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.

Sequencing risk : the worst returns in their worst order

For the first of the baby boomers turning 65 years of age, after a decade littered with financial shocks (dot.com bubble, sub-prime, global financial crisis, sovereign debt), sequencing risk can represent a significant threat to their retirement nest eggs. This paper takes an outcomeoriented approach to the problem, to provide practical insights into how sequencing risk works and the critical dependency of retirement outcomes on sequencing risk. Our analysis challenges the conventional wisdom that it is the accumulated average of investment returns that matter. We show, instead, that it is the realised sequence of returns which largely determines the sustainability of retirement incomes.

Towards networked governance : improving interagency communication and collaboration for disaster risk management and climate change adaptation in Australia

Major disasters, such as bushfires or floods, place significant stress on scarce public resources. Climate change is likely to exacerbate this stress. An integrated approach to disaster risk management (DRM) and climate change adaptation (CCA) could reduce the stress by encouraging the more efficient use of pooled resources and expertise. A comparative analysis of three extreme climate-related events that occurred in Australia between 2009 and 2011 indicated that a strategy to improve interagency communication and collaboration would be a key factor in this type of policy/planning integration. These findings are in accord with the concepts of Joined-up Government and Network Governance. Five key reforms are proposed: developing a shared policy vision; adopting multi-level planning; integrating legislation; networking organisations; and establishing cooperative funding. These reforms are examined with reference to the related research literature in order to identify potential problems associated with their implementation. The findings are relevant for public policy generally but are particularly useful for CCA and DRM.

Terrorism risk, resilience and volatility : a comparison of terrorism patterns in three Southeast Asian countries

Objective This article explores patterns of terrorist activity over the period from 2000 through 2010 across three target countries: Indonesia, the Philippines and Thailand. Methods We use self-exciting point process models to create interpretable and replicable metrics for three key terrorism concepts: risk, resilience and volatility, as defined in the context of terrorist activity. Results Analysis of the data shows significant and important differences in the risk, volatility and resilience metrics over time across the three countries. For the three countries analysed, we show that risk varied on a scale from 0.005 to 1.61 “expected terrorist attacks per day”, volatility ranged from 0.820 to 0.994 “additional attacks caused by each attack”, and resilience, as measured by the number of days until risk subsides to a pre-attack level, ranged from 19 to 39 days. We find that of the three countries, Indonesia had the lowest average risk and volatility, and the highest level of resilience, indicative of the relatively sporadic nature of terrorist activity in Indonesia. The high terrorism risk and low resilience in the Philippines was a function of the more intense, less clustered pattern of terrorism than what was evident in Indonesia. Conclusions Mathematical models hold great promise for creating replicable, reliable and interpretable “metrics” to key terrorism concepts such as risk, resilience and volatility.

A novel, automated nutrition screening system as a predictor of nutritional risk in an oncology day treatment unit (ODTU)

Purpose Paper-based nutrition screening tools can be challenging to implement in the ambulatory oncology setting. The aim of this study was to determine the validity of the Malnutrition Screening Tool (MST) and a novel, automated nutrition screening system compared to a ‘gold standard’ full nutrition assessment using the Patient-Generated Subjective Global Assessment (PG-SGA). Methods An observational, cross-sectional study was conducted in an outpatient oncology day treatment unit (ODTU) within an Australian tertiary health service. Eligibility criteria were as follows: ≥18 years, receiving outpatient anticancer treatment and English literate. Patients self-administered the MST. A dietitian assessed nutritional status using the PGSGA, blinded to the MST score. Automated screening system data were extracted from an electronic oncology prescribing system. This system used weight loss over 3 to 6 weeks prior to the most recent weight record or age-categorised body mass index (BMI) to identify nutritional risk. Sensitivity and specificity against PG-SGA (malnutrition) were calculated using contingency tables and receiver operating curves. Results There were a total of 300 oncology outpatients (51.7 % male, 58.6±13.3 years). The area under the curve (AUC) for weight loss alone was 0.69 with a cut-off value of ≥1 % weight loss yielding 63 % sensitivity and 76.7 % specificity. MST (score ≥2) resulted in 70.6 % sensitivity and 69.5 % specificity, AUC 0.77. Conclusions Both the MST and the automated method fell short of the accepted professional standard for sensitivity (~≥80 %) derived from the PG-SGA. Further investigation into other automated nutrition screening options and the most appropriate parameters available electronically is warranted to support targeted service provision.

