Transfer pricing and multinational financial institutions : the case for replacing arm’s length price with a unitary approach

The international tax system, designed a century ago, has not kept pace with the modern multinational entity rendering it ineffective in taxing many modern businesses according to economic activity. One of those modern multinational entities is the multinational financial institution (MNFI). The recent global financial crisis provides a particularly relevant and significant example of the failure of the current system on a global scale. The modern MNFI is increasingly undertaking more globalised and complex trading operations. A primary reason for the globalisation of financial institutions is that they typically ‘follow-the-customer’ into jurisdictions where international capital and international investors are required. The International Monetary Fund (IMF) recently reported that from 1995-2009, foreign bank presence in developing countries grew by 122 per cent. The same study indicates that foreign banks have a 20 per cent market share in OECD countries and 50 per cent in emerging markets and developing countries. Hence, most significant is that fact that MNFIs are increasingly undertaking an intermediary role in developing economies where they are financing core business activities such as mining and tourism. IMF analysis also suggests that in the future, foreign bank expansion will be greatest in emerging economies. The difficulties for developing countries in applying current international tax rules, especially the current traditional transfer pricing regime, are particularly acute in relation to MNFIs, which are the biggest users of tax havens and offshore finance. This paper investigates whether a unitary taxation approach which reflects economic reality would more easily and effectively ensure that the profits of MNFIs are taxed in the jurisdictions which give rise to those profits. It has previously been argued that the uniqueness of MNFIs results in a failure of the current system to accurately allocate profits and that unitary tax as an alternative could provide a sounder allocation model for international tax purposes. This paper goes a step further, and examines the practicalities of the implementation of unitary taxation for MNFIs in terms of the key components of such a regime, along with their their implications. This paper adopts a two-step approach in considering the implications of unitary taxation as a means of improved corporate tax coordination which requires international acceptance and agreement. First, the definitional issues of the unitary MNFI are examined and second, an appropriate allocation formula for this sector is investigated. To achieve this, the paper asks first, how the financial sector should be defined for the purposes of unitary taxation and what should constitute a unitary business for that sector and second, what is the ‘best practice’ model of an allocation formula for the purposes of the apportionment of the profits of the unitary business of a financial institution.

Violence in and around entertainment districts : a longitudinal analysis of the impact of late-night lockout legislation

Violence in entertainment districts is a major problem across urban landscapes throughout the world. Research shows that licensed premises are the third most common location for homicides and serious assaults, accounting for one in ten fatal and nonfatal assaults. One class of interventions that aims to reduce violence in entertainment districts involves the use of civil remedies: a group of strategies that use civil or regulatory measures as legal “levers” to reduce problem behavior. One specific civil remedy used to reduce problematic behavior in entertainment districts involves manipulation of licensed premise trading hours. This article uses generalized linear models to analyze the impact of lockout legislation on recorded violent offences in two entertainment districts in the Australian state of Queensland. Our research shows that 3 a.m. lockout legislation led to a direct and significant reduction in the number of violent incidents inside licensed premises. Indeed, the lockouts cut the level of violent crime inside licensed premises by half. Despite these impressive results for the control of violence inside licensed premises, we found no evidence that the lockout had any impact on violence on streets and footpaths outside licensed premises that were the site for more than 80 percent of entertainment district violence. Overall, however, our analysis suggests that lockouts are an important mechanism that helps to control the level of violence inside licensed premises but that finely grained contextual responses to alcohol-related problems are needed rather than one-size-fits-all solutions.

Defence industry projects : investigating the impact of major project manager attributes on stakeholder relationships and project success

This thesis identifies attributes, skills and behaviours that major project managers require for stakeholder relationships competence and project success within a major project environment. It develops valid and reliable measures of internal and external stakeholder relationships competence, tests a complex conceptual model and explores the effectiveness of the QUT Executive Masters of Complex Project Management and Strategic Procurement in developing major project managers' stakeholder relationships competence. Implications of this thesis are for government and industry in identifying factors associated with major project success, as this will lead to better major project outcomes potentially resulting in time and monetary savings of years and billions of dollars.

Crowdsourcing interactions : using crowdsourcing for evaluating interactive information retrieval systems

In the field of information retrieval (IR), researchers and practitioners are often faced with a demand for valid approaches to evaluate the performance of retrieval systems. The Cranfield experiment paradigm has been dominant for the in-vitro evaluation of IR systems. Alternative to this paradigm, laboratory-based user studies have been widely used to evaluate interactive information retrieval (IIR) systems, and at the same time investigate users’ information searching behaviours. Major drawbacks of laboratory-based user studies for evaluating IIR systems include the high monetary and temporal costs involved in setting up and running those experiments, the lack of heterogeneity amongst the user population and the limited scale of the experiments, which usually involve a relatively restricted set of users. In this paper, we propose an alternative experimental methodology to laboratory-based user studies. Our novel experimental methodology uses a crowdsourcing platform as a means of engaging study participants. Through crowdsourcing, our experimental methodology can capture user interactions and searching behaviours at a lower cost, with more data, and within a shorter period than traditional laboratory-based user studies, and therefore can be used to assess the performances of IIR systems. In this article, we show the characteristic differences of our approach with respect to traditional IIR experimental and evaluation procedures. We also perform a use case study comparing crowdsourcing-based evaluation with laboratory-based evaluation of IIR systems, which can serve as a tutorial for setting up crowdsourcing-based IIR evaluations.

Insurer and insured

This chapter analyses the obligations insurers and insureds owe each other and the remedies which follow a breach of obligation.

Challenges of responding to online fraud victimisation in Australia

Online fraud occurs when an individual or a business responds in some manner to an unsolicited invitation received via the internet and suffers financial or other detrimental effects as a result. In 2010–11, the Australian Bureau of Statistics (2012) found that over 1.2 million Australians (6.7% of the population aged 15 years and over) had been a victim of personal fraud, losing approximately $1.4b in the preceding 12 months. More than half of these victims (55.7%) were contacted via the internet or email (online victimisation). In addition to monetary losses, victims of online fraud suffer serious psychological, emotional, social and even physical problems as a consequence of their victimisation. This paper explores the challenges of responding to online fraud victimisation in Australia and describes some of the specific support services that have recently emerged to support victims of this crime.

The cost-effectiveness of total laparoscopic hysterectomy compared to total abdominal hysterectomy for the treatment of early stage endometrial cancer

Objective To summarise how costs and health benefits will change with the adoption of total laparoscopic hysterectomy compared to total abdominal hysterectomy for the treatment of early stage endometrial cancer. Design Cost-effectiveness modelling using the information from a randomised controlled trial. Participants Two hypothetical modelled cohorts of 1000 individuals undergoing total laparoscopic hysterectomy and total abdominal hysterectomy. Outcome measures Surgery costs; hospital bed days used; total healthcare costs; quality-adjusted life years; and net monetary benefits. Results For 1000 individuals receiving total laparoscopic hysterectomy surgery, the costs were $509 575 higher, 3548 hospital fewer bed days were used and total health services costs were reduced by $3 746 221. There were 39.13 more quality-adjusted life years for a 5 year period following surgery. Conclusions The adoption of total laparoscopic hysterectomy is almost certainly a good decision for health services policy makers. There is 100% probability that it will be cost saving to health services, a 86.8% probability that it will increase health benefits and a 99.5% chance that it returns net monetary benefits greater than zero.

A Tradable Permit System in an Intertemporal Economy

It is known that in an intertemporal competitive economy, a tradable permit system may not achieve efficiency without setting appropriate permit interest rates (i.e., rewards for holding permits). To find the rates, however, we need to know in advance the path of efficient permit prices, which is difficult to obtain. This study intends to solve this problem in two ways. First, we analyze a special case in which the permit interest rates are given by a simple rule. For example, if the marginal abatement cost of pollution emission is constant, then the appropriate rate is to equal the monetary interest rate. As is the case for global warming, if the damage is caused in the future far beyond the planning period of the environmental program, the appropriate rate coincides with the marginal self-recovery of environmental stock under certain conditions. As a second approach, we propose a tradable permit system with a permit bank, as a mechanism by which the permit interest rates are generated endogenously without governmental intervention other than the issuance of permits. However, we also show that this approach raises the problem of indeterminacy of the equilibrium. © 2013 Springer Science+Business Media Dordrecht.

A story about being engaged in research : buzzing bees, small business and Australian unfair dismissal laws

Protection for employees from unfair dismissal (UFD) has been around in Australia under various guises for 30 years or so (Chapman, 2006). Labour standards, and particularly ILO Convention 158 (Convention Concerning Termination of Employment at the Initiative of the Employer 1982), underpin the adoption of a particular form of federal statutory UFD regime which first appeared in the 1993 reforms to the Industrial Relations Act 1998 (Commonwealth). Its existence, however, has not been uncontroversial, and the meaning, operation, scope and remedies have attracted attention over time. In fact, the first reforms to the federal UFD regime were undertaken under the Keating Labor government three months after they were enacted (Chapman, ibid.). Further reforms were made by the incoming Howard Liberal-national coalition government through the Workplace Relations Act 1996 (Commonwealth) (WRA), and arguably these reforms continued down the ‘contraction’ path (ibid.).