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.

A data analytics case study assessing factors affecting pavement deflection values

Road networks are a national critical infrastructure. The road assets need to be monitored and maintained efficiently as their conditions deteriorate over time. The condition of one of such assets, road pavement, plays a major role in the road network maintenance programmes. Pavement conditions depend upon many factors such as pavement types, traffic and environmental conditions. This paper presents a data analytics case study for assessing the factors affecting the pavement deflection values measured by the traffic speed deflectometer (TSD) device. The analytics process includes acquisition and integration of data from multiple sources, data pre-processing, mining useful information from them and utilising data mining outputs for knowledge deployment. Data mining techniques are able to show how TSD outputs vary in different roads, traffic and environmental conditions. The generated data mining models map the TSD outputs to some classes and define correction factors for each class.

Investigative journalism in a socially networked world

This article explores how investigative journalists can join the network society by moving online, collaborating with other reporters and media outlets across regions and across national borders, yet publishing in newspapers which arguably remain the central stage of the public sphere (Carson, 2013). A better understanding of the potential of social media and web-based communications for undertaking journalistic investigations can lead to the adoption of a global perspective, enriching local, regional and national stories (Berglez, 2013). The research and collaboration for a transnational story published simultaneously in The Australian and collaboration in London in 2013 may provide insights into the potential for the use of social media platforms and web-based communications for finding stories, collaborating and following stories into the social media to find leads to follow-up stories. This article questions whether the synergies between mainstream media and social media platforms may yield potentially high impact stories for major masthead newspapers and thus contribute to their sustainability. Connectivity with news sources has always been an important resource for journalists. Online networks may have the potential to expand the range of voices that can be heard and the issues that can be covered.

Load leveling in LV network using coordianted Energy Storage Units

This paper proposes a new distributed coordination approach to make load leveling, using Energy Storage Units (ESUs) in LV network. The proposed distributed control strategy is based on consensus algorithm which shares the required active power equally among the ESUs with respect to their rating. To show the effectiveness of the proposed approach, a typical radial LV network is simulated as a case study.

A coordinated voltage support strategy for LV network with multiple DSTATCOMs

Voltage rise and drop are the main power quality challenges in Low Voltage (LV) network with Renewable Energy (RE) generators. This paper proposes a new voltage support strategy based on coordination of multiple Distribution Static Synchronous Compensators (DSTATCOMs) using consensus algorithm. The study focuses on LV network with PV as the RE source for customers. The proposed approach applied to a typical residential LV network and its advantages are shown comparing with other voltage control strategies.

The tertiary debate : a case study analysis of factors considered when applying for university entry by traditional age school leavers in Brisbane

Many interacting factors contribute to a student's choice of a university. This study takes a systems perspective of the choice and develops a Bayesian Network to represent and quantify these factors and their interactions. The systems model is illustrated through a small study of traditional school leavers in Australia, and highlights similarities and differences between universities' perceptions of student choices, students' perceptions of factors that they should consider and how students really make choices. The study shows the range of information that can be gained from this approach, including identification of important factors and scenario assessment.

Sensor Network Based AUV Localisation

The operation of Autonomous Underwater Vehicles (AUVs) within underwater sensor network fields provides an opportunity to reuse the network infrastructure for long baseline localisation of the AUV. Computationally efficient localisation can be accomplished using off-the-shelf hardware that is comparatively inexpensive and which could already be deployed in the environment for monitoring purposes. This paper describes the development of a particle filter based localisation system which is implemented onboard an AUV in real-time using ranging information obtained from an ad-hoc underwater sensor network. An experimental demonstration of this approach was conducted in a lake with results presented illustrating network communication and localisation performance.

National curriculum reform and equipping pre-service teachers to teach about Australia in the Asian Century

Currently a range of national policy settings are reshaping schooling and teacher education in Australia. This paper presents some of the findings from a small qualitative pilot study conducted with a group of final year pre-service teachers studying a secondary social science curriculum method unit in an Australian university. One of the study’s research objectives aimed at identifying how students reflected on their capacity to navigate curriculum change and, more specifically, on teaching about Australia and Asia in the forthcoming implementation of the first national history curriculum. The unit was designed and taught by the researcher on the assumption that beginning social science teachers need to be empowered to deal with the curriculum change they’ll encounter throughout their careers. The pilot study’s methodology was informed by a constructivist approach to grounded theory and its scope was limited to one semester with volunteer students. Of the pre-service teacher reflections on their preparedness to teach, this paper reports on the content, pedagogy and learning they experienced in one segment of the unit with specific reference to the new history curriculum’s ‘Australia in a world history’ approach and the development of Asia literacy. The findings indicate that whilst pre-service teachers valued the opportunity to engage with learning experiences which enhanced their intercultural understanding and extended their pedagogical and content knowledge on campus, the nature of the final practicum in schools was also influential in shaping their preparedness to enter the profession.

