Full Circle or Spiralling Out of Control?: State Violence and the Control of Urbanisation in Papua New Guinea

There is an administrative reluctance to recognise the permanency of urban settlement in Papua New Guinea. This reluctance, evident since the 1960s, has been characteristic of both the colonial and post-colonial administrations. Opposition to some facets of urbanisation continues today, despite growing population and land pressures in most rural areas and real problems of landlessness emerging in particular rural areas. Colonial control of urban populations has been replicated in contemporary times, often in more draconian form. Eviction of urban settlers has been tied to issues of crime and urban respectability, and lingering perceptions that Melanesians should be rural residents. The growth of informal settlements and urbanisation are not seen as issues of urban planning, nor is the context of urban migration linked to socioeconomic inequality, hence other forms of urban policy are largely absent. Strengthening alliances between land-owners and the state (especially police and provincial administrations) have thus emphasised intraurban inequality and hampered national development

BEPS and country-by-country reporting: a step closer towards formulary apportionment?

Transparency represents today a key issue on the agendas of international and domestic tax policy makers. Improving the access and the exchange of relevant tax information and removing existing bank and tax secrecy regimes is currently seen as the most effective tool, together with the identification of harmful tax regimes and practices, to counter both tax evasion and harmful or aggressive tax competition. Action item13 of the BEPS Action Plan suggests to reform the structure of the transfer pricing documentation and introduce a new reporting requirement in the form of a countryby-country reporting template. Although such new reporting requirement is meant to provide an informative tool for the up-front identification of transfer pricing risks within the group, its unexpected area of application may become the improvement of the global acceptance of the formulary apportionment idea for the allocation of multinational enterprises’ profits. This article aims to provide a critical review of the proposed template and assess its potential in reviving the debate on formulary apportionment. Keywords: BEPS, taxation of MNE’s, country-by-country reporting, tax transparency, formulary apportionmen