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.

Accurate stratospheric particle size distributions from two separate flat-plate collection surfaces

Over the past two decades, flat-plate particle collections have revealed the presence of a remarkable variety of both terrestrial and extraterrestrial material in the stratosphere [1-6]. The ratio of terrestrial to extraterrestrial material and the nature of material collected may vary over observable time scales. Variations in particle number density can be important since the earth’s atmospheric radiation balance, and therefore the earth’s climate, can be influenced by articulate absorption and scattering of radiation from the sun and earth [7-9]. In order to assess the number density of solid particles in the stratosphere, we have examined a representative fraction of the so1id particles from two flat-plate collection surfaces, whose collection dates are separated in time by 5 years.

To separate or not to separate? Parental decision-making regarding the separation of twins in the early years of schooling

In recent times concerns about possible adverse effects of early separation and advocacy for individual rights have resulted in a movement away from organizational level policies about the separation of twin children as they enter school. Instead, individualized approaches that focus on the twin children’s characteristics and family perspectives have been proposed. This study, conducted in Australia where all but a few families had choice about the class placement of their twin children, questioned parents (N = 156) about their placement decisions. Results indicated that most parents opted for placement together in the early years of schooling. The choice to separate twins at school entry was associated with parent identification of risk in the twin relationship, while being kept together was associated with parent identification of absence of such risk. The findings are discussed in light of the current evidence against separation, and suggest that parent choices regarding the separation of twin children in the early years are informative to educational policy and practice.

Separate or simultaneous removal of radioactive cations and anions from water by layered sodium vanadate-based sorbents

Nanofibers of sodium vanadate, consisting of very thin negatively charged layers and exchangeable sodium ions between the layers, are efficient sorbents for the removal of radioactive 137Cs+ and 85Sr2+ cations from water. The exchange of 137Cs+ or 85Sr2+ ions with the interlayer Na+ ions eventually triggered structural deformation of the thin layers, trapping the 137Cs+ and 85Sr2+ ions in the nanofibers. Furthermore, when the nanofibers were dispersed in a AgNO3 solution at pH >7, well-dispersed Ag2O nanocrystals formed by firmly anchoring themselves on the fiber surfaces along planes of crystallographic similarity with those of Ag2O. These nanocrystals can efficiently capture I– anions by forming a AgI precipitate, which was firmly attached to the substrates. We also designed sorbents that can remove 137Cs+ and 125I– ions simultaneously for safe disposal by optimizing the Ag2O loading and sodium content of the vanadate. This study confirms that sorbent features such as fibril morphology, negatively charged thin layers and readily exchangeable Na+ ions between the layers, and the crystal planes for the formation of a coherent interface with Ag2O nanocrystals on the fiber surface are very important for the simultaneous uptake of cations and anions.

Behavior of the indian social wasp ropalidia-cyathiformis on a nest of separate combs (hymenoptera, vespidae)

Observations were made on a nest of Ropalidia cyathiformis consisting of three combs. The number of eggs, larvae, pupae and adults were monitored at about 3-day intervals for a 2-month period. The behaviour of the adults was observed with special reference to the proportion of time spent on each of the three combs, the proportion of time spent away from the nest site and the frequencies of dominance interactions and egg laying. The adults moved freely between the three combs suggesting that all of them and all the three combs belonged to one nest. However, most of the adults preferred combs 2 and 3 over comb 1. Of the 10 animals chosen for a detailed analysis of behaviour, seven spent varying periods of time away from the nest site and oRen brought back food or building material. Five of the 10 animals laid at least one egg each but two adults monopolized most of the egg-laying. The animals showed a variety of dominance interactions on the basis of which they have been arranged in a dominance hierarchy. The dominant individuals laid most of the eggs and spent little or no time foraging, while the subordinate individuals spent more time foraging and laid few eggs or none. It is argued that R. cyathiformis is different from R. marginata, the only other Indian social wasp whose behaviour has been studied, in being at a more primitive stage of social organization.

Separate and interacting effects within the catechol-O-methyltransferase (COMT) are associated with schizophrenia

Several lines of evidence have implicated the catechol-O-methyltransferase (COMT) gene as a candidate for schizophrenia (SZ) susceptibility, not only because it encodes a key dopamine catabolic enzyme but also because it maps to the velocardiofacial syndrome region of chromosome 22q11 which has long been associated with SZ predisposition. The interest in COMT as a candidate SZ risk factor has led to numerous case-control and family-based studies, with the majority placing emphasis on examining a functional Val/Met polymorphism within this enzyme. Unfortunately, these studies have continually produced conflicting results. To assess the genetic contribution of other COMT variants to SZ susceptibility, we investigated three single-nucleotide polymorphisms (SNPs) (rs737865, rs4633, rs165599) in addition to the Val/Met variant (rs4680) in a highly selected sample of Australian Caucasian families containing 107 patients with SZ. The Val/Met and rs4633 variants showed nominally significant associations with SZ (P<0.05), although neither of the individual SNPs remained significant after adjusting for multiple testing (most significant P=0.1174). However, haplotype analyses showed strong evidence of an association; the most significant being the three-marker haplotype rs737865-rs4680-rs165599 (global P=0.0022), which spans more than 26 kb. Importantly, conditional analyses indicated the presence of two separate and interacting effects within this haplotype, irrespective of gender. In addition, our results indicate the Val/Met polymorphism is not disease-causing and is simply in strong linkage disequilibrium with a causative effect, which interacts with another as yet unidentified variant approximately 20 kb away. These results may help explain the inconsistent results reported on the Val/Met polymorphism and have important implications for future investigations into the role of COMT in SZ susceptibility.

