Double tax agreements and the international allocation of business income in Australia

Increasingly, the effectiveness of the present system of taxation of international businesses is being questioned. The problem associated with the taxation of such businesses is twofold. A system of international taxation must be a fair and equitable system, distributing profits between the relevant jurisdictions and, in doing so, avoiding double taxation. At the same time, the prevention of fiscal evasion must be secured. In an attempt to achieve a fair and equitable system Australia adopts unilateral, bilateral and multilateral measures to avoid double taxation and restrict the avoidance of tax. The first step in ascertaining the international allocation of business income is to consider the taxation of business income according to domestic law, that is, the unilateral measures. The treatment of international business income under the Australian domestic law, that is, the Income Tax Assessment Act 1936 (Cth) and Income Tax Assessment Act 1997 (Cth), will depend on two concepts, first, whether the taxpayer is a resident of Australia and secondly, whether the income is sourced in Australia. After the taxation of business profits has been determined according to domestic law it is necessary to consider the applicability of the bilateral measures, that is, the Double Tax Agreements (DTAs) to which Australia is a party, as the DTAs will override the domestic law where there is any conflict. Australia is a party to 40 DTAs with another seven presently being negotiated. The preamble to Australia's DTAs provides that the purpose of such agreements is 'to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income'. Both purposes, for different reasons, are equally important. It has been said that: The taxpayer hopes the treaty will prevent the double taxation of his income; the tax gatherer hopes the treaty will prevent fiscal evasion; and the politician just hopes. The first purpose, the avoidance of double taxation, is achieved through the provision of rules whereby the Contracting States agree to the classification of income and the allocation of that income to a particular State. In this sense DTAs do not allocate jurisdiction to tax but rather provide an arrangement whereby the States agree to restrict their substantive law. The restriction is either through the non-taxing of the income or via the provision of a tax credit.

Business process variability modeling : A survey

It is common for organizations to maintain multiple variants of a given business process, such as multiple sales processes for different products or multiple bookkeeping processes for different countries. Conventional business process modeling languages do not explicitly support the representation of such families of process variants. This gap triggered significant research efforts over the past decade leading to an array of approaches to business process variability modeling. This survey examines existing approaches in this field based on a common set of criteria and illustrates their key concepts using a running example. The analysis shows that existing approaches are characterized by the fact that they extend a conventional process mod- eling language with constructs that make it able to capture customizable process models. A customizable process model represents a family of process variants in a way that each variant can be derived by adding or deleting fragments according to configuration parameters or according to a domain model. The survey puts into evidence an abundance of customizable process modeling languages, embodying a diverse set of con- structs. In contrast, there is comparatively little tool support for analyzing and constructing customizable process models, as well as a scarcity of empirical evaluations of languages in the field.

Indigenous/digital heterogeneities : an actor-network-theory approach

This thesis analysed the theoretical and ontological issues of previous scholarship concerning information technology and indigenous people. As an alternative, the thesis used the framework of actor-network-theory, especially through historiographical and ethnographic techniques. The thesis revealed an assemblage of indigenous/digital enactments striving for relevance and avoiding obsolescence. It also recognised heterogeneities- including user-ambivalences, oscillations, noise, non-coherences and disruptions - as part of the milieu of the daily digital lives of indigenous people. By taking heterogeneities into account, the thesis ensured that the data “speaks for itself” and that social inquiry is not overtaken by ideology and ontology.

An investigation into painting's transformation and regeneration through post-photographic intervention in the digital archive

This PhD practice-led research inquiry sets out to examine and describe how the fluid interactions between memory and time can be rendered via the remediation of my painting and the construction of a digital image archive. My abstract digital art and handcrafted practice is informed by Deleuze and Guattari’s rhizomics of becoming. I aim to show that the technological mobility of my creative strategies produce new conditions of artistic possibility through the mobile principles of rhizomic interconnection, multiplicity and diversity. Subsequently through the ongoing modification of past painting I map how emergent forms and ideas open up new and incisive engagements with the experience of a ‘continual present’. The deployment of new media and cross media processes in my art also deterritorialises the modernist notion of painting as a static and two dimensional spatial object. Instead, it shows painting in a postmodern field of dynamic and transformative intermediality through digital formats of still and moving images that re-imagines the relationship between memory, time and creative practice.

Hybrid placemaking in the library : designing digital technology to enhance users’ on-site experience

This paper presents research findings and design strategies that illustrate how digital technology can be applied as a tool for hybrid placemaking in ways that would not be possible in purely digital or physical space. Digital technology has revolutionised the way people learn and gather new information. This trend has challenged the role of the library as a physical place, as well as the interplay of digital and physical aspects of the library. The paper provides an overview of how the penetration of digital technology into everyday life has affected the library as a place, both as designed by place makers, and, as perceived by library users. It then identifies a gap in current library research about the use of digital technology as a tool for placemaking, and reports results from a study of Gelatine – a custom built user check-in system that displays real-time user information on a set of public screens. Gelatine and its evaluation at The Edge, at State Library of Queensland illustrates how combining affordances of social, spatial and digital space can improve the connected learning experience among on-site visitors. Future design strategies involving gamifying the user experience in libraries are described based on Gelatine’s infrastructure. The presented design ideas and concepts are relevant for managers and designers of libraries as well as other informal, social learning environments.

The Indigenous digital collectif : the case among the iTadian of Northern Philippines

This paper reports on an adaptation of Callon and Law’s (1995) hybrid collectif derived from research conducted on the usage of mobile phones and internet technologies among the iTadian indigenous people of the Cordillera region, northern Philippines. Results brings to light an indigenous digital collectif—an emergent effect from the translation of both human and non-human heterogeneous actors as well as pre-existent networks, such as: traditional knowledge and practices, kinship relations, the traditional exchange of goods, modern academic requisites, and advocacies for indigenous rights. This is evinced by the iTadian’s enrolment of internet and mobile phone technologies. Examples include: treating these technologies as an efficient communicative tool, an indicator of well-being, and a portable extension of affective human relationships. Alternatively, counter-enrolment strategies are also at play, which include: establishing rules of acceptable use on SMS texting and internet access based on traditional notions of discretion, privacy, and the customary treatment of the dead. Within the boundaries of this digital collectif reveal imbrications of pre-existing networks like traditional customs, the kinship system across geophysical boundaries, the traditional exchange of mail and other goods, and the advocacy of indigenous rights. These imbrications show that the iTadian digital collectif fluently configures itself to a variety of networked ontologies without losing its character.

Hybrid place : blurring the edge between the digital and physical layers of urban environments

The purpose of this paper is to investigate the edge condition between the digital layers and the physical layers of the city and how tangible expressions of the interrelationships between them to create and define new experiences of place, creating hybrid place. To date there has been discussion and investigation into understanding the importance of place, similarly into defining hybrid space. This paper explores principles of place and space to question how they can be applied into defining and proposing the notion of hybrid place in urban environments. The integration of media spaces into architecture provide infrastructure for the development of hybrid place. The physical boundaries of urban spaces become blurred through the integration of media such as computer technologies connecting the physical environment with the digital. Literature and case studies that reflect the current trends of use of technology by people in space and place within urban environments are examined.

The remediation of the personal photograph and the politics of self-representation in digital storytelling

Over the past couple of decades, the cultural field formerly known as ‘domestic’, and later ‘personal’ photography has been remediated and transformed as part of the social web, with its convergence of personal expression, interpersonal communication, and online social networks (most recently via platforms like Flickr, Facebook and Twitter). Meanwhile, the Digital Storytelling movement (involving the workshop-based production of short autobiographical videos) from its beginnings in the mid 1990s relied heavily on the narrative power of the personal photograph, often sourced from family albums, and later from online archives. This paper addresses the new issues arising for the politics of self-representation and personal photography in the era of social media, focusing particularly on the consequences of online image-sharing. It discusses in detail the practices of selection, curation, manipulation and editing of personal photographic images among a group of activist-oriented queer digital storytellers who have in common a stated desire to share their personal stories in pursuit of social change, and whose stories often aim to address both intimate and antagonistic publics.

The embodied hybrid space : designing social and digital interventions to facilitate connected learning in coworking spaces

This thesis developed and evaluated strategies for social and ubiquitous computing designs that can enhance connected learning and networking opportunities for users in coworking spaces. Based on a social and a technical design intervention deployed at the State Library of Queensland, the research findings illustrate the potential of combining social, spatial and digital affordances in order to nourish peer-to-peer learning, creativity, inspiration, and innovation. The study proposes a hybrid notion of placemaking as a new way of thinking about the design of coworking and interactive learning spaces.