Advance pricing arrangements : an Australian Tax Office success or a legislative failure?

Australia’s domestic income tax legislation and double tax agreements contain transfer pricing rules which are designed to counter the underpayment of tax by businesses engaged in international dealings between related parties. The current legislation and agreements require that related party transactions take place at a value which reflects an arm’s length price, that is, a price which would be charged between unrelated parties. For a host of reasons, it is increasingly difficult for multinational entities to demonstrate that they are transferring goods and services at a price which is reflective of the behaviour of independent parties, thereby making it difficult to demonstrate compliance with the relevant legislation. Further, where an Australian business undertakes cross-border related party transactions there is the risk of an audit by the Australian Tax Office (ATO). If a business wishes to avoid the risk of an audit, and any ensuing penalties, there is one option: an advance pricing arrangement (APA). An APA is an agreement whereby the future transfer pricing methodology to be used to determine the arm’s length price is agreed to by the taxpayer and the relevant tax authority or authorities. The ATO views the APA process as an important part of its international tax strategy and believes that there are complementary benefits provided to both the taxpayer and the ATO. The ATO promotes the APA process on the basis of creating greater certainty for all parties while reducing compliance costs and the risk of audit and penalty. While the ATO regards the APA system as a success, it may be argued that the implementation of such a system is simply a practical solution to an ongoing problem of an inherent failure in both the legislation and ATO interpretation and application of this legislation to provide certainty to the taxpayer. This paper investigates the use of APAs as a solution to the problem of transfer pricing and considers whether they are the success the ATO claims. It is argued that there is no doubt that APAs provide a valuable practical tool for multinational entities facing the challenges of the taxation of global trading under the current transfer pricing regime. It does not, however, provide a long term solution. Rather, the long term solution may be in the form of legislative amendment.

Meeting under the “Omei” Tree in the Torres Strait Islands : networks and funds of knowledge of mathematical ideas

This paper focuses on the turning point experiences that worked to transform the researcher during a preliminary consultation process to seek permission to conduct of a small pilot project on one Torres Strait Island. The project aimed to learn from parents how they support their children in their mathematics learning. Drawing on a community research design, a consultative meeting was held with one Torres Strait Islander community to discuss the possibility of piloting a small project that focused on working with parents and children to learn about early mathematics processes. Preliminary data indicated that parents use networks in their community. It highlighted the funds of knowledge of mathematics that exist in the community and which are used to teach their children. Such knowledges are situated within a community’s unique histories, culture and the voices of the people. “Omei” tree means the Tree of Wisdom in the Island community.

Australian children with special health care needs: Social-emotional and learning competencies in the early years

This study examined the relationship between special health care needs and social-emotional and learning competence in the early years, reporting on two waves of data from the Kindergarten Cohort of Growing up in Australia: The Longitudinal Study of Australian Children (LSAC). Six hundred and fifty children were identified through the 2-question Special Health Care Needs Screener as having special health care needs. Children with special health care needs were more likely to be male, to have been of low birth weight, to be taking prescription medications, to be diagnosed with a specific health condition and to be from families where the mother was less well educated. These children scored significantly lower on teacher-rated social-emotional and learning competencies prior to school compared to a control group of children without special health care needs. Multiple regression analyses indicated that being identified with a special health care need prior to school predicted lower social-emotional and learning competencies in the early years of school. Results are discussed in terms of the implications for policy and practice.

A longitudinal study of change in preservice teachers’ personal epistemologies

There is strong evidence to show that beliefs about knowing and knowledge held by individuals (personal epistemologies) influence preservice teachers’ learning strategies and learning outcomes (Muis, 2004). However, we know very little about how preservice teachers’ personal epistemologies change as they progress through their teacher education programs. This study investigated changes in personal epistemology and beliefs about learning for a group of preservice teachers as they progressed through the four years of a Bachelor of Education degree. Preservice teachers completed the Epistemological Beliefs Survey (EBS, Kardash & Wood, 2000) when they commenced their course (Time 1) when they were in the 3rd year of their course (Time 2) and then again in the final year of their degree (Time 3). Findings indicated that there were significant changes in preservice teachers’ personal epistemologies between course entry and the final year of their course across all but one of the dimensions measured. Results are discussed in terms of the implications for teaching and teacher education.

Books, toys and tablets : playing and learning in the age of digital media

Introduction During a recent study of how parents source information about children‘s early learning, one of us made our first serious foray into a local store licensed to the global chain Toys'R' Us. While walking the aisles, closely observing layout, signage and stock, several things became obvious. Firstly, large numbers of toys were labeled'educational'. Secondly, many toys in that category were intended for children under the age of two years. These were further differentiated as intended for 'babies' or 'infants', and sub-categorized on packaging or shelving using even smaller age increments (e.g. 0-3 months, 12-18 months, and so on). Thirdly, many products were labeled as 'interactive' and 'learning' toys that promised to assist children‘s early learning and development. The activation of some of these toys relied on embedded computer chip technology and promised to 'connect' children with the home television, computer and the Internet. These products were hybrids between a toy and a platform for digital media interaction. Closer inspection of toy packaging and other promotional material suggested that industry had begun to invest heavily in developing highly differentiated children‘s markets for products that yoked together concepts of learning and development, the 'fun toy' that incorporates digital technology, and offline- and online participation. In this chapter we explore the growth of this contemporary cultural phenomenon that now connects books, toys and mobile digital media with children‘s play and learning.

Choosing work and care : four Australian women negotiating return to paid work in the first year of motherhood

Australian women make decisions about return to paid work and care for their child within a policy environment that presents mixed messages about maternal employment and child care standards. Against this background an investigation of first-time mothers’ decision-making about workforce participation and child care was undertaken. Four women were studied from pregnancy through the first postnatal year using interview and diary methods. Inductive analyses identified three themes, all focused on dimensions of family security: financial security relating to family income, emotional security relating to child care quality, and pragmatic security relating to child care access. The current policy changes that aim to increase child care quality standards in Australia present a positive step toward alleviating family insecurities but are insufficient to alleviate the evidently high levels of tension between workforce participation and family life experienced by women transitioning back into the workforce in Australia.

An examination of tax-deductible donations made by individual taxpayers in Australia for 1997/98

This paper analyses the amount and type of tax-deductible donations made by Australian taxpayers to charities for the period 1 July 1997 to 30 June 1998. The information has been extracted from the Australian Taxation Office's publication Taxation Statistics 1997-98 which provides an overview and profile of the income and taxation status of Australian taxpayers using information extracted from their income tax returns for the period 1 July 1997 to 30 June 1998. This report is the latest publicly available summary. At the time of writing.