Country-by-country reporting: A critical analysis

This thesis evaluates the recent work of the Organisation for Economic Cooperation and Development and civil society groups in creating requirements for multinational entities to disclose financial information on a Country-by-Country basis. Country-by-Country reports may identify profit-shifting activities and enable various stakeholders to hold multinational entities accountable for their global conduct, through the provision of transparent and decision-useful information. This thesis identifies inadequacies in current disclosure requirements and develops a standardised Country-by-Country model, which is applied to the disclosures of three multinational entities to illustrate its pragmatic feasibility and the improvement in quality of financial information available to users.

The case for unitary taxation with formulary apportionment in the finance sector and the effect on developing nations

In 2013 the OECD released its 15 point Action plan to deal with base erosion and profit shifting (BEPS). In that plan it was recognised that BEPS has a significant effect on developing countries. This is because the lack of tax revenue can lead to a critical underfunding of public investment that would help promote economic growth. To this end, the BEPS project is aimed at ensuring an inclusive approach to take into account not only views of the G20 and OECD countries but also the perspective of developing nations. With this focus in mind and in the context of developing nations, the purpose of this article is to consider a possible solution to profit shifting which occurs under the current transfer pricing regime, with that solution being unitary taxation with formulary apportionment. It does so using the finance sector as a specific case for application. Multinational financial institutions (MNFIs) play a significant role in financing activities of their clients in developing nations. Consistent with the ‘follow-the-client’ phenomenon which explains financial institution expansion, these entities are increasingly profiting from activities associated with this growing market. Further, not only are MNFIs persistent users of tax havens but also, more than other industries, have opportunities to reduce tax through transfer pricing measures. This article establishes a case for an industry specific adoption of unitary taxation with formulary apportionment as a viable alternative to the current regime. It argues that such a model would benefit not only developed nations but also developing nations which are currently suffering the effects of BEPS. In doing so, it considers the practicalities of such an implementation by examining both definitional issues and a possible formula for MNFIs. This article argues that, while there would be implementation difficulties to overcome, the current domestic models of formulary apportionment provide important guidance as to how the unitary business and business activities of MNFIs should be defined as well as factors that should be included in an allocation formula, along with the appropriate weighting. While it would be difficult for developing nations to adopt such a regime, it is argued that it would be no more difficult than addressing issues they face with the current transfer pricing regime. As such, this article concludes that unitary taxation with formulary apportionment is a viable industry specific alternative for MNFIs which would assist developing nations and aid independent fiscal soundness.

G20 host Australia faces hard truths of multinational profit shifting

The G20 Finance Ministers have the opportunity this weekend to endorse the initial recommendations of the OECD on how to address the global problem of multinational tax avoidance. The work of the OECD on the issue to date is substantial. Most notable is the adoption by many nations, including Australia, of the Common Reporting Standard for the automatic exchange of tax information. This standard will allow significant inroads to be made into tax avoidance, particularly by individuals sheltering money offshore. This is the first step in an ambitious tax reform program. There is a long way to go if we are to end the issue now known as Base Erosion and Profit Shifting (BEPS). This week’s release of the first of the OECD recommendations contains some positive signs that further advances will be made. It also recognises some hard truths.

Thin capitalisation – the multinational tax avoidance strategy the budget forgot

We have already seen major amendments to Australia’s tax regime to tackle base erosion and profit shifting (BEPS). Several more significant measures were announced in the federal budget, most notably the diverted profits tax, aimed at multinationals which shift tax to a lower taxing jurisdiction. Yet to date, a very simple tax minimisation strategy has been largely ignored in the ongoing reforms and was ignored in the federal budget. Excessive debt loading is a problem that not been afforded the same attention as other aggressive tax planning strategies adopted by multinationals.

Self-assembled GaAs quantum rings by MBE droplet epitaxy

Fabrication of semiconductor nanostructures such as quantum dots (QDs), quantum rings (QRs) has been considered as the important step for realization of solid state quantum information devices, including QDs single photon emission source, QRs single electron memory unit, etc. To fabricate GaAs quantum rings, we use Molecular Beam Epitaxy (MBE) droplet technique in this report. In this droplet technique, Gallium (Ga) molecular beams are supplied initially without Arsenic (As) ambience, forming droplet-like nano-clusters of Ga atoms on the substrate, then the Arsenic beams are supplied to crystallize the Ga droplets into GaAs crystals. Because the morphologies and dimensions of the GaAs crystal are governed by the interplay between the surface migration of Ga and As adatoms and their crystallization, the shape of the GaAs crystals can be modified into rings, and the size and density can be controlled by varying the growth temperatures and As/Ga flux beam equivalent pressures(BEPs). It has been shown by Atomic force microscope (AFM) measurements that GaAs single rings, concentric double rings and coupled double rings are grown successfully at typical growth temperatures of 200 C to 300 C under As flux (BEP) of about 1.0 x 10(-6) Torr. The diameter of GaAs rings is about 30-50 nm and thickness several nm.

Substrate temperature dependence of ZnTe epilayers grown on GaAs(001) by molecular beam epitaxy

ZnTe thin films have been grown on GaAs(0 0 1) substrates at different temperatures with constant Zn and Te beam equivalent pressures (BEPs) by molecular beam epitaxy (MBE). In situ reflection high-energy electron diffraction (RHEED) observation indicates that two-dimensional (2D) growth mode can be established after around one-minute three-dimensional (3D) nucleation by increasing the substrate temperature to 340 degrees C. We found that Zn desorption from the ZnTe surface is much greater than that of Te at higher temperatures, and estimated the Zn sticking coefficient by the evolution of growth rate. The Zn sticking coefficient decreases from 0.93 to 0.58 as the temperature is elevated from 320 to 400 degrees C. The ZnTe epilayer grown at 360 degrees C displays the narrowest full-width at half-maximum (FWHM) of 660 arcsec from (0 0 4) reflection in double-crystal X-ray rocking curve (DCXRC) measurements. The surface morphology of ZnTe epilayers is strongly dependent on the substrate temperature, and the root-mean-square (RMS) roughness diminishes drastically with the increase in temperature.