A nation's role in addressing base erosion and profit shifting : sovereignty in relation to transfer pricing

The notion of sovereignty is central to any international tax issue. While a nation is free to design its tax laws as it sees fit and raise revenue in accordance with the needs of its citizens, it is not possible to undertake such a task in isolation. Tax interactions between sovereign states cannot be avoided. Ultimately, the interactions mean that a nation must decide whether or engage in both collaboration and co ordination with other nations and supranational bodies alike or maintain a unilateral stance in relation to its tax policy. This article considers a modern conceptualisation of sovereignty to argue that a move towards a more unified approach to addressing international base erosion and profit sharing may be the ultimate exercise of national fiscal sovereignty.

Knowledge transfer through dual degree programs : perspectives from Indonesian universities

The thesis provides an Indonesian perspective into the rationales and outcomes of cooperation between Indonesian and Australian universities. It demonstrates that Indonesian universities participating in this study have actively pursued their institutional agenda to bring benefits from the cooperation with the international partners and engaged in knowledge transfer with these partners to develop their capacity. It particularly investigates the knowledge transfer processes between Indonesian and Australian universities through dual degree program partnerships.

Anglican Church knew clergyman Robert Waddington was a risk

AUSTRALIAN church officials knew of child-sex allegations in Britain against a senior clergymen when they pushed a victim into accepting a compensation payout on the basis that there was no evidence to back up his claims of abuse. Former Church of England investigator Ray Morris says he prepared a 2004 report about allegations in Britain and Australia - from the 1960s and 80s - against Robert Waddington. He sent it to north Queensland diocese officials, who were at the time involved in mediation with the Australian victim over his claims that he was abused weekly by Waddington between 1964 and 1968, who was headmaster of St Barnabas boarding school in Ravenshoe, southwest of Cairns.

Genetic polymorphisms in miRNAs targeting the estrogen receptor and their effect on breast cancer risk

Breast cancer is the cancer that most commonly affects women worldwide. This type of cancer is genetically complex, but is strongly linked to steroid hormone signalling systems. Because microRNAs act as translational regulators of multiple genes, including the steroid nuclear receptors, single nucleotide polymorphisms (SNPs) in microRNAs genes can have potentially wide-ranging influences on breast cancer development. Thus, this study was conducted to investigate the relationships between six SNPs (rs6977848, rs199981120, rs185641358, rs113054794, rs66461782, and rs12940701) located in four miRNA genes predicted to target the estrogen receptor (miR-148a, miR-221, miR-186, and miR-152) and breast cancer risk in Caucasian Australian women. By using high resolution melt analysis (HRM) and polymerase chain reaction- restriction fragment length polymorphism (PCR-RFLP), 487 samples including 225 controls and 262 cases were genotyped. Analysis of their genotype and allele frequencies indicated that the differences between case and control populations was not significant for rs6977848, rs66461782, and rs12940701 because their p-values are 0.81, 0.93, 0.1 which are all above the threshold value (p=0.05). Our data thus suggests that these SNPs do not affect breast cancer risk in the tested population. In addition, rs199981120, rs185641358, and rs113054794 could not be found in this population, suggesting that these SNPs do not occur in Caucasian Australians.

The effectiveness of an intervention in reducing risk of dioxin exposure in Da Nang : changes in community knowledge, attitudes and prevention practices after 2.5 years

Introduction Environmental and biological samples taken around Da Nang Air Base have shown elevated levels of dioxin over many years [1-3]. A pre-intervention knowledge, attitudes and practices (KAP) survey (2009), a risk reduction program (2010) and a post intervention KAP survey (2011) were undertaken in four wards surrounding Danang Airbase. A follow-up evaluation was undertaken in 2013. Methods A KAP survey was implemented among 400 randomly selected food handlers. Eleven indepth interviews and four focus group discussions were also undertaken. Results The knowledge of respondents remained positive and/or improved at 2.5 years follow-up. There were no significant differences in attitudes toward preventing dioxin exposure across surveys; most respondents were positive in all three surveys. An increase in households (69.5%) undertaking measures to prevent exposure was observed, which was higher than in the pre-intervention survey (39.6%) and post- intervention survey (60.4%) (χ2 = 95.6; p < 0.001). The proportion of respondents practicing appropriate preventive measures was also significantly improved. Conclusions Despite most of the intervention program’s activities ceasing in 2010, the risk reduction program has resulted in positive outcomes over the longer-term, with many knowledge and attitude measures remaining stable or imporving. Some KAP indicators decreased, but these KAP indicators were still significantly higher than the pre-intervention levels.

