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.

An Expenditure-Based Estimation of Self-Employment Income Underreporting in Finland

This paper estimates the extent of income underreporting by the self-employed in Finland using the expenditure based approach developed by Pissarides & Weber (1989). Household spending data are for the years 1994 to 1996. The results suggest that self-employment income in Finland is underreported by some 27% on average. Since income for the self-employed is about 8 % of all incomes in Finland, the size of this part of the black economy in Finland is estimated to be about 2,3% of GDP.

Income inequality in the process of economic development : An empirical approach

This thesis studies the effect of income inequality on economic growth. This is done by analyzing panel data from several countries with both short and long time dimensions of the data. Two of the chapters study the direct effect of inequality on growth, and one chapter also looks at the possible indirect effect of inequality on growth by assessing the effect of inequality on savings. In Chapter two, the effect of inequality on growth is studied by using a panel of 70 countries and a new EHII2008 inequality measure. Chapter contributes on two problems that panel econometric studies on the economic effect of inequality have recently encountered: the comparability problem associated with the commonly used Deininger and Squire s Gini index, and the problem relating to the estimation of group-related elasticities in panel data. In this study, a simple way to 'bypass' vagueness related to the use of parametric methods to estimate group-related parameters is presented. The idea is to estimate the group-related elasticities implicitly using a set of group-related instrumental variables. The estimation results with new data and method indicate that the relationship between income inequality and growth is likely to be non-linear. Chapter three incorporates the EHII2.1 inequality measure and a panel with annual time series observations from 38 countries to test the existence of long-run equilibrium relation(s) between inequality and the level of GDP. Panel unit root tests indicate that both the logarithmic EHII2.1 inequality measure and the logarithmic GDP per capita series are I(1) nonstationary processes. They are also found to be cointegrated of order one, which implies that there is a long-run equilibrium relation between them. The long-run growth elasticity of inequality is found to be negative in the middle-income and rich economies, but the results for poor economies are inconclusive. In the fourth Chapter, macroeconomic data on nine developed economies spanning across four decades starting from the year 1960 is used to study the effect of the changes in the top income share to national and private savings. The income share of the top 1 % of population is used as proxy for the distribution of income. The effect of inequality on private savings is found to be positive in the Nordic and Central-European countries, but for the Anglo-Saxon countries the direction of the effect (positive vs. negative) remains somewhat ambiguous. Inequality is found to have an effect national savings only in the Nordic countries, where it is positive.

Low-rank optimization on the cone of positive semidefinite matrices

We propose an algorithm for solving optimization problems defined on a subset of the cone of symmetric positive semidefinite matrices. This algorithm relies on the factorization X = Y Y T , where the number of columns of Y fixes an upper bound on the rank of the positive semidefinite matrix X. It is thus very effective for solving problems that have a low-rank solution. The factorization X = Y Y T leads to a reformulation of the original problem as an optimization on a particular quotient manifold. The present paper discusses the geometry of that manifold and derives a second-order optimization method with guaranteed quadratic convergence. It furthermore provides some conditions on the rank of the factorization to ensure equivalence with the original problem. In contrast to existing methods, the proposed algorithm converges monotonically to the sought solution. Its numerical efficiency is evaluated on two applications: the maximal cut of a graph and the problem of sparse principal component analysis. © 2010 Society for Industrial and Applied Mathematics.

A Direct Algorithm for the Type Interference in the Rank 2 Fragment of the Second--Order λ-Calculus

We study the problem of type inference for a family of polymorphic type disciplines containing the power of Core-ML. This family comprises all levels of the stratification of the second-order lambda-calculus by "rank" of types. We show that typability is an undecidable problem at every rank k ≥ 3 of this stratification. While it was already known that typability is decidable at rank ≤ 2, no direct and easy-to-implement algorithm was available. To design such an algorithm, we develop a new notion of reduction and show how to use it to reduce the problem of typability at rank 2 to the problem of acyclic semi-unification. A by-product of our analysis is the publication of a simple solution procedure for acyclic semi-unification.

Urbanization effects on welfare and income diversification strategies of peri-urban farm households in Tigray, Northern Ethiopia: An empirical analysis

Urban areas in many developing countries are expanding rapidly by incorporating nearby subsistence farming communities. This has a direct effect on the consumption and production behaviours of the farm households but empirical evidence is sparse. This thesis investigated the effects of rapid urbanization and the associated policies on welfare of subsistence farm households in peri-urban areas using a panel dataset from Tigray, Ethiopia. The study revealed a number of important issues emerging with the rapid urban expansion. Firstly, private asset holdings and consumption expenditure of farm households, that have been incorporated into urban administration, has decreased. Secondly, factors that influence the farm households’ welfare and vulnerability depend on the administration they belong to, urban or rural. Gender and literacy of the household head have significant roles for the urban farm households to fall back into and/or move out of poverty. However, livestock holding and share of farm income are the most important factors for rural households. Thirdly, the study discloses that farming continues to be important source of income and income diversification is the principal strategy. Participation in nonfarm employment is less for farm households in urban than rural areas. Adult labour, size of the local market and past experience in the nonfarm sector improves the likelihood of engaging in skilled nonfarm employment opportunities. But money, given as compensation for the land taken away, is not crucial for the household to engage in better paying nonfarm employments. Production behaviour of the better-off farm households is the same, regardless of the administration they belong to. However, the urban poor participate less in nonfarm employment compared to the rural poor. These findings signify the gradual development of urban-induced poverty in peri-urban areas. In the case of labour poor households, introducing urban safety net programmes could improve asset productivity and provide further protection.

Who Feels Inferior? A Test of the Status Anxiety Hypothesis of Social Inequalities in Health

The empirical association between income inequality, population health and other social problems is now well established and the research literature suggests that the relationship is not artefactual. Debate is still ongoing as to the cause of this association. Wilkinson, Marmot and colleagues have argued for some time that the relationship stems from the psycho-social effects of status comparisons. Here, income inequality is a marker of a wider status hierarchy that provokes an emotional stress response in individuals that is harmful to health and well-being. We label this the ‘status anxiety hypothesis’. If true, this would imply a structured relationship between income inequality at the societal level, individual income rank and anxiety relating to social status. This paper sets out strong and weak forms of the hypothesis and then presents three predictions concerning the structuring of ‘status anxiety’ at the individual level given different levels of national income inequality and varying individual income. We then test these predictions using data from a cross-national survey of over 34,000 individuals carried out in 2007 in 31 European countries. Respondents from low inequality countries reported less status anxiety than those in higher inequality countries at all points on the income rank curve. This is an important precondition of support for the status anxiety hypothesis and may be seen as providing support for the weaker version of the hypothesis. However, we do not find evidence to support the stronger version of the hypothesis which requires the negative effect of income rank on status anxiety to be exacerbated by increasing income inequality.

Trends in Economic Stress and the Great Recession in Ireland: An Analysis of the CSO Survey in Income and Living Conditions (SILC)

Since 2008, Ireland has experienced the most severe economic and labour market crisis since the foundation of the State. These economic and labour market changes have had a stark impact on the standard of living across the Irish population. The rapid deterioration in the labour market, the rising level of household indebtedness and stringent austerity measures to plug the public finance deficit have had a widespread impact yet there is debate about where the heaviest burden has fallen and where the economic stress has been felt most. The paper analyses data from the Survey of Income and Living Conditions for the period 2004 to 2011. The aim of the paper is to develop and test a measure of economic stress, which will capture some of the aspects of the rapid change in economic fortunes on Irish households that are not picked up by income alone. This includes tapping into features of the recession such as debt problems, unsustainable housing costs, and other difficulties associated with managing on reduced household income in a period of uncertainty. In testing such a measure we examine trends over time from boom to bust in the Irish economy and consider how economic stress is distributed across different socio-economic groups. The paper explores the distribution and level of economic stress across income class groups, social classes and the life-course and tests the thesis of ‘middle class squeeze’.

Rank estimation of trajectory matrix in motion segmentation

A novel technique for estimating the rank of the trajectory matrix in the local subspace affinity (LSA) motion segmentation framework is presented. This new rank estimation is based on the relationship between the estimated rank of the trajectory matrix and the affinity matrix built with LSA. The result is an enhanced model selection technique for trajectory matrix rank estimation by which it is possible to automate LSA, without requiring any a priori knowledge, and to improve the final segmentation

The income requirements of marine protected areas

Given the growing impact of human activities on the sea, managers are increasingly turning to marine protected areas (MPAs) to protect marine habitats and species. Many MPAs have been unsuccessful, however, and lack of income has been identified as a primary reason for failure. In this study, data from a global survey of 79 MPAs in 36 countries were analysed and attempts made to construct predictive models to determine the income requirements of any given MPA. Statistical tests were used to uncover possible patterns and relationships in the data, with two basic approaches. In the first of these, an attempt was made to build an explanatory "bottom-up" model of the cost structures that might be required to pursue various management activities. This proved difficult in practice owing to the very broad range of applicable data, spanning many orders of magnitude. In the second approach, a "top-down" regression model was constructed using logarithms of the base data, in order to address the breadth of the data ranges. This approach suggested that MPA size and visitor numbers together explained 46% of the minimum income requirements (P < 0.001), with area being the slightly more influential factor. The significance of area to income requirements was of little surprise, given its profile in the literature. However, the relationship between visitors and income requirements might go some way to explaining why northern hemisphere MPAs with apparently high incomes still claim to be under-funded. The relationship between running costs and visitor numbers has important implications not only in determining a realistic level of funding for MPAs, but also in assessing from where funding might be obtained. Since a substantial proportion of the income of many MPAs appears to be utilized for amenity purposes, a case may be made for funds to be provided from the typically better resourced government social and educational budgets as well as environmental budgets. Similarly visitor fees, already an important source of funding for some MPAs, might have a broader role to play in how MPAs are financed in the future. (C) 2007 Elsevier Ltd. All rights reserved.

Response : A defensible and workable approach to the income tax treatment of financial instruments

It is a privilege to have the opportunity to respond to the comments on my monograph1 provided by Mark Gergen, Glenn May, and Gordon Longhouse. Their comments, which are inevitably coloured by their very different perspectives, reflect the considerable expertise that each one of them has in the area of the income taxation of financial instruments. Indeed, it is with some hesitation that I offer a response in defence of various portions of the analysis presented in my monograph in support of some pretty modest proposals in this extremely difficult area of income tax law. Although I spent considerable time exploring some necessary first principles and their implications for the design of a system for the income taxation of financial instruments, I made several concessions to certain practical constraints that led me to support, in some measure, the status quo reflected in certain of the existing literature, as well as the legislation in a select group of countries. On the assumption that many readers may be unfamiliar with the monograph, I propose to respond by outlining much of my analysis in the monograph and the proposals that are the logical outcome. Throughout the outline, I will highlight and respond to what I see as the important points of difference emphasized by Gergen, May, and Longhouse.

Income security of international students in Australia

Growth in the number of international students studying in English language countries has slowed in recent years and this development has generated extended debate amongst university managers and policy makers. In these discussions much attention has focussed on whether the slow down is to be explained by currency realignments, visa requirements, the quality of education, or the increasing competitiveness of the international education market. But what has attracted little attention is the fact that when parents and students choose in which country they will purchase a foreign education their choice is commonly influenced by the level of security that is perceived to characterise the range of options. What security means can take many forms and in this paper we focus on income security. Drawing on interview data from 9 Australian universities, we clarify the sources of international student income, the extent to which these students experience income security/insecurity, how they cope with income difficulties and/or ensure finances do not become a serious problem, and whether the nature of the information provided by governments and universities helps explain the extent of income insecurity manifest amongst international students in Australia. We argue that a significant proportion of international students studying in Australia do experience income insecurity and suggest that for both moral and economic reasons the government and the university sector should pay increased attention to this aspect of student need.

Wellbeing of Australians : income security

The Australian Unity Wellbeing Index monitors the subjective wellbeing of the Australian population. Our first survey was conducted in April 2001 and this report concerns the 15th survey, undertaken in May 2006. Our previous survey had been conducted seven months earlier in October 2005. This intervening period contained a number of significant events. The first Australian terrorist threat was marked by the arrest of people in Sydney and Melbourne alleged to be plotting an attack. In December rioting took place in Sydney between Muslim and non-Muslim youths, but whether this was due more to religious differences or a ‘turf-war’ is unclear. Then, in May 2005, the new Industrial Relations legislation came into force. Each survey involves a telephone interview with a new sample of 2,000 Australians, selected to represent the national population geographic distribution. These surveys comprise the Personal Wellbeing Index, which measures people’s satisfaction with their own lives, and the National Wellbeing Index, which measures how satisfied people are with life in Australia. Other items include a standard set of demographic questions and other survey-specific questions. The specific topic for Survey 15 is the extent to which people feel that their source of income is secure.

Interjurisdictional allocation of multinational banking income : aligning taxation principles with economic activity

This thesis argues that one type of multinational entity – the multinational bank – poses particularly significant challenges to the international tax regime in terms of its current profit allocation rules. Multinational banks are a unique subset of multinational entities, and as a consequence of their unique traits, the traditional international tax regime foes not yield an optimal interjurisdictional allocation of taxing rights. The opportunity for tax minimisation, achievable because of the unique traits, and realised through exploitation of the traditional source and transfer pricing regime, results in a jurisdictional distribution of taxing rights which does not reflect economic reality. There are two distinct ways in which the traditional international tax regime fails to reflect economic activity. The first way that economic activity may not be reflected in the distribution of the taxing rights to income from multinational banking is through the application of traditional source rules. The traditional sources rules allocate income where transactions are completed rather than where the intermediation services are arranged. As a result of their unique commercial role as financial intermediaries, by separating intermediary economic activity from legal transactions with third parties, multinational banks may distort the true location of the activity giving rise to income. The second way in which the traditional tax regime may fail to reflect economic activity is through the traditional transfer pricing regime requiring related or internal transaction to be undertaken at an arm’s length price. The arm’s length pricing requirement is theoretically deficient in its failure to recognise the highly integrated nature of multinational banking. In practice, the arm’s length pricing requirement is also difficult, if not impossible, to apply to multinational banks because of the requirement of comparability. The difficulties associated with the current model have resulted in a subtle move by multinational banks towards global formulary apportionment. This thesis concludes that, for the international taxation of multinational banks, the current source regime should be replaced with a system that allocates profits for tax purposes on the basis of income source, with source determined using a unitary taxation or global formulary apportionment system. It is argued that global formulary apportionment is a theoretically superior model that provides both jurisdiction to tax and allocated profits on the basis of the economic activity that generates the income.

Income inequality: the role of impatience in a job-search process

This paper investigates the income inequality generated by a jobsearch process when di§erent cohorts of homogeneous workers are allowed to have di§erent degrees of impatience. Using the fact the average wage under the invariant Markovian distribution is a decreasing function of the time preference (Cysne (2004)), I show that the Lorenz curve and the between-cohort Gini coe¢ cient of income inequality can be easily derived in this case. An example with arbitrary measures regarding the wage o§ers and the distribution of time preferences among cohorts provides some quantitative insights into how much income inequality can be generated, and into how it varies as a function of the probability of unemployment and of the probability that the worker does not Önd a job o§er each period.