The traditional rationale of the arm’s length approach to transfer pricing : should the separate accounting model be maintained for modern multinational entities?

This article examines the current transfer pricing regime to consider whether it is a sound model to be applied to modern multinational entities. The arm's length price methodology is examined to enable a discussion of the arguments in favour of such a regime. The article then refutes these arguments concluding that, contrary to the very reason multinational entities exist, applying arm's length rules involves a legal fiction of imagining transactions between unrelated parties. Multinational entities exist to operate in a way that independent entities would not, which the arm's length rules fail to take into account. As such, there is clearly an air of artificiality in applying the arm's length standard. To demonstrate this artificiality with respect to modern multinational entities, multinational banks are used as an example. The article concluded that the separate entity paradigm adopted by the traditional transfer pricing regime is incongruous with the economic theory of modern multinational enterprises.

Reply to Camens : how recently did modern monotremes diversify?

Camens (1) responds to our analysis of morphological data (2) in which platypuses (Ornithorhynchidae) and echidnas (Tachyglossidae) were inferred to be each other's closest relatives, to the exclusion of Early Cretaceous forms, Teinolophos and Steropodon. Our phylogeny is consistent with the late appearance of undisputed fossil echidnas and platypuses. Molecular dating provided important independent corroboration, revealing that platypuses and echidnas diverged only 19–48 Ma, implying that Teinolophos and Steropodon (105–121 Ma) must lie outside the platypus–echidna dichotomy...

Strolling through the (post)modern city: Modes of being a flaneur in picture books

The city and the urban condition, popular subjects of art, literature, and film, have been commonly represented as fragmented, isolating, violent, with silent crowds moving through the hustle and bustle of a noisy, polluted cityspace. Included in this diverse artistic field is children’s literature—an area of creative and critical inquiry that continues to play a central role in illuminating and shaping perceptions of the city, of city lifestyles, and of the people who traverse the urban landscape. Fiction’s textual representations of cities, its sites and sights, lifestyles and characters have drawn on traditions of realist, satirical, and fantastic writing to produce the protean urban story—utopian, dystopian, visionary, satirical—with the goal of offering an account or critique of the contemporary city and the urban condition. In writing about cities and urban life, children’s literature variously locates the child in relation to the social (urban) space. This dialogic relation between subject and social space has been at the heart of writings about/of the flâneur: a figure who experiences modes of being in the city as it transforms under the influences of modernism and postmodernism. Within this context of a changing urban ontology brought about by (post)modern styles and practices, this article examines five contemporary picture books: The Cows Are Going to Paris by David Kirby and Allen Woodman; Ooh-la-la (Max in love) by Maira Kalman; Mr Chicken Goes to Paris and Old Tom’s Holiday by Leigh Hobbs; and The Empty City by David Megarrity. I investigate the possibility of these texts reviving the act of flânerie, but in a way that enables different modes of being a flâneur, a neo-flâneur. I suggest that the neo-flâneur retains some of the characteristics of the original flâneur, but incorporates others that take account of the changes wrought by postmodernity and globalization, particularly tourism and consumption. The dual issue at the heart of the discussion is that tourism and consumption as agents of cultural globalization offer a different way of thinking about the phenomenon of flânerie. While the flâneur can be regarded as the precursor to the tourist, the discussion considers how different modes of flânerie, such as the tourist-flâneur, are an inevitable outcome of commodification of the activities that accompany strolling through the (post)modern urban space.

Sustainable, smart, safe : a 3'S' approach towards a modern transportation system

Sustainability, smartness and safety are three sole components of a modern transportation system. The objective of this study is to introduce a modern transportation system in the light of a 3‘S’ approach: sustainable, smart and safe. In particular this paper studies the transportation system of Singapore to address how this system is progressing in this three-pronged approach towards a modern transportation system. While sustainability targets environmental justice and social equity without compromising economical efficiency, smartness incorporates qualities like automated sensing, processing and decision making, and action-taking into the transportation system. Since a system cannot be viable without being safe, the safety of the modern transportation system aims minimizing crash risks of all users including motorists, motorcyclists, pedestrians, and bicyclists. Various policy implications and technology applications inside the transportation system of Singapore are discussed to illustrate a modern transportation system within the framework of the 3‘S’ model.

