investment options between 2004 and 2012. A majority of these funds fail to earn returns commensurate with their strategic asset allocation policy. It appears that much of the variation of returns between the funds might be a result of their engaging in significant active management of assets. Our results indicate that returns from active management are negatively related to expenses. We also find strong evidence of economies of scale existing in these superannuation funds across different size categories.

Block models for improved earthwork allocation planning in linear infrastructure construction

Earthwork planning has been considered in this article and a generic block partitioning and modelling approach has been devised to provide strategic plans of various levels of detail. Conceptually this approach is more accurate and comprehensive than others, for instance those that are section based. In response to environmental concerns the metric for decision making was fuel consumption and emissions. Haulage distance and gradient are also included as they are important components of these metrics. Advantageously the fuel consumption metric is generic and captures the physical difficulties of travelling over inclines of different gradients, that is consistent across all hauling vehicles. For validation, the proposed models and techniques have been applied to a real world road project. The numerical investigations have demonstrated that the models can be solved with relatively little CPU time. The proposed block models also result in solutions of superior quality, i.e. they have reduced fuel consumption and cost. Furthermore the plans differ considerably from those based solely upon a distance based metric thus demonstrating a need for industry to reflect upon their current practices.

Fairness aware resource allocation in multi-hop OFDM systems

This thesis presents an analysis of the resource allocation problem in Orthogonal Frequency Division Multiplexing based multi-hop wireless communications systems. The study analyzed the tractable nature of the problem and designed several heuristic and fairness-aware resource allocation algorithms. These algorithms are fast and efficient and therefore can improve power management in wireless systems significantly.

On the allocation of a takeover purchase price under AASB1013

The purpose of this paper is to document and explain the allocation of takeover purchase price to identifiable intangible assets (IIAs), purchased goodwill, and/or target net tangible assets in an accounting environment unconstrained with respect to IIA accounting policy choice. Using a sample of Australian acquisitions during the unconstrained accounting environment from 1988 to 2004, we find the percentage allocation of purchase price to IIAs averaged 19.09%. The percentage allocation to IIAs is significantly positively related to return on assets and insignificantly related to leverage, contrary to opportunism. Efficiency suggests an explanation: profitable firms acquire and capitalise a higher percentage of IIAs in acquisitions. The target's investment opportunity set is significantly positively related to the percentage allocation to IIAs, consistent with information-signalling. The paper contributes to the accounting policy choice literature by showing how Australian firms make the one-off accounting policy choice in regards allocation of takeover purchase price (which is often a substantial dollar amount to) in an environment where accounting for IIAs was unconstrained.

Constrained control design for dynamic positioning of marine vehicles with control allocation

In this paper, we address the control design problem of positioning of over-actuated marine vehicles with control allocation. The proposed design is based on a combined position and velocity loops in a multi-variable anti-windup implementation together with a control allocation mapping. The vehicle modelling is considered with appropriate simplifications related to low-speed manoeuvring hydrodynamics and vehicle symmetry. The control design is considered together with a control allocation mapping. We derive analytical tuning rules based on requirements of closed-loop stability and performance. The anti- windup implementation of the controller is obtained by mapping the actuator-force constraint set into a constraint set for the generalized forces. This approach ensures that actuation capacity is not violated by constraining the generalized control forces; thus, the control allocation is simplified since it can be formulated as an unconstrained problem. The mapping can also be modified on-line based on actuator availability to provide actuator-failure accommodation. We provide a proof of the closed-loop stability and illustrate the performance using simulation scenarios for an open-frame underwater vehicle.

A survey of control allocation methods for underwater vehicles

A control allocation system implements a function that maps the desired control forces generated by the vehicle motion controller into the commands of the different actuators. In this article, a survey of control allocation methods for over-actuated underwater vehicles is presented. The methods are applicable for both surface vessels and underwater vehicles. The paper presents a survey of control allocation methods with focus on mathematical representation and solvability of thruster allocation problems. The paper is useful for university students and engineers who want to get an overview of state-of-the art control allocation methods as well as advance methods to solve more complex problems.

An integrated approach for earthwork allocation, sequencing and routing

Planning techniques for large scale earthworks have been considered in this article. To improve these activities a “block theoretic” approach was developed that provides an integrated solution consisting of an allocation of cuts to fills and a sequence of cuts and fills over time. It considers the constantly changing terrain by computing haulage routes dynamically. Consequently more realistic haulage costs are used in the decision making process. A digraph is utilised to describe the terrain surface which has been partitioned into uniform grids. It reflects the true state of the terrain, and is altered after each cut and fill. A shortest path algorithm is successively applied to calculate the cost of each haul, and these costs are summed over the entire sequence, to provide a total cost of haulage. To solve this integrated optimisation problem a variety of solution techniques were applied, including constructive algorithms, meta-heuristics and parallel programming. The extensive numerical investigations have successfully shown the applicability of our approach to real sized earthwork problems.

