Juridical double taxation by cross border transactions: the Block Case (C-67/08)

Treaty Establishing the European Community, operative until December 1st 2009, had already established in its article 2 the mission of the up until then European Community and actual European Union is to promote an harmonious, