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.

Preservation of encapsulated shoot tips and nodes of the tropical hardwoods Corymbia torelliana × C. citriodora and Khaya senegalensis

Alginate encapsulation is a simple and cost-effective technique to preserve plant germplasm but there are only a few reports available on preservation of encapsulated explants of two highly valuable groups of tropical trees, the eucalypts (Myrtaceae) and mahoganies (Meliaceae). This study investigated alginate encapsulation for preservation of the eucalypt hybrid, Corymbia torelliana × C. citriodora, and the African mahogany, Khaya senegalensis. We assessed shoot regrowth of encapsulated shoot tips and nodes after storage for 0, 3, 6 and 12 months on media varying in sucrose and nutrient content, under storage conditions of 14°C and zero-irradiance. Encapsulated explants of both trees were preserved most effectively on high-nutrient (half-strength Murashige and Skoog) medium containing 1% sucrose, which provided very high frequencies of shoot regrowth (92–100% for Corymbia and 71–98% for Khaya) and excellent shoot development after 12 months’ storage. This technique provides an extremely efficient means for storage and exchange of eucalypts and mahoganies, ideally suited for incorporation into plant breeding and germplasm conservation programs.

Preliminary studies on the effect of irradiation as a means of preservation of fish and shellfish

Preliminary investigations on the effect of irradiation on commercially important fish and shell fish like silver pomfret, Bombay duck and prawns were conducted. Irradiated samples had an extended storage life compared to their respective controls even though yellowish or brownish discoloration occurred earlier in irradiated fish. Irradiation enhanced the rate of drip formation. Brine treatment prior to irradiation retarded this rate. Pre-blanching was found to further extend the storage life of irradiated fish.

Preservation of fish by freezing and glazing. Pt. 3. Effect of freezing, glazing and frozen storage on the B-vitamins and essential minerals present in the fish flesh

The changes occurring in moisture, thiamine, riboflavin niacin, phosphorus, iron and calcium in pomfret, surmai and frozen mackerel, glazed with ascorbic acid, citric acid, sodium chloride, glucose, sodium nitrite and kept under frozen storage were studied up to 6 months and results reported.

Bacteriology of chilled water during the preservation of fish

Except for the preliminary studies at Torry Research Station in Scotland, no results have been reported on the succession of the bacterial flora during the storage of fish in chilled water. The present work was undertaken to elucidate the dynamics of bacterial population changes in chilled fresh water under comparable conditions of storage in melting ice (+1° to +3°C.) which has been earlier studied by de Silva in 1960.

Use of antibiotics in the preservation of prawn

Effect of incorporating chlorotetracycline (CTC) in ice up to 5 ppm level on the keeping quality of prawns has been studied. A shelf life extension by nearly six days is obtained for the CTC-iced sample over the control. The headless prawns absorbed greater amounts of CTC than whole prawns during storage in CTC-ice. Traces of the antibiotic are found in the muscle of the CTC-iced prawns even after cooking for one hour. The cause of destruction of CTC when used for prawn preservation is discussed.

Technological aspects of preservation and processing of edible shell fishes IV. Comparative efficiency of different glazes in the preservation of frozen crab meat

The present work was undertaken to enlighten upon the comparative efficiency of different glazes in improving the quality of frozen crab meat (Scylla Serrata).

The preservation of some Indian freshwater fish

Quality changes in Labeo rohita, Cirrhinus mrigala and Tilapia mossambica were studied during storage in ice and at ambient temperature (29-32°C). After 10h at ambient temperature L. rohita and T. mossambica were completely spoiled, while C. mrigala became unacceptable within 11h. Organoleptic examination, total volatile base nitrogen and total bacterial counts showed that L. rohita (0.5 kg and above) and C. mrigala (0.5 kg and above) were acceptable up to 7 to 8 days of storage in ice in popular container (Bamboo basket) lined with palmyrah mat) at ambient temperature while T. mossambica (30-40 g) was acceptable up to 6 days. Influence of size of fish on shelf life in ice studied with reference to L. rohita showed that fishes below 500 g were acceptable up to 6 days of storage in ice in popular container at ambient temperature while those above 1000 g size were acceptable up to 8 days. Provision of an alkathene lining to the popular container extended the storage life of L. rohita from 6 days to 8 days. Pre-chilled and iced L. rohita had a longer shel flife (9 days) than merely iced sample (7 days).

Methods of harvesting and preservation of the diatom Chaetoceros calcitrans

Diatom culture and larval feeding experiments were conducted to test the viability and acceptability of preserved algal concentrates. C. calcitrans is characterised by the presence of setae which keep them suspended in cultures and make autoflocculation very difficult. Flocculation was induced by the addition of a floc-forming chemical. Using the optimum conditions, it was possible to harvest the algae within 1-h settling time and with about 84% recovery. The viability of frozen Chaetoceros was determined by actual cell reproduction. Preliminary feeding experiments showed that Chaetoceros can be successfully used as a substitute for fresh diatoms as feed for Penaeus monodon larvae. Simple freezing techniques, with or without the use of protectants has been found convenient for preserving algal concentrates in small volumes for both feeding and culture purposes.

The preservation of some East African freshwater fish

Quality changes during storage were investigated for several commercially important East African freshwater fish. Lates, Bagrus, Protopterus, Tilapia esculenta and T. nilotica were examined during storage in ice and at ambient temperature (250•C). After 24 hours at ambient temperature Lates and Bagrus were completely spoilt but Protopterus was still edible. In iced storage most fish were acceptable for at least 20 days. Organoleptic examination showed that T. nilotica was acceptable after 22 days storage in ice and that gutting was only marginally beneficial. Changes in physical appearance, which could form the basis of a fish inspection system, were recorded during storage. Possible chemical quality control indices were also investigated. It was found that total volatile bases and hypoxanthine are unlikely to be useful quality indices for the species studied with the possible exception of Lates. The bacterial counts of the flesh and skin of T. esculenta and T. niloticus were found to be low (a maximum of 10 organisms per sq cm of skin or per g of flesh) after 22 days storage in ice.