Not all corporate tax avoiders will be snared by new rules

Hockey’s budget announcement of two major tax integrity measures was flagged before the budget was handed down, but even that came as no surprise. Integrity, or lack thereof, in our tax system is a hot topic and an easy target for a Treasurer looking to sell a federal budget. The first of the proposed changes is to our GST regime. No-one likes hearing that they will be paying more tax. But, the charging of GST on supplies of digital products and services in Australia by an off-shore supplier will at least make sense to the general public. With the inherent unfairness in the current system and a revenue raising prediction of A$350 million over the next four years, most are likely to accept the logic of such a measure. The second of the proposed changes are new laws to be included in Australia’s general anti-avoidance provision. New laws, which will apply from 1 January 2016, are aimed at multinational companies engaged in aggressive tax practices. The proposed anti-avoidance law is designed to stop multinationals that artificially avoid a taxable presence in Australia. It is difficult to see how this strategy of addressing specific behaviour through what is considered a general provision will work. And, it is these changes that are already causing confusion.

Government cracks down on tax avoidance through foreign investment rules

The Turnbull Government announced yet another measure aimed at addressing tax base erosion and profit shifting, placing additional requirements on new foreign investment under the existing national interest test. In the last 12 months Australia has seen various reforms within the tax system. However, this latest initiative is a shift as it links Australia’s tax regime with its foreign investment regime. It sends a broader signal to the market that Australia will look beyond the collection of tax revenues to a consideration of national interest.

Assessing taxpayer response to legislative changes: A case study of ‘in-house’ fringe benefits rules

On 22 October 2012, the Australian Federal Government announced the removal of the $1,000 in-house fringe benefits concession when used as part of a salary packaging arrangement. At the time of the announcement, the Federal Government predicted that the removal of the concession would contribute additional tax revenue of $445 million over the following four years as well as an increase of GST payments to the States and Territories. However, anecdotal evidence at the same time indicated that the Australian employer response was to immediately stop providing employees with such in-house fringe benefits via salary sacrificing arrangements. Data presented in this article, collected from a combination of interviews with tax managers of four Australian entities as well as a review of the published archival data, confirms that the abolition of the $1,000 in-house fringe benefits concession was perceived as a negative change, whereby employees were considered the ‘big losers’ despite assertions by the Federal Government to the contrary. Using a conceptual map of tax rule change developed by Oats and Sadler, this article seeks to understand the reasons for this fringe benefits tax change and taxpayer response. In particular, the economic and political factors, and the responses of the relevant taxpayers (employers) are explored. Drawing on behavioural economic concepts, the actions, attitudes and response of employers to the rule change are also examined. The research findings suggest that the decision by Australian employers to cease providing the in-house fringe benefits as part of a salary-packaging arrangement after the legislative amendment was impacted by more than simple rational behaviour.

Reducing tariffs according to WTO accession rules: The case of Vietnam

When Vietnam joined the World Trade Organization (WTO) in 2007 it was granted an accession period up to 2014. During this period tariffs would have to fall according to the accession agreement. This paper evaluates this 2007–2014 trade liberalization by building an applied general equilibrium model and calibrating it to the Vietnamese data. The model pays careful attention to the fact that Vietnam has many state-owned enterprises. The model simulations show that the WTO tariff reductions will reduce overall welfare. Moreover, the biggest loss will take place among the poor rural households in Vietnam. This paper proposes other tariff reforms that will both raise overall welfare and reduce income inequality.

Transfer pricing rules and competing governments

The literature on the regulation of multinationals' transfer prices has not considered the possibility that governments may use transfer pricing rules strategically when they compete with other governments. The present paper analyses this case and shows that, even in the absence of agency considerations, a non‐cooperative equilibrium is characterised by above‐optimal levels of effective taxation. We then derive conditions under which harmonization of transfer pricing rules lead to a Pareto improvement, and show that harmonization according to the ‘arm's length’ principle—the form of harmonization advocated by the OECD—may not be Pareto improving.

Temperature independent mixing rules to correlate the solubilities of antibiotics and anti-inflammatory drugs in SCCO2

The accurate experimental determination of the solubilities of antibiotics and anti-inflammatory drugs in supercritical fluids (SCFs) and correlations are essential for the development of supercritical technologies for the pharmaceuticals industry. In this work, the solubilities of penicillinG, penicillinV, flurbiprofen, ketoprofen, naproxen, ibuprofen, aspirin and diflunisal in supercritical carbon dioxide (SCCO2) were correlated using Peng-Robinson equation of state (PR EOS) with the modified Kwak and Mansoori mixing rules (mKM) and with Bartle model. The ability of mKM rules was compared against the conventional mixing rules of van der Waals in correlating the solubilities. In the present model, vapor pressure was considered as an adjustable parameter along with binary interactions parameters. In the proposed model, the constants used in the mixing rule, and vapor pressure expression coefficients are temperature independent. The optimization of these constants with experimental data gives binary interaction parameters along with vapor pressure correlations. Sublimation enthalpies were estimated with both the models compared with literature reported experimental values.

Generic Routing Rules and a Scalable Access Enhancement for the Network-on-Chip RECONNECT

RECONNECT is a Network-on-Chip using a honeycomb topology. In this paper we focus on properties of general rules applicable to a variety of routing algorithms for the NoC which take into account the missing links of the honeycomb topology when compared to a mesh. We also extend the original proposal [5] and show a method to insert and extract data to and from the network. Access Routers at the boundary of the execution fabric establish connections to multiple periphery modules and create a torus to decrease the node distances. Our approach is scalable and ensures homogeneity among the compute elements in the NoC. We synthesized and evaluated the proposed enhancement in terms of power dissipation and area. Our results indicate that the impact of necessary alterations to the fabric is negligible and effects the data transfer between the fabric and the periphery only marginally.