GNSS ambiguity resolution with controllable failure rate for long baseline network RTK

Many large-scale GNSS CORS networks have been deployed around the world to support various commercial and scientific applications. To make use of these networks for real-time kinematic positioning services, one of the major challenges is the ambiguity resolution (AR) over long inter-station baselines in the presence of considerable atmosphere biases. Usually, the widelane ambiguities are fixed first, followed by the procedure of determination of the narrowlane ambiguity integers based on the ionosphere-free model in which the widelane integers are introduced as known quantities. This paper seeks to improve the AR performance over long baseline through efficient procedures for improved float solutions and ambiguity fixing. The contribution is threefold: (1) instead of using the ionosphere-free measurements, the absolute and/or relative ionospheric constraints are introduced in the ionosphere-constrained model to enhance the model strength, thus resulting in the better float solutions; (2) the realistic widelane ambiguity precision is estimated by capturing the multipath effects due to the observation complexity, leading to improvement of reliability of widelane AR; (3) for the narrowlane AR, the partial AR for a subset of ambiguities selected according to the successively increased elevation is applied. For fixing the scalar ambiguity, an error probability controllable rounding method is proposed. The established ionosphere-constrained model can be efficiently solved based on the sequential Kalman filter. It can be either reduced to some special models simply by adjusting the variances of ionospheric constraints, or extended with more parameters and constraints. The presented methodology is tested over seven baselines of around 100 km from USA CORS network. The results show that the new widelane AR scheme can obtain the 99.4 % successful fixing rate with 0.6 % failure rate; while the new rounding method of narrowlane AR can obtain the fix rate of 89 % with failure rate of 0.8 %. In summary, the AR reliability can be efficiently improved with rigorous controllable probability of incorrectly fixed ambiguities.

A rule-based hybrid method for anomaly detection in online-social-network graphs

Detecting anomalies in the online social network is a significant task as it assists in revealing the useful and interesting information about the user behavior on the network. This paper proposes a rule-based hybrid method using graph theory, Fuzzy clustering and Fuzzy rules for modeling user relationships inherent in online-social-network and for identifying anomalies. Fuzzy C-Means clustering is used to cluster the data and Fuzzy inference engine is used to generate rules based on the cluster behavior. The proposed method is able to achieve improved accuracy for identifying anomalies in comparison to existing methods.

Pulse-coupled neural network performance for real-time identification of vegetation during forced landing

Safety concerns in the operation of autonomous aerial systems require safe-landing protocols be followed during situations where the mission should be aborted due to mechanical or other failure. This article presents a pulse-coupled neural network (PCNN) to assist in the vegetation classification in a vision-based landing site detection system for an unmanned aircraft. We propose a heterogeneous computing architecture and an OpenCL implementation of a PCNN feature generator. Its performance is compared across OpenCL kernels designed for CPU, GPU, and FPGA platforms. This comparison examines the compute times required for network convergence under a variety of images to determine the plausibility for real-time feature detection.

Preventing pollution attacks in multi-source network coding

Network coding is a method for achieving channel capacity in networks. The key idea is to allow network routers to linearly mix packets as they traverse the network so that recipients receive linear combinations of packets. Network coded systems are vulnerable to pollution attacks where a single malicious node floods the network with bad packets and prevents the receiver from decoding correctly. Cryptographic defenses to these problems are based on homomorphic signatures and MACs. These proposals, however, cannot handle mixing of packets from multiple sources, which is needed to achieve the full benefits of network coding. In this paper we address integrity of multi-source mixing. We propose a security model for this setting and provide a generic construction.

Mechanical influences on endothelial cell network formation in vitro

While both the restoration of the blood supply and an appropriate local mechanical environment are critical for uneventful bone healing, their influence on each other remains unclear. Human bone fracture haematomas (<72h post-trauma) were cultivated for 3 days in fibrin matrices, with or without cyclic compression. Conditioned medium from these cultures enhanced the formation of vessel-like networks by HMEC-1 cells, and mechanical loading further elevated it, without affecting the cells’ metabolic activity. While haematomas released the angiogenesis-regulators, VEGF and TGF-β1, their concentrations were not affected by mechanical loading. However, direct cyclic stretching of the HMEC-1 cells decreased network formation. The appearance of the networks and a trend towards elevated VEGF under strain suggested physical disruption rather than biochemical modulation as the responsible mechanism. Thus, early fracture haematomas and their mechanical loading increase the paracrine stimulation of endothelial organisation in vitro, but direct periodic strains may disrupt or impair vessel assembly in otherwise favourable conditions.

Using a public key registry for improved trust and scalability in national E-health systems

An increasing number of countries are faced with an aging population increasingly needing healthcare services. For any e-health information system, the need for increased trust by such clients with potentially little knowledge of any security scheme involved is paramount. In addition notable scalability of any system has become a critical aspect of system design, development and ongoing management. Meanwhile cryptographic systems provide the security provisions needed for confidentiality, authentication, integrity and non-repudiation. Cryptographic key management, however, must be secure, yet efficient and effective in developing an attitude of trust in system users. Digital certificate-based Public Key Infrastructure has long been the technology of choice or availability for information security/assurance; however, there appears to be a notable lack of successful implementations and deployments globally. Moreover, recent issues with associated Certificate Authority security have damaged trust in these schemes. This paper proposes the adoption of a centralised public key registry structure, a non-certificate based scheme, for large scale e-health information systems. The proposed structure removes complex certificate management, revocation and a complex certificate validation structure while maintaining overall system security. Moreover, the registry concept may be easier for both healthcare professionals and patients to understand and trust.

Introduction to the special issue on next generation network architectures, protocols, theory, systems and applications

This special issue of Networking Science focuses on Next Generation Network (NGN) that enables the deployment of access independent services over converged fixed and mobile networks. NGN is a packet-based network and uses the Internet protocol (IP) to transport the various types of traffic (voice, video, data and signalling). NGN facilitates easy adoption of distributed computing applications by providing high speed connectivity in a converged networked environment. It also makes end user devices and applications highly intelligent and efficient by empowering them with programmability and remote configuration options. However, there are a number of important challenges in provisioning next generation network technologies in a converged communication environment. Some preliminary challenges include those that relate to QoS, switching and routing, management and control, and security which must be addressed on an urgent or emergency basis. The consideration of architectural issues in the design and pro- vision of secure services for NGN deserves special attention and hence is the main theme of this special issue.