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.

Adoption of innovative products on Australian road infrastructure projects

Product innovation is an important contributor to the performance of infrastructure projects in the construction industry. Maximizing the potential for innovative product adoption is a challenging task due to the complexities of the construction innovation system. A qualitative methodology involving interviews with major construction project stakeholders is employed to address the research question: ‘What are the main obstacles to the adoption of innovative products in the road industry?’ The characteristics of six key product innovation obstacles in Australian road projects are described. The six key obstacles are: project goal misalignment, client pressures, weak contractual relations, lack of product trialling, inflexible product specifications and product liability concerns. A snapshot of the dynamics underlying these obstacles is provided. There are few such assessments in the literature, despite the imperative to improve construction innovation rates globally in order to deliver road infrastructure projects of increasing size and complexity. Key obstacles are interpreted through an open innovation construct, providing direction for policy to enhance the uptake of innovation across the construction product supply network. Early evidence suggests the usefulness of an open innovation construct that integrates three conceptual lenses: network governance, absorptive capacity and knowledge intermediation, in order to interpret product adoption obstacles in the context of Australian road infrastructure projects. The paper also provides practical advice and direction for government and industry organizations that wish to promote the flow of innovative product knowledge across the construction supply network.

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.

One more tier, no more tears: Students’ perceptions of QUT Library’s 2nd tier learning and study support

This nuts and bolts session discusses QUT Library’s Study Solutions service which is staffed by academic skills advisors and librarians as the 2nd tier of its learning and study support model. Firstly, it will discuss the rationale behind the Study Solutions model and provide a brief profile of the service. Secondly, it will outline what distinguishes it from other modes of one-to-one learning support. Thirdly, it will report findings from a student perception study conducted to determine what difference this model of individual study assistance made to academic confidence, ability to transfer academic skills and capacity to assist peers. Finally, this session will include small group discussions to consider the feasibility of this model as best practice for other tertiary institutions and student perception as a valuable measure of the impact of learning support services.