Monetary policy rules and estimated reaction functions for the European Central Bank

This thesis studies the interest-rate policy of the ECB by estimating monetary policy rules using real-time data and central bank forecasts. The aim of the estimations is to try to characterize a decade of common monetary policy and to look at how different models perform at this task.The estimated rules include: contemporary Taylor rules, forward-looking Taylor rules, nonlinearrules and forecast-based rules. The nonlinear models allow for the possibility of zone-like preferences and an asymmetric response to key variables. The models therefore encompass the most popular sub-group of simple models used for policy analysis as well as the more unusual non-linear approach. In addition to the empirical work, this thesis also contains a more general discussion of monetary policy rules mostly from a New Keynesian perspective. This discussion includes an overview of some notable related studies, optimal policy, policy gradualism and several other related subjects. The regression estimations are performed with either least squares or the generalized method of moments depending on the requirements of the estimations. The estimations use data from both the Euro Area Real-Time Database and the central bank forecasts published in ECB Monthly Bulletins. These data sources represent some of the best data that is available for this kind of analysis. The main results of this thesis are that forward-looking behavior appears highly prevalent, but that standard forward-looking Taylor rules offer only ambivalent results with regard to inflation. Nonlinear models are shown to work, but on the other hand do not have a strong rationale over a simpler linear formulation. However, the forecasts appear to be highly useful in characterizing policy and may offer the most accurate depiction of a predominantly forward-looking central bank. In particular the inflation response appears much stronger while the output response becomes highly forward-looking as well.

A Flat Concurrent Prolog compiler for PARAM

We describe a compiler for the Flat Concurrent Prolog language on a message passing multiprocessor architecture. This compiler permits symbolic and declarative programming in the syntax of Guarded Horn Rules, The implementation has been verified and tested on the 64-node PARAM parallel computer developed by C-DAC (Centre for the Development of Advanced Computing, India), Flat Concurrent Prolog (FCP) is a logic programming language designed for concurrent programming and parallel execution, It is a process oriented language, which embodies dataflow synchronization and guarded-command as its basic control mechanisms. An identical algorithm is executed on every processor in the network, We assume regular network topologies like mesh, ring, etc, Each node has a local memory, The algorithm comprises of two important parts: reduction and communication, The most difficult task is to integrate the solutions of problems that arise in the implementation in a coherent and efficient manner. We have tested the efficacy of the compiler on various benchmark problems of the ICOT project that have been reported in the recent book by Evan Tick, These problems include Quicksort, 8-queens, and Prime Number Generation, The results of the preliminary tests are favourable, We are currently examining issues like indexing and load balancing to further optimize our compiler.

Ising pyrochlore magnets: Low-temperature properties, "ice rules," and beyond

Pyrochlore magnets are candidates for what Harris et al. [Phys. Rev. Lett. 79, 2554 (1997)] call "spin-ice" behavior. We present theoretical simulations of relevance for the pyrochlore family R2Ti2O7 (R = rare earth) supported by magnetothermal measurements on selected systems. Ey considering long-ranged dipole-dipole as well as short-ranged superexchange interactions, we get three distinct behaviors: (i) an ordered doubly degenerate state, (ii) a highly disordered state with a broad transition to paramagnetism, and (iii) a partially ordered state with a sharp transition to paramagnetism. Closely corresponding behavior is seen in the real compounds.

Shear sum rules at finite chemical potential

We derive sum rules which constrain the spectral density corresponding to the retarded propagator of the T-xy component of the stress tensor for three gravitational duals. The shear sum rule is obtained for the gravitational dual of the N = 4 Yang-Mills, theory of the M2-branes and M5-branes all at finite chemical potential. We show that at finite chemical potential there are additional terms in the sum rule which involve the chemical potential. These modifications are shown to be due to the presence of scalars in the operator product expansion of the stress tensor which have non-trivial vacuum expectation values at finite chemical potential.

Reducing convergence times of self-propelled swarms via modified nearest neighbor rules

Vicsek et al. proposed a biologically inspired model of self-propelled particles, which is now commonly referred to as the Vicsek model. Recently, attention has been directed at modifying the Vicsek model so as to improve convergence properties. In this paper, we propose two modification of the Vicsek model which leads to significant improvements in convergence times. The modifications involve an additional term in the heading update rule which depends only on the current or the past states of the particle's neighbors. The variation in convergence properties as the parameters of these modified versions are changed are closely investigated. It is found that in both cases, there exists an optimal value of the parameter which reduces convergence times significantly and the system undergoes a phase transition as the value of the parameter is increased beyond this optimal value. (C) 2012 Elsevier B.V. All rights reserved.

Applying Genetic Algorithms to Optimize Power in Tiled SNUCA Chip Multicore Architectures

We propose a novel technique for reducing the power consumed by the on-chip cache in SNUCA chip multicore platform. This is achieved by what we call a "remap table", which maps accesses to the cache banks that are as close as possible to the cores, on which the processes are scheduled. With this technique, instead of using all the available cache, we use a portion of the cache and allocate lesser cache to the application. We formulate the problem as an energy-delay (ED) minimization problem and solve it offline using a scalable genetic algorithm approach. Our experiments show up to 40% of savings in the memory sub-system power consumption and 47% savings in energy-delay product (ED).