Challenges to environmental toxicology and epidemiology : where do we stand and which way do we go?

Modern toxicology investigates a wide array of both old and new health hazards. Priority setting is needed to select agents for research from the plethora of exposure circumstances. The changing societies and a growing fraction of the aged have to be taken into consideration. A precise exposure assessment is of importance for risk estimation and regulation. Toxicology contributes to the exploration of pathomechanisms to specify the exposure metrics for risk estimation. Combined effects of co-existing agents are not yet sufficiently understood. Animal experiments allow a separate administration of agents which can not be disentangled by epidemiological means, but their value is limited for low exposure levels in many of today’s settings. As an experimental science, toxicology has to keep pace with the rapidly growing knowledge about the language of the genome and the changing paradigms in cancer development. During the pioneer era of assembling a working draft of the human genome, toxicogenomics has been developed. Gene and pathway complexity have to be considered when investigating gene–environment interactions. For a best conduct of studies, modern toxicology needs a close liaison with many other disciplines like epidemiology and bioinformatics.

The dual orexin/hypocretin receptor antagonist, almorexant, in the ventral tegmental area attenuates ethanol self-administration

Recent studies have implicated the hypocretin/orexinergic system in reward-seeking behavior. Almorexant, a dual orexin/hypocretin R1 and R2 receptor antagonist, has proven effective in preclinical studies in promoting sleep in animal models and was in Phase III clinical trials for sleep disorders. The present study combines behavioral assays with in vitro biochemical and electrophysiological techniques to elucidate the role of almorexant in ethanol and sucrose intake. Using an operant self-administration paradigm, we demonstrate that systemic administration of almorexant decreased operant selfadministration of both 20% ethanol and 5% sucrose. We further demonstrate that intraventral tegmental area (VTA) infusions, but not intra substantia nigra infusions, of almorexant reduced ethanol self-administration. Extracellular recordings performed in VTA neurons revealed that orexin-A increased firing and this enhancement of firing was blocked by almorexant. The results demonstrate that orexin/hypocretin receptors in distinct brain regions regulate ethanol and sucrose mediated behaviors.

Physical access control administration using building information models

Physical access control systems play a central role in the protection of critical infrastructures, where both the provision of timely access and preserving the security of sensitive areas are paramount. In this paper we discuss the shortcomings of existing approaches to the administration of physical access control in complex environments. At the heart of the problem is the current dependency on human administrators to reason about the implications of the provision or the revocation of staff access to an area within these facilities. We demonstrate how utilising Building Information Models (BIMs) and the capabilities they provide, including 3D representation of a facility and path-finding can reduce possible intentional or accidental errors made by security administrators.

An interview with Jacques Rancière : on medium-specificity and discipline crossovers in modern art

Jacques Rancière's work on aesthetics has received a great deal of attention in recent years. Given his work has enormous range – covering art and literature, political theory, historiography, pedagogy and worker's history – Andrew McNamara and Toni Ross (UNSW) explore his wider critical ambitions in this interview, while showing how it leads to alternative insights into aesthetics. Rancière sets aside the core suppositions linking the medium to aesthetic judgment, which has informed many definitions of modernism. Rancière is emphatic in freeing aesthetic judgment from issues of medium-specificity. He argues that the idea of autonomy associated with medium-specificity – or 'truth to the medium' – was 'a very late one' in modernism, and that post-medium trends were already evident in early modernism. While not stressing a simple continuity between early modernism and contemporary art, Ranciere nonetheless emphasizes the on-going ethical and political ramifications of maintaining an a-disciplinary stance.