A nation’s role in addressing base erosion and profit shifting : balancing sovereignty with international collaboration and coordination

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. In a world of cross-border investments and business transactions, all tax regimes impact on one another. Tax interactions between sovereign states cannot be avoided. Ultimately, the interactions mean that a nation must decide whether to engage in both collaboration and coordination with other nations and supranational bodies alike or maintain an individualised stance in relation to its tax policy. Whatever the decision, there is arguably an exercise in national sovereignty in some form. In the context of an international tax regime, whether that regime is interpreted broadly as meaning international norms generally adopted by nations around the world or domestic regimes legislating for cross-border transactions, rhetoric around national fiscal sovereignty takes on many different forms. At one end of the spectrum it is relied upon by financial secrecy jurisdictions (tax havens) as a defence to their position on the basis that ‘other’ nations cannot interfere with the fiscal sovereignty of a jurisdiction. At the other end of the spectrum, it is argued that profit shifting and international tax avoidance if not stopped is, in and of itself, a threat to a nation’s fiscal sovereignty on the basis that it threatens the ability to tax and raise the revenue needed. This paper considers a modern conceptualisation of sovereignty along with its role within international tax coordination and collaboration to argue that a move towards a more unified approach to addressing international base erosion and profit shifting may be the ultimate exercise of national fiscal sovereignty. By using the current transfer pricing regime as a case study, this paper posits that it is not merely enough to have international agreement on allocation rules to be applied, but that the ultimate exercise of national sovereignty is political agreement with other states to ensure that it is governments which determine the allocational basis of worldwide profits to be taxed. In doing so, it is demonstrated that the arm’s length pricing requirement of the current transfer pricing regime, rather than providing governments with the ability to determine the location of profits, is providing multinational entities with the ultimate power to determine that location. If left unchecked, this will eventually erode a nation’s ability to capture the required tax revenue and, as a consequence, may be deemed a failure by nation states to exercise their fiscal sovereignty.

Investigation of the effects of various types of wind turbine generators on power-system stability

It has become more and more demanding to investigate the impacts of wind farms on power system operation as ever-increasing penetration levels of wind power have the potential to bring about a series of dynamic stability problems for power systems. This paper undertakes such an investigation through investigating the small signal and transient stabilities of power systems that are separately integrated with three types of wind turbine generators (WTGs), namely the squirrel cage induction generator (SCIG), the doubly fed induction generator (DFIG), and the permanent magnet generator (PMG). To examine the effects of these WTGs on a power system with regard to its stability under different operating conditions, a selected synchronous generator (SG) of the well-known Western Electricity Coordinating Council (WECC three-unit nine-bus system and an eight-unit 24-bus system is replaced in turn by each type of WTG with the same capacity. The performances of the power system in response to the disturbances are then systematically compared. Specifically, the following comparisons are undertaken: (1) performances of the power system before and after the integration of the WTGs; and (2) performances of the power system and the associated consequences when the SCIG, DFIG, or PMG are separately connected to the system. These stability case studies utilize both eigenvalue analysis and dynamic time-domain simulation methods.

Development route of the wind power industry in China

Wind power is one of the world's major renewable energy sources, and its utilization provides an important contribution in helping solve the energy problems of many countries. After nearly 40 years of development, China's wind power industry now not only manufactures its own massive six MW turbines but also has the largest capacity in the world with a national output of 50 million MW•h in 2010 and set to rise by eight times of that amount by 2020. This paper investigates this development route by analyzing relevant academic literature, statistics, laws and regulations, policies and research and industry reports. The main drivers of the development in the industry are identified as technologies, turbines, wind farm construction, pricing mechanism and government support systems, each of which is also divided into different stages with distinctive features. A systematic review of these aspects provides academics and practitioners with a better understanding of the history of the wind power industry in China and reasons for its rapid development with a view to enhancing progress in wind power development both in China and the world generally.

Digital tablets as a tool for blended learning in power engineering education

Digital tablets have been identified as a tool for enabling blended learning and supporting online teaching and learning. A small scale trial was undertaken to assess the effectiveness of this technology when applied to power engineering education. Critical findings and experiences gained from this trial, including potential benefits, presentation techniques and the resulting student feedback are presented in this paper.

Wide-area control of aggregated power systems

This paper proposes a new method for stabilizing disturbed power systems using wide area measurement and FACTS devices. The approach focuses on both first swing and damping stability of power systems following large disturbances. A two step control algorithm based on Lyapunov Theorem is proposed to be applied on the controllers to improve the power systems stability. The proposed approach is simulated on two test systems and the results show significant improvement in the first swing and damping stability of the test systems.

Identification of reduced models of power system areas using phasor measurement units

In this paper an approach is presented for identification of a reduced model for coherent areas in power systems using phasor measurement units to represent the inter-area oscillations of the system. The generators which are coherent in a wide range of operating conditions form the areas in power systems and the reduced model is obtained by representing each area by an equivalent machine. The reduced nonlinear model is then identified based on the data obtained from measurement units. The simulation is performed on three test systems and the obtained results show high accuracy of identification process.