Perceiving and pursuing novelty : a grounded theory of adolescent creativity

Creativity plays an increasingly important role in our personal, social, educational, and community lives. For adolescents, creativity can enable self-expression, be a means of pushing boundaries, and assist learning, achievement, and completion of everyday tasks. Moreover, adolescents who demonstrate creativity can potentially enhance their capacity to face unknown future challenges, address mounting social and ecological issues in our global society, and improve their career opportunities and contribution to the economy. For these reasons, creativity is an essential capacity for young people in their present and future, and is highlighted as a priority in current educational policy nationally and internationally. Despite growing recognition of creativity’s importance and attention to creativity in research, the creative experience from the perspectives of the creators themselves and the creativity of adolescents are neglected fields of study. Hence, this research investigated adolescents’ self-reported experiences of creativity to improve understandings of their creative processes and manifestations, and how these can be supported or inhibited. Although some aspects of creativity have been extensively researched, there were no comprehensive, multidisciplinary theoretical frameworks of adolescent creativity to provide a foundation for this study. Therefore, a grounded theory methodology was adopted for the purpose of constructing a new theory to describe and explain adolescents’ creativity in a range of domains. The study’s constructivist-interpretivist perspective viewed the data and findings as interpretations of adolescents’ creative experiences, co-constructed by the participants and the researcher. The research was conducted in two academically selective high schools in Australia: one arts school, and one science, mathematics, and technology school. Twenty adolescent participants (10 from each school) were selected using theoretical sampling. Data were collected via focus groups, individual interviews, an online discussion forum, and email communications. Grounded theory methods informed a process of concurrent data collection and analysis; each iteration of analysis informed subsequent data collection. Findings portray creativity as it was perceived and experienced by participants, presented in a Grounded Theory of Adolescent Creativity. The Grounded Theory of Adolescent Creativity comprises a core category, Perceiving and Pursuing Novelty: Not the Norm, which linked all findings in the study. This core category explains how creativity involved adolescents perceiving stimuli and experiences differently, approaching tasks or life unconventionally, and pursuing novel ideas to create outcomes that are not the norm when compared with outcomes by peers. Elaboration of the core category is provided by the major categories of findings. That is, adolescent creativity entailed utilising a network of Sub-Processes of Creativity, using strategies for Managing Constraints and Challenges, and drawing on different Approaches to Creativity – adaptation, transfer, synthesis, and genesis – to apply the sub-processes and produce creative outcomes. Potentially, there were Effects of Creativity on Creators and Audiences, depending on the adolescent and the task. Three Types of Creativity were identified as the manifestations of the creative process: creative personal expression, creative boundary pushing, and creative task achievement. Interactions among adolescents’ dispositions and environments were influential in their creativity. Patterns and variations of these interactions revealed a framework of four Contexts for Creativity that offered different levels of support for creativity: high creative disposition–supportive environment; high creative disposition–inhibiting environment; low creative disposition–supportive environment; and low creative disposition–inhibiting environment. These contexts represent dimensional ranges of how dispositions and environments supported or inhibited creativity, and reveal that the optimal context for creativity differed depending on the adolescent, task, domain, and environment. This study makes four main contributions, which have methodological and theoretical implications for researchers, as well as practical implications for adolescents, parents, teachers, policy and curriculum developers, and other interested stakeholders who aim to foster the creativity of adolescents. First, this study contributes methodologically through its constructivist-interpretivist grounded theory methodology combining the grounded theory approaches of Corbin and Strauss (2008) and Charmaz (2006). Innovative data collection was also demonstrated through integration of data from online and face-to-face interactions with adolescents, within the grounded theory design. These methodological contributions have broad applicability to researchers examining complex constructs and processes, and with populations who integrate multimedia as a natural form of communication. Second, applicable to creativity in diverse domains, the Grounded Theory of Adolescent Creativity supports a hybrid view of creativity as both domain-general and domain-specific. A third major contribution was identification of a new form of creativity, educational creativity (ed-c), which categorises creativity for learning or achievement within the constraints of formal educational contexts. These theoretical contributions inform further research about creativity in different domains or multidisciplinary areas, and with populations engaged in formal education. However, the key contribution of this research is that it presents an original Theory and Model of Adolescent Creativity to explain the complex, multifaceted phenomenon of adolescents’ creative experiences.

Benefits of publicly available data

The National Morbidity, Mortality, and Air Pollution Study (NMMAPS) was designed to examine the health effects of air pollution in the United States. The primary question was whether particulate matter was responsible for the associations between air pollution and daily mortality. Secondary questions concerned measurement error in air pollution and mortality displacement.1 Since then, NMMAPS has been used to answer many important questions in environmental epidemiology...

Analysis and correction of voltage profile in low voltage distribution networks containing photovoltaic cells and electric vehicles

Voltage drop and rise at network peak and off–peak periods along with voltage unbalance are the major power quality problems in low voltage distribution networks. Usually, the utilities try to use adjusting the transformer tap changers as a solution for the voltage drop. They also try to distribute the loads equally as a solution for network voltage unbalance problem. On the other hand, the ever increasing energy demand, along with the necessity of cost reduction and higher reliability requirements, are driving the modern power systems towards Distributed Generation (DG) units. This can be in the form of small rooftop photovoltaic cells (PV), Plug–in Electric Vehicles (PEVs) or Micro Grids (MGs). Rooftop PVs, typically with power levels ranging from 1–5 kW installed by the householders are gaining popularity due to their financial benefits for the householders. Also PEVs will be soon emerged in residential distribution networks which behave as a huge residential load when they are being charged while in their later generation, they are also expected to support the network as small DG units which transfer the energy stored in their battery into grid. Furthermore, the MG which is a cluster of loads and several DG units such as diesel generators, PVs, fuel cells and batteries are recently introduced to distribution networks. The voltage unbalance in the network can be increased due to the uncertainties in the random connection point of the PVs and PEVs to the network, their nominal capacity and time of operation. Therefore, it is of high interest to investigate the voltage unbalance in these networks as the result of MGs, PVs and PEVs integration to low voltage networks. In addition, the network might experience non–standard voltage drop due to high penetration of PEVs, being charged at night periods, or non–standard voltage rise due to high penetration of PVs and PEVs generating electricity back into the grid in the network off–peak periods. In this thesis, a voltage unbalance sensitivity analysis and stochastic evaluation is carried out for PVs installed by the householders versus their installation point, their nominal capacity and penetration level as different uncertainties. A similar analysis is carried out for PEVs penetration in the network working in two different modes: Grid to vehicle and Vehicle to grid. Furthermore, the conventional methods are discussed for improving the voltage unbalance within these networks. This is later continued by proposing new and efficient improvement methods for voltage profile improvement at network peak and off–peak periods and voltage unbalance reduction. In addition, voltage unbalance reduction is investigated for MGs and new improvement methods are proposed and applied for the MG test bed, planned to be established at Queensland University of Technology (QUT). MATLAB and PSCAD/EMTDC simulation softwares are used for verification of the analyses and the proposals.

Managing open incremental process innovation : absorptive capacity and distributed learning

In this conceptual article, we extend earlier work on Open Innovation and Absorptive Capacity. We suggest that the literature on Absorptive Capacity does not place sufficient emphasis on distributed knowledge and learning or on the application of innovative knowledge. To accomplish physical transformations, organisations need specific Innovative Capacities that extend beyond knowledge management. Accessive Capacity is the ability to collect, sort and analyse knowledge from both internal and external sources. Adaptive Capacity is needed to ensure that new pieces of equipment are suitable for the organisation's own purposes even though they may have been originally developed for other uses. Integrative Capacity makes it possible for a new or modified piece of equipment to be fitted into an existing production process with a minimum of inessential and expensive adjustment elsewhere in the process. These Innovative Capacities are controlled and coordinated by Innovative Management Capacity, a higher-order dynamic capability.

Not-for-profit ratios for financial resilience and internal accountability : a study of Australian international aid organisations

Not-for-profit (NFP) financial ratio research has focused primarily on organisational efficiency measurements for external stakeholders. Ratios that also capture information about stability, capacity (liquidity), gearing and sustainability, enable an assessment of financial resilience. They are thus valuable tools that can provide a framework of internal accountability between boards and management. The establishment of an Australian NFP regulator highlights the importance of NFP sustainability, and affirms the timeliness of this paper. We propose a suite of key financial ratios for use by NFP boards and management, and demonstrate its practical usefulness by applying the ratios to financial data from the 2009 reports of ACFID (Australian Council for International Development)-affiliated international aid organisations.

Simple rules to contain an invasive species with a complex life cycle and high dispersal capacity

Designing practical rules for controlling invasive species is a challenging task for managers, particularly when species are long-lived, have complex life cycles and high dispersal capacities. Previous findings derived from plant matrix population analyses suggest that effective control of long-lived invaders may be achieved by focusing on killing adult plants. However, the cost-effectiveness of managing different life stages has not been evaluated. We illustrate the benefits of integrating matrix population models with decision theory to undertake this evaluation, using empirical data from the largest infestation of mesquite (Leguminosae: Prosopis spp) within Australia. We include in our model the mesquite life cycle, different dispersal rates and control actions that target individuals at different life stages with varying costs, depending on the intensity of control effort. We then use stochastic dynamic programming to derive cost-effective control strategies that minimize the cost of controlling the core infestation locally below a density threshold and the future cost of control arising from infestation of adjacent areas via seed dispersal. Through sensitivity analysis, we show that four robust management rules guide the allocation of resources between mesquite life stages for this infestation: (i) When there is no seed dispersal, no action is required until density of adults exceeds the control threshold and then only control of adults is needed; (ii) when there is seed dispersal, control strategy is dependent on knowledge of the density of adults and large juveniles (LJ) and broad categories of dispersal rates only; (iii) if density of adults is higher than density of LJ, controlling adults is most cost-effective; (iv) alternatively, if density of LJ is equal or higher than density of adults, management efforts should be spread between adults, large and to a lesser extent small juveniles, but never saplings. Synthesis and applications.In this study, we show that simple rules can be found for managing invasive plants with complex life cycles and high dispersal rates when population models are combined with decision theory. In the case of our mesquite population, focussing effort on controlling adults is not always the most cost-effective way to meet our management objective.