Transfer pricing and multinational financial institutions : the case for replacing arm’s length price with a unitary approach

The international tax system, designed a century ago, has not kept pace with the modern multinational entity rendering it ineffective in taxing many modern businesses according to economic activity. One of those modern multinational entities is the multinational financial institution (MNFI). The recent global financial crisis provides a particularly relevant and significant example of the failure of the current system on a global scale. The modern MNFI is increasingly undertaking more globalised and complex trading operations. A primary reason for the globalisation of financial institutions is that they typically ‘follow-the-customer’ into jurisdictions where international capital and international investors are required. The International Monetary Fund (IMF) recently reported that from 1995-2009, foreign bank presence in developing countries grew by 122 per cent. The same study indicates that foreign banks have a 20 per cent market share in OECD countries and 50 per cent in emerging markets and developing countries. Hence, most significant is that fact that MNFIs are increasingly undertaking an intermediary role in developing economies where they are financing core business activities such as mining and tourism. IMF analysis also suggests that in the future, foreign bank expansion will be greatest in emerging economies. The difficulties for developing countries in applying current international tax rules, especially the current traditional transfer pricing regime, are particularly acute in relation to MNFIs, which are the biggest users of tax havens and offshore finance. This paper investigates whether a unitary taxation approach which reflects economic reality would more easily and effectively ensure that the profits of MNFIs are taxed in the jurisdictions which give rise to those profits. It has previously been argued that the uniqueness of MNFIs results in a failure of the current system to accurately allocate profits and that unitary tax as an alternative could provide a sounder allocation model for international tax purposes. This paper goes a step further, and examines the practicalities of the implementation of unitary taxation for MNFIs in terms of the key components of such a regime, along with their their implications. This paper adopts a two-step approach in considering the implications of unitary taxation as a means of improved corporate tax coordination which requires international acceptance and agreement. First, the definitional issues of the unitary MNFI are examined and second, an appropriate allocation formula for this sector is investigated. To achieve this, the paper asks first, how the financial sector should be defined for the purposes of unitary taxation and what should constitute a unitary business for that sector and second, what is the ‘best practice’ model of an allocation formula for the purposes of the apportionment of the profits of the unitary business of a financial institution.

Demand-side response model to avoid spike of electricity price

The aim of this work is to develop a demand-side-response model, which assists electricity consumers exposed to the market price to independently and proactively manage air-conditioning peak electricity demand. The main contribution of this research is to show how consumers can optimize the energy cost caused by the air conditioning load considering to several cases e.g. normal price, spike price, and the probability of a price spike case. This model also investigated how air-conditioning applies a pre-cooling method when there is a substantial risk of a price spike. The results indicate the potential of the scheme to achieve financial benefits for consumers and target the best economic performance for electrical generation distribution and transmission. The model was tested with Queensland electricity market data from the Australian Energy Market Operator and Brisbane temperature data from the Bureau of Statistics regarding hot days from 2011 to 2012.

Defining expected cost for the air conditioning to avoid a price spike of electricity market under DSR model

This work presents a demand side response model (DSR) which assists small electricity consumers, through an aggregator, exposed to the market price to proactively mitigate price and peak impact on the electrical system. The proposed model allows consumers to manage air-conditioning when as a function of possible price spikes. The main contribution of this research is to demonstrate how consumers can minimise the total expected cost by optimising air-conditioning to account for occurrences of a price spike in the electricity market. This model investigates how pre-cooling method can be used to minimise energy costs when there is a substantial risk of an electricity price spike. The model was tested with Queensland electricity market data from the Australian Energy Market Operator and Brisbane temperature data from the Bureau of Statistics during hot days on weekdays in the period 2011 to 2012.

"But we’re already doing it!" Examining conceptual blurring between health promotion and palliative care

Over the past decade, an increasing number of palliative care service providers have attempted to integrate health promotion into their organisational practice. A key factor in the success of this endeavour has been the recognition by these providers of the conceptual ‘fit’ between two seemingly disparate approaches to health care. When informed of the elements of health promotion, palliative care professionals have expressed their recognition in their declaration: ‘But we’re already doing it!’ (Rosenberg 2007). Yet it appears that this association between the two suggests that health promotion in palliative care organisations is being understood in poorly defined ways. ‘Health promotion’ can be incorrectly assumed to be synonymous with ‘health education’; ‘death education’ can be understood to be synonymous with providing information about palliative care resources. Whilst these activities may be worthwhile within themselves, their presence in the activities of an organisation does not constitute the practice of health promoting palliative care (HPPC) (Kellehear 1999)...

We have a lot to learn yet : a postcolonial lens in health promotion

Health promotion progresses a social justice and empowerment agenda and thus emphasises working with people to increase their control over their health. Certainly, Australia has experienced much success in this endeavour and is internationally recognised as a leader. However, health promotion has failed Indigenous Australians; a fact that is echoed in the health outcomes that ironically provide us with the “moral imperative” to act. Further investigation has also revealed health promotion’s foundation in colonial imaginings. Thus, this paper calls for the culture of health promotion to be examined as a risk factor for poor Indigenous health. To complement this call, this paper presents findings of an ethnographic study of Indigenous health promotion practice, undertaken from a postcolonial and critical whiteness framework. These findings provide a narrative of strength and innovative approaches, highlighting the value of Indigenous knowledge. These findings also contradict the biomedical tendency to construct culture as illness-producing. More broadly, this study’s findings entail important lessons for health promotion to consider, if it is to move beyond the rhetoric, to truly increase people’s control over their health.

Health promotion

Subheadings: What is health promotion? Research and health promotion practice Planning and evaluation as the cornerstones of evidence

The prevention of childhood anxiety and promotion of resilience among preschool-aged children : a universal school based trial

This study is the first to examine the effectiveness of the Fun FRIENDS programme, a school-based, universal preventive intervention for early childhood anxiety and promotion of resilience delivered by classroom teachers. Participants (N = 488) included children aged 4–7 years attending 1 of 14 Catholic Education schools in Brisbane, Australia. The schools were randomly allocated to one of three groups, the intervention, active comparison and waitlist control group. Parents completed standardized measures of anxiety and behavioural inhibition (BI), resilience, social and emotional functioning and behaviour difficulties in addition to parental stress and anxiety, at pre- and post- and 12-month follow-up. Teachers also completed a parallel measure of social and emotional strength at the three time points. Comparable results were obtained for the intervention and comparison groups; however, the intervention group (IG) achieved greater reductions in BI, child behavioural difficulties and improvements in social and emotional competence. In addition, significant improvements in parenting distress and parent–child interactions were found for the IG, with gains maintained at 12-month follow-up. Teacher reports revealed more significant improvement in social and emotional competence for the IG. Clinical implications of the findings are discussed, along with limitations and directions for future research.

Parameter estimation of structural commodity price models

Commodity price modeling is normally approached in terms of structural time-series models, in which the different components (states) have a financial interpretation. The parameters of these models can be estimated using maximum likelihood. This approach results in a non-linear parameter estimation problem and thus a key issue is how to obtain reliable initial estimates. In this paper, we focus on the initial parameter estimation problem for the Schwartz-Smith two-factor model commonly used in asset valuation. We propose the use of a two-step method. The first step considers a univariate model based only on the spot price and uses a transfer function model to obtain initial estimates of the fundamental parameters. The second step uses the estimates obtained in the first step to initialize a re-parameterized state-space-innovations based estimator, which includes information related to future prices. The second step refines the estimates obtained in the first step and also gives estimates of the remaining parameters in the model. This paper is part tutorial in nature and gives an introduction to aspects of commodity price modeling and the associated parameter estimation problem.

A securities market operator's use of the "please explain" price query and its impact on compliance

Market operators in New Zealand and Australia, such as the New Zealand Exchange (NZX) and the Australian Securities Exchange (ASX), have the regulatory power in their listing rules to issue queries to their market participants to explain unusual fluctuations in trading price and/or volume in the market. The operator will issue a price query where it believes that the market has not been fully informed as to price relevant information. Responsive regulation theory has informed much of the regulatory debate in securities laws in the region. Price queries map onto the lower level of the enforcement pyramid envisaged by responsive regulation and are one strategy that a market operator can use in communicating its compliance expectations to its stakeholders. The issue of a price query may be a precursor to more severe enforcement activities. The aim of this study is to investigate whether increased use of price queries by the securities market operator in New Zealand corresponded with an increase in disclosure frequency by all participating companies. The study finds that an increased use of price queries did correspond with an increase in disclosure frequency. A possible explanation for this finding is that price queries are an effective means of appealing to the factors that motivate corporations, and the individuals who control them, to comply with the law and regulatory requirements. This finding will have implications for both the NZX and the ASX as well as for regulators and policy makers generally.

Building community coalitions for the promotion of physical activity: 10,000 steps Rockhampton

The 10,000 Steps Rockhampton project is a multi-strategy community-wide, physical activity intervention based on the simultaneous implementation of five strategies, each identified as 'best practice' for the promotion of physical activity. Several community partners were engaged to develop and implement the strategies during the first eighteen months of the project. These included: the local media (TV, newspaper and radio); the local Division of General Practice and other health professional groups; the Heart Foundation and ‘Just Walk It’; the local council; and several large worksites. A local physical activity task force was also formed to administer a 'micro-grants' scheme, and to guide the development of community based strategies. The presentation will focus on the critical elements involved in developing and maintaining relationships with community partners. These include identification and ‘courting’ of potential partners, strategies for keeping them engaged, and the challenges of maintaining the balance between ‘top-down’ (evidence-based) and ‘bottom-up’ (community-driven) strategies. Data on implementation and uptake of the key strategies will also be presented. These include: 1) process data on the number of health

Health promotion for dogs and humans : the 10,000 steps Rockhampton dog walking intervention

Purpose This paper describes the implementation and evaluation of an intervention aimed at increasing the dog-walking behaviour of residents from a community of approximately 60,000. This intervention was a sub strategy of the 10 000 Steps Rockhampton project – a community intervention aimed at decreasing sedentary behaviour in the adult population. Methods Brochures and posters were developed that promoted dog walking as a means to improve both human and canine health. The brochures were distributed by the local council to over 8 000 homes with the annual dog-renewal registrations. Results Evaluation of the intervention included a telephone survey of a randomly selected sample of Rockhampton residents (n=420) four-months post intervention. Although 63.6% of participants reported that owning a dog increased their physical activity levels, 40% of dog-owners did not walk their dog at all in the last week. The outcome evaluation of the intervention showed that 20.2% of dog-owners recalled receiving the brochure. Overall 15.3% of respondents with a dog in their household reported an increase in their physical activity levels since the intervention, 8.4% reported a decrease. Conclusions The intervention was an innovative and cost-effective way to tap into a section of the population that can benefit from engaging in regular walking behaviour. It was also a unique and useful way to engage local council in physical activity health promotion as part of a larger ongoing community-wide intervention.

Deadly Choices or deadly choices? An ethnography of health promotion practice with Indigenous Australians

This presentation provides an overview of my PhD research, which links with the Institute for Urban Indigenous Health (IUIH) and its Deadly Choices team. In the presentation, I introduce my critique of mainstream health promotion practice, highlighting the need for decolonisation of health promotion and the opportunity to learn from health promotion practice that acknowledges Indigenous knowledge, skills and perspectives. I also overview my ethnographic research methodology, which enabled me to be a participant observer with IUIH health promotion practitioners. I canvas some of my findings to date, according to two key areas: the unique way Deadly Choices applies leadership as its model of health promotion practice; and the range of innovative engagement strategies they employed, including the Deadly Choices brand and social media. I conclude by highlighting the counter-narrative and contrast that Deadly Choices provides compared to traditional health promotion approaches with Indigenous people, and identify lessons for decolonisation of heath promotion more broadly.

Promotion of Homologous Recombination and Genomic Stability by RAD51AP1 via RAD51 Recombinase Enhancement

Homologous recombination (HR) repairs chromosome damage and is indispensable for tumor suppression in humans. RAD51 mediates the DNA strand-pairing step in HR. RAD51 associated protein 1 (RAD51AP1) is a RAD51-interacting protein whose function has remained elusive. Knockdown of RAD51AP1 in human cells by RNA interference engenders sensitivity to different types of genotoxic stress, and RAD51AP1 is epistatic to the HR protein XRCC3. Moreover, RAD51AP1-depleted cells are impaired for the recombinational repair of a DNA double-strand break and exhibit chromatid breaks both spontaneously and upon DNA-damaging treatment. Purified RAD51AP1 binds both dsDNA and a D loop structure and, only when able to interact with RAD51, greatly stimulates the RAD51-mediated D loop reaction. Biochemical and cytological results show that RAD51AP1 functions at a step subsequent to the assembly of the RAD51-ssDNA nucleoprotein filament. Our findings provide evidence that RAD51AP1 helps maintain genomic integrity via RAD51 recombinase enhancement.