Selecting volatility forecasting models for portfolio allocation purposes

Techniques for evaluating and selecting multivariate volatility forecasts are not yet understood as well as their univariate counterparts. This paper considers the ability of different loss functions to discriminate between a set of competing forecasting models which are subsequently applied in a portfolio allocation context. It is found that a likelihood-based loss function outperforms its competitors, including those based on the given portfolio application. This result indicates that considering the particular application of forecasts is not necessarily the most effective basis on which to select models.

Antispin thrust allocation for marine vessels

In extreme weather conditions, thrusters on ships and rigs may be subject to severe thrust losses caused by ventilation and in-and-out-of-water events. When a thruster ventilates, air is sucked down from the surface and into the propeller. In more severe cases, parts of or even the whole propeller can be out of the water. These losses vary rapidly with time and cause increased wear and tear in addition to reduced thruster performance. In this paper, a thrust allocation strategy is proposed to reduce the effects of thrust losses and to reduce the possibility of multiple ventilation events. This thrust allocation strategy is named antispin thrust allocation, based on the analogous behavior of antispin wheel control of cars. The proposed thrust allocation strategy is important for improving the life span of the propulsion system and the accuracy of positioning for vessels conducting station keeping in terms of dynamic positioning or thruster-assisted position mooring. Application of this strategy can result in an increase of operational time and, thus, increased profitability. The performance of the proposed allocation strategy is demonstrated with experiments on a model ship.

A low-complexity flight controller for Unmanned Aircraft Systems with constrained control allocation

In this paper, we propose a framework for joint allocation and constrained control design of flight controllers for Unmanned Aircraft Systems (UAS). The actuator configuration is used to map actuator constraint set into the space of the aircraft generalised forces. By constraining the demanded generalised forces, we ensure that the allocation problem is always feasible; and therefore, it can be solved without constraints. This leads to an allocation problem that does not require on-line numerical optimisation. Furthermore, since the controller handles the constraints, and there is no need to implement heuristics to inform the controller about actuator saturation. The latter is fundamental for avoiding Pilot Induced Oscillations (PIO) in remotely operated UAS due to the rate limit on the aircraft control surfaces.

Joint motion control and control allocation design for UAS flight control systems

As Unmanned Aircraft Systems (UAS) grow in complexity, and their level of autonomy increases|moving away from the concept of a remotely piloted systems and more towards autonomous systems|there is a need to further improve reliability and tolerance to faults. The traditional way to accommodate actuator faults is by using standard control allocation techniques as part of the flight control system. The allocation problem in the presence of faults often requires adding constraints that quantify the maximum capacity of the actuators. This in turn requires on-line numerical optimisation. In this paper, we propose a framework for joint allocation and constrained control scheme via vector input scaling. The actuator configuration is used to map actuator constraints into the space of the aircraft generalised forces, which are the magnitudes demanded by the light controller. Then by constraining the output of controller, we ensure that the allocation function always receive feasible demands. With the proposed framework, the allocation problem does not require numerical optimisation, and since the controller handles the constraints, there is not need to implement heuristics to inform the controller about actuator saturation.

Organizational factors impacting on patient satisfaction : a cross sectional examination of service climate and linkages to nurses' effort and performance

Background Patient satisfaction is influenced by the setting in which patients are treated and the employees providing care. However, to date, limited research has explained how health care organizations or nurses influence patient satisfaction. Objectives The purpose of this study was to test the model that service climate would increase the effort and performance of nursing groups and, in turn, increase patient satisfaction. Method This study incorporated data from 156 nurses, 28 supervisors, and 171 patients. A cross-sectional design was utilized to examine the relationship between service climate, nurse effort, nurse performance and patient satisfaction. Structural equation modeling was conducted to test the proposed relationships. Results Service climate was associated with the effort that nurses directed towards technical care and extra-role behaviors. In turn, the effort that nurses exerted predicted their performance, as rated by their supervisors. Finally, task performance was a significant predictor of patient satisfaction. Conclusions This study suggests that both hospital management and nurses play a role in promoting patient satisfaction. By focusing on creating a climate for service, health care managers can improve nursing performance and patient satisfaction with care.

Control design for positioning of underwater vehicles with control allocation

In this paper, we address the control design problem of positioning of over-actuated underwater vehicles. The proposed design is based on a control architecture with combined position and velocity loops and a control tuning method based on the decoupled models. We derive analytical tuning rules based on requirements of closed-loop stability, positioning performance, and the vehicle velocity dynamic characteristics. The vehicle modelling is considered from force to motion with appropriate simplifications related to low-speed manoeuvring hydrodynamics and vehicle symmetry. The control design is considered together with a control allocation mapping. This approach makes the control tuning independent of the characteristics of the force actuators and provides the basis for control reconfiguration in the presence of actuator failure. We propose an anti-wind-up implementation of the controller, which ensures that the constraints related to actuation capacity are not violated. This approach simplifies the control allocation problem since the actuator constraints are mapped into generalised force constraints.