Latent class and genetic analysis does not support migraine with aura and migraine without aura as separate entities

Latent class and genetic analyses were used to identify subgroups of migraine sufferers in a community sample of 6,265 Australian twins (55% female) aged 25-36 who had completed an interview based on International Headache Society (IHS) criteria. Consistent with prevalence rates from other population-based studies, 703 (20%) female and 250 (9%) male twins satisfied the IHS criteria for migraine without aura (MO), and of these, 432 (13%) female and 166 (6%) male twins satisfied the criteria for migraine with aura (MA) as indicated by visual symptoms. Latent class analysis (LCA) of IHS symptoms identified three major symptomatic classes, representing 1) a mild form of recurrent nonmigrainous headache, 2) a moderately severe form of migraine, typically without visual aura symptoms (although 40% of individuals in this class were positive for aura), and 3) a severe form of migraine typically with visual aura symptoms (although 24% of individuals were negative for aura). Using the LCA classification, many more individuals were considered affected to some degree than when using IHS criteria (35% vs. 13%). Furthermore, genetic model fitting indicated a greater genetic contribution to migraine using the LCA classification (heritability, h(2)=0.40; 95% CI, 0.29-0.46) compared with the IHS classification (h(2)=0.36; 95% CI, 0.22-0.42). Exploratory latent class modeling, fitting up to 10 classes, did not identify classes corresponding to either the IHS MO or MA classification. Our data indicate the existence of a continuum of severity, with MA more severe but not etiologically distinct from MO. In searching for predisposing genes, we should therefore expect to find some genes that may underlie all major recurrent headache subtypes, with modifying genetic or environmental factors that may lead to differential expression of the liability for migraine.

Creating healthy food environments in NSW: A knowledge and evidence synthesis to inform advocacy and action. Seven separate documents across the domains: Food promotion

Reviews and synthesizes evidence to make recommendations on policy actions improve food environments in the area of food promotion for NSW Health

Creating healthy food environments in NSW: A knowledge and evidence synthesis to inform advocacy and action. Seven separate documents across the domains: Food retail

Reviews and synthesizes nutrition policy actions to improve food retail for NSW Health

Creating healthy food environments in NSW: A knowledge and evidence synthesis to inform advocacy and action. Seven separate documents across the domains: Overview

Summaries evidence across seven domains of potential food policy action to improve food environments and food supply to prevent obesity for NSW Health

Company taxation and tax spillovers: Separate accounting versus formula apportionment

It is observed in the real world that taxes matter for location decisions and that multinationals shift profits by transfer pricing. The US and Canada use so-called formula apportionment (FA) to tax corporate income, and the EU is debating a switch from separate accounting (SA) to FA. This paper develops a theoretical model that compares basic properties of FA to SA. The focal point of the analysis is how changes in tax rates affect capital formation, input choice, and transfer pricing, as well as on spillovers on tax revenue in other countries. The analysis shows that a move from SA to FA will not eliminate such spillovers and will, in cases identified in the paper, actually aggravate them.

The production of separate streams of pure hydrogen and carbon dioxide from coal via an iron-oxide redox cycle

A chemical looping process using the redox reactions of iron oxide has been used to produce separate streams of pure H2 and CO2 from a solid fuel. An iron oxide carrier prepared using a mechanical mixing technique and comprised of 100wt.% Fe2O3 was used. It was demonstrated that hydrogen can be produced from three representative coals - a Russian bituminous, a German lignite and a UK sub-bituminous coal. Depending on the fuel, pure H2 with [CO] ≲50vol.ppm can be obtained from the proposed process. The cyclic stability of the iron oxide carrier was not adversely affected by contaminants found in syngas which are gaseous above 273K. Stable quantities of H2 were produced over five cycles for all three coals investigated. Independent of the fuel, SO2 was not formed during the oxidation with steam, i.e. the produced H2 was not contaminated with SO2. Since oxidation with air removes contaminants and generates useful heat and pure N2 for purging, it should be included in the operating cycle. Overall, it was demonstrated that the proposed process may be an attractive approach to upgrade crude syngas produced by the gasification of low-rank coals to pure H2, representing a substantial increase in calorific value, whilst simultaneous capturing CO2, a greenhouse gas. © 2010 Elsevier B.V.

Ability of Urografin Density Gradients to Separate Nonculturable Subpopulations of Escherichia coli

Poster presentado a 11th International Symposium on Microbial Ecology(ISME -11)celebrado en Viena del 20 al 25 de agosto de 2006