La fiscalità delle perdite dei gruppi transfrontalieri: tra regimi nazionali e libertà di stabilimento

Caratteristica comune ai regimi di consolidamento previsti dai diversi ordinamenti, è quella di consentire la compensazione tra utili e perdite di società residenti, e, di negare, o rendere particolarmente difficoltosa, la stessa compensazione, quando le perdite sono maturate da società non residenti. La non considerazione delle perdite comporta una tassazione al lordo del gruppo multinazionale, per mezzo della quale, non si colpisce il reddito effettivo dei soggetti che vi appartengono. L’effetto immediato è quello di disincentivare i gruppi a travalicare i confini nazionali. Ciò impedisce il funzionamento del Mercato unico, a scapito della libertà di stabilimento prevista dagli artt. 49-54 del TFUE. Le previsioni ivi contenute sono infatti dirette, oltre ad assicurare a società straniere il beneficio della disciplina dello Stato membro ospitante, a proibire altresì allo Stato di origine di ostacolare lo stabilimento in un altro Stato membro dei propri cittadini o delle società costituite conformemente alla propria legislazione. Gli Stati membri giustificano la discriminazione tra società residenti e non residenti alla luce della riserva di competenza tributaria ad essi riconosciuta dall’ordinamento europeo in materia delle imposte dirette, dunque, in base all’equilibrata ripartizione del potere impositivo. In assenza di qualsiasi riferimento normativo, va ascritto alla Corte di Giustizia il ruolo di interprete del diritto europeo. La Suprema Corte, con una serie di importanti pronunce, ha infatti sindacato la compatibilità con il diritto comunitario dei vari regimi interni che negano la compensazione transfrontaliera delle perdite. Nel verificare la compatibilità con il diritto comunitario di tali discipline, la Corte ha tentato di raggiungere un (difficile) equilibrio tra due interessi completamenti contrapposti: quello comunitario, riconducibile al rispetto della libertà di stabilimento, quello degli Stati membri, che rivendicano il diritto di esercitare il proprio potere impositivo.

A "Beyond WTO" Scenario for Swiss Agriculture: Consequences for Income Generation and the Provision of Public Goods

The conclusion of the Doha Round negotiations is likely to influence Swiss agricultural policy substantially. The same goes for a free trade agreement in agriculture and food with the European Communities. Even though neither of them will bring about duty-free and quota-free market access, or restrict domestic support measures to green box compatible support, both would represent a big step in that direction. There is no empirical evidence on the effect of such a counterfactual scenario for Swiss agriculture. We therefore use a normative mathematical programming model to illustrate possible effects for agricultural production and the corresponding agricultural income. Moreover, we discuss the results with respect to the provision of public goods under the assumption of continuing green box-compatible direct payments. The aim of our article is to bring more transparency into the discussion on the effects of freer and less distorted trade on the income generation by a multifunctional agriculture. The article will be organized as follows. In the first Section we specify the background of our study. In the second section, we focus on the problem statement and our research questions. In Section 3, we describe in detail a counterfactual scenario of “duty-free, quota-free and price support-free” agriculture from an economic as well as a legal perspective. Our methodology and the results are presented in Section 4 and 5 respectively. In Section 6, we discuss our results with respect to economic and legal aspects of multifunctional agriculture.

Vulnerability to risk among small farmers in Tajikistan: results of a 2011 survey

Tajikistan is judged to be highly vulnerable to risk, including food insecurity risks and climate change risks. By some vulnerability measures it is the most vulnerable among all 28 countries in the World Bank’s Europe and Central Asia Region – ECA (World Bank 2009). The rural population, with its relatively high incidence of poverty, is particularly vulnerable. The Pilot Program for Climate Resilience (PPCR) in Tajikistan (2011) provided an opportunity to conduct a farm-level survey with the objective of assessing various dimensions of rural population’s vulnerability to risk and their perception of constraints to farming operations and livelihoods. The survey should be accordingly referred to as the 2011 PPCR survey. The rural population in Tajikistan is highly agrarian, with about 50% of family income deriving from agriculture (see Figure 4.1; also LSMS 2007 – own calculations). Tajikistan’s agriculture basically consists of two groups of producers: small household plots – the successors of Soviet “private agriculture” – and dehkan (or “peasant”) farms – new family farming structures that began to be created under relevant legislation passed after 1992 (Lerman and Sedik, 2008). The household plots manage 20% of arable land and produce 65% of gross agricultural output (GAO). Dehkan farms manage 65% of arable land and produce close to 30% of GAO. The remaining 15% of arable land is held in agricultural enterprises – the rapidly shrinking sector of corporate farms that succeeded the Soviet kolkhozes and sovkhozes and today produces less than 10% of GAO (TajStat 2011) The survey conducted in May 2011 focused on dehkan farms, as budgetary constraints precluded the inclusion of household plots. A total of 142 dehkan farms were surveyed in face-to-face interviews. They were sampled from 17 districts across all four regions – Sughd, Khatlon, RRP, and GBAO. The districts were selected so as to represent different agro-climatic zones, different vulnerability zones (based on the World Bank (2011) vulnerability assessment), and different food-insecurity zones (based on WFP/IPC assessments). Within each district, 3-4 jamoats were chosen at random and 2-3 farms were selected in each jamoat from lists provided by jamoat administration so as to maximize the variability by farm characteristics. The sample design by region/district is presented in Table A, which also shows the agro-climatic zone and the food security phase for each district. The sample districts are superimposed on a map of food security phases based on IPC April 2011.