The Fukushima nuclear power plant disaster and percetions of health risk communication : a case study

This case study was conducted to explore the perceptions of health risk messages sent by the Japanese Government following the Fukushima nuclear power plant disaster. The content of health risk messages from the Japanese Government and the Japanese national broadcaster (NHK) were analysed and semi-structured interviews were conducted with a sample of Tokyo residents. Initially, participants trusted these messages but as the crisis unfolded they became sceptical about the messages. Participants felt the messages did not communicate health risk information effectively because the messages were; not supported by evidence, inconsistent, delayed and changed over time. Despite widespread access to the internet, social media and mobile telephones, most participants relied on television news for information about the health risks. The Japanese Government urgently needs to re-build trust by engaging the community in the planning and development phases of health risk communication strategies.

A Cyber-Physical System Simulator for risk-free transport studies

The article introduces a novel platform for conducting controlled and risk-free driving and traveling behavior studies, called Cyber-Physical System Simulator (CPSS). The key features of CPSS are: (1) simulation of multiuser immersive driving in a threedimensional (3D) virtual environment; (2) integration of traffic and communication simulators with human driving based on dedicated middleware; and (3) accessibility of multiuser driving simulator on popular software and hardware platforms. This combination of features allows us to easily collect large-scale data on interesting phenomena regarding the interaction between multiple user drivers, which is not possible with current single-user driving simulators. The core original contribution of this article is threefold: (1) we introduce a multiuser driving simulator based on DiVE, our original massively multiuser networked 3D virtual environment; (2) we introduce OpenV2X, a middleware for simulating vehicle-to-vehicle and vehicle to infrastructure communication; and (3) we present two experiments based on our CPSS platform. The first experiment investigates the “rubbernecking” phenomenon, where a platoon of four user drivers experiences an accident in the oncoming direction of traffic. Second, we report on a pilot study about the effectiveness of a Cooperative Intelligent Transport Systems advisory system.

Prior storm experience moderates water surge perception and risk

Background How accurately do people perceive extreme water speeds and how does their perception affect perceived risk? Prior research has focused on the characteristics of moving water that can reduce human stability or balance. The current research presents the first experiment on people's perceptions of risk and moving water at different speeds and depths. Methods Using a randomized within-person 2 (water depth: 0.45, 0.90 m) ×3 (water speed: 0.4, 0.8, 1.2 m/s) experiment, we immersed 76 people in moving water and asked them to estimate water speed and the risk they felt. Results Multilevel modeling showed that people increasingly overestimated water speeds as actual water speeds increased or as water depth increased. Water speed perceptions mediated the direct positive relationship between actual water speeds and perceptions of risk; the faster the moving water, the greater the perceived risk. Participants' prior experience with rip currents and tropical cyclones moderated the strength of the actual–perceived water speed relationship; consequently, mediation was stronger for people who had experienced no rip currents or fewer storms. Conclusions These findings provide a clearer understanding of water speed and risk perception, which may help communicate the risks associated with anticipated floods and tropical cyclones.

Wind speed perception and risk

Background How accurately do people perceive extreme wind speeds and how does that perception affect the perceived risk? Prior research on human–wind interaction has focused on comfort levels in urban settings or knock-down thresholds. No systematic experimental research has attempted to assess people's ability to estimate extreme wind speeds and perceptions of their associated risks. Method We exposed 76 people to 10, 20, 30, 40, 50, and 60 mph (4.5, 8.9, 13.4, 17.9, 22.3, and 26.8 m/s) winds in randomized orders and asked them to estimate wind speed and the corresponding risk they felt. Results Multilevel modeling showed that people were accurate at lower wind speeds but overestimated wind speeds at higher levels. Wind speed perceptions mediated the direct relationship between actual wind speeds and perceptions of risk (i.e., the greater the perceived wind speed, the greater the perceived risk). The number of tropical cyclones people had experienced moderated the strength of the actual–perceived wind speed relationship; consequently, mediation was stronger for people who had experienced fewer storms. Conclusion These findings provide a clearer understanding of wind and risk perception, which can aid development of public policy solutions toward communicating the severity and risks associated with natural disasters.