Study of multiferroic materials

The present PhD work aims the research and development of materials that exhibit multiferroic properties, in particular having a significant interaction between ferromagnetism and ferroelectricity; either directly within an intrinsic single phase or by combining extrinsic materials, achieving the coupling of properties through mechanic phenomena of the respective magnetostriction and piezoelectricity. These hybrid properties will allow the cross modification of magnetic and electric polarization states by the application of cross external magnetic and/or electric fields, giving way to a vast area for scientific investigation and potential technological applications in a new generation of electronic devices, such as computer memories, signal processing, transducers, sensors, etc. Initial experimental work consisted in chemical synthesis of nano powders oxides by urea pyrolysis method: A series of ceramic bulk composites with potential multiferroic properties comprised: of LuMnO3 with La0.7Sr0.3MnO3 and BaTiO3 with La0.7Ba0.3MnO3; and a series based on the intrinsic multiferroic LuMn1-zO3 phase modified with of Manganese vacancies. The acquisition of a new magnetron RF sputtering deposition system, in the Physics Department of Aveiro University, contributed to the proposal of an analogous experimental study in multiferroic thin films and multilayer samples. Besides the operational debut of this equipment several technical upgrades were completed like: the design and construction of the heater electrical contacts; specific shutters and supports for the magnetrons and for the substrate holder and; the addition of mass flow controllers, which allowed the introduction of N2 or O2 active atmosphere in the chamber; and the addition of a second RF generator, enabling co-deposition of different targets. Base study of the deposition conditions and resulting thin films characteristics in different substrates was made from an extensive list of targets. Particular attention was given to thin film deposition of magnetic phases La1-xSrxMnO3, La1-xBaxMnO3 and Ni2+x-yMn1-xGa1+y alloy, from the respective targets: La0.7Sr0.3MnO3, La0.7Ba0.3MnO3; and NiGa with NiMn. Main structural characterization of samples was performed by conventional and high resolution X-Ray Diffraction (XRD); chemical composition was determined by Electron Dispersion Spectroscopy (EDS); magnetization measurements recur to a Vibrating Sample Magnetometer (VSM) prototype; and surface probing (SPM) using Magnetic-Force (MFM) and Piezo-Response (PFM) Microscopy. Results clearly show that the composite bulk samples (LuM+LSM and BTO+LBM) feat the intended quality objectives in terms of phase composition and purity, having spurious contents below 0.5 %. SEM images confirm compact grain packaging and size distribution around the 50 nm scale. Electric conductivity, magnetization intensity and magneto impedance spreading response are coherent with the relative amount of magnetic phase in the sample. The existence of coupling between the functional phases is confirmed by the Magnetoelectric effect measurements of the sample “78%LuM+22%LSM” reaching 300% of electric response for 1 T at 100 kHz; while in the “78%BTO+22%LBM” sample the structural transitions of the magnetic phase at ~350 K result in a inversion of ME coefficient the behavior. A functional Magneto-Resistance measurement system was assembled from the concept stage until the, development and operational status; it enabled to test samples from 77 to 350 K, under an applied magnetic field up to 1 Tesla with 360º horizontal rotation; this system was also designed to measure Hall effect and has the potential to be further upgraded. Under collaboration protocols established with national and international institutions, complementary courses and sample characterization studies were performed using Magneto-Resistance (MR), Magneto-Impedance (MZ) and Magneto-Electric (ME) measurements; Raman and X-ray Photoelectron Spectroscopy (XPS); SQUID and VSM magnetization; Scanning Electron Microscopy (SEM) and Rutherford Back Scattering (RBS); Scan Probe Microscopy (SPM) with Band Excitation Probe Spectroscopy (BEPS); Neutron Powder Diffraction (NPD) and Perturbed Angular Correlations (PAC). Additional collaboration in research projects outside the scope of multiferroic materials provided further experience in sample preparation and characterization techniques, namely VSM and XPS measurements were performed in cubane molecular complex compounds and enable to identify the oxidation state of the integrating cluster of Ru ions; also, XRD and EDS/SEM analysis of the acquired targets and substrates implied the devolution of some items not in conformity with the specifications. Direct cooperation with parallel research projects regarding multiferroic materials, enable the assess to supplementary samples, namely a preliminary series of nanopowder Y1-x-yCaxØyMn1O3 and of Eu0.8Y0.2MnO3, a series of micropowder composites of LuMnO3 with La0.625Sr0.375MnO3 and of BaTiO3 with hexagonal ferrites; mono and polycrystalline samples of Pr1-xCaxMnO3, La1-xSrxMnO3 and La1-xCaxMnO3.

Governo Lula: contornos sociais e políticos da elite do poder

O objetivo central é conhecer a trajetória desses funcionários, seu papel e funções, bem como a interface que mantêm com o serviço público, a sociedade, terceiro setor, partidos, sindicatos, carreiras públicas, empresas. Queremos acompanhar sua formação acadêmica, experiência profissional e traçar uma radiografia desse corpo de funcionários, de forma a podermos formular algumas hipóteses sobre a relação desses cargos de confiança com as carreiras de Estado e as associações da sociedade civil. Esta pesquisa insere-se dentro de um esforço mais amplo visando a entender critérios de nomeação e composição dos principais quadros do Executivo. Para isso comparamos nossa amostra com dados já existentes nos BEPs e com outros inéditos que estamos coletando. Para efeitos de organização metodológica de nossas informações, a pesquisa, ainda em fase preliminar, está dividida em três partes.

Límites a la interpretación dinámica de los convenios de doble imposición internacional: el caso ING

El presente trabajo contiene algunas reflexiones críticas sobre el valor hermenéutico de los Comentarios al Convenio Modelo de la OCDE y su interpretación dinámica, más o menos matizada, al hilo de la Sentencia de la Audiencia Nacional de 10 de julio de 2015, dictada en el Caso ING. La interpretación de los convenios de doble imposición internacional ha concitado desde antiguo posturas encontradas tanto en el plano doctrinal como jurisprudencial; discusión que cobra hoy renovada importancia en relación con el soft law en general, y las recomendaciones del Proyecto BEPS de la OCDE, en particular.