Understanding Economic Biases in Representation: Income, Resources, and Policy Representation in the 110th House

This article explores the extent, and possible causes, of income-based biases in representation of citizens by members of the 110th Congress. The author finds that the preferences of wealthier citizens are modestly but significantly better reflected in the choices of their congressional representatives than are the preferences of poorer citizens. More importantly, the author shows that education, political sophistication, political engagement, ethnicity, and other sociodemographic factors can explain only a small part of this representation gap. Biases in representation across income lines appear to be driven by income alone, or at least not by politically relevant factors correlated with income.

Tuberculosis in HIV programmes in lower-income countries: practices and risk factors

BACKGROUND: Tuberculosis (TB) is a common diagnosis in human immunodeficiency virus (HIV) infected patients on antiretroviral treatment (ART). OBJECTIVE: To describe TB-related practices in ART programmes in lower-income countries and identify risk factors for TB in the first year of ART. METHODS: Programme characteristics were assessed using standardised electronic questionnaire. Patient data from 2003 to 2008 were analysed and incidence rate ratios (IRRs) calculated using Poisson regression models. RESULTS: Fifteen ART programmes in 12 countries in Africa, South America and Asia were included. Chest X-ray, sputum microscopy and culture were available free of charge in respectively 13 (86.7%), 14 (93.3%) and eight (53.3%) programmes. Eight sites (53.3%) used directly observed treatment and five (33.3%) routinely administered isoniazid preventive treatment (IPT). A total of 19 413 patients aged ≥16 years contributed 13 227 person-years of follow-up; 1081 new TB events were diagnosed. Risk factors included CD4 cell count (>350 cells/μl vs. <25 cells/μl, adjusted IRR 0.46, 95%CI 0.33–0.64, P < 0.0001), sex (women vs. men, adjusted IRR 0.77, 95%CI 0.68–0.88, P = 0.0001) and use of IPT (IRR 0.24, 95%CI 0.19–0.31, P < 0.0001). CONCLUSIONS: Diagnostic capacity and practices vary widely across ART programmes. IPT prevented TB, but was used in few programmes. More efforts are needed to reduce the burden of TB in HIV co-infected patients in lower income countries.

Income, Trade and Pollution in Central Asia, Russia and China: An Econometric Analysis

The study performs a panel estimation of the relationship between per capita income, trade, and airborne pollution in the five Central Asian nations, Russia and China between 1992 and 2008. First, this study uses an environmental Kuznets curve hypothesis (EKC)- an inverted-U relationship between the increase in income and the level of environmental degradation - to examine how income and pollution are related. Second, the study uses a gravity model to estimate the effect of a regional trade agreement (Shanghai Cooperation Organization: SCO) on incomes and carbon dioxide emissions in the region. Empirical analysis confirms the existence of the rising portion of the EKC curve in the region - a positive correlation between per capita income growth and carbon dioxide emissions- and that the volume of bilateral trade, and not the existence of a regional trade agreement, contributes to the increasing level of environmental pollution.

Income, Trade and Pollution in Central Asia, Russia and China: An Econometric Analysis

The study performs a panel estimation of the relationship between per capita income, trade, and airborne pollution in the five Central Asian nations, Russia and China between 1992 and 2008. First, this study uses an environmental Kuznets curve hypothesis (EKC)- an inverted-U relationship between the increase in income and the level of environmental degradation - to examine how income and pollution are related. Second, the study uses a gravity model to estimate the effect of a regional trade agreement (Shanghai Cooperation Organization: SCO) on incomes and carbon dioxide emissions in the region. Empirical analysis confirms the existence of the rising portion of the EKC curve in the region - a positive correlation between per capita income growth and carbon dioxide emissions- and that the volume of bilateral trade, and not the existence of a regional trade agreement, contributes to the increasing level of environmental pollution.

Gross total resection rates in contemporary glioblastoma surgery: results of an institutional protocol combining 5-aminolevulinic acid intraoperative fluorescence imaging and brain mapping

Complete resection of contrast-enhancing tumor has been recognized as an important prognostic factor in patients with glioblastoma and is a primary goal of surgery. Various intraoperative technologies have recently been introduced to improve glioma surgery.

Impact of antiretroviral therapy on tuberculosis incidence among HIV-positive patients in high-income countries

The lower tuberculosis incidence reported in human immunodeficiency virus (HIV)-positive individuals receiving combined antiretroviral therapy (cART) is difficult to interpret causally. Furthermore, the role of unmasking immune reconstitution inflammatory syndrome (IRIS) is unclear. We aim to estimate the effect of cART on tuberculosis incidence in HIV-positive individuals in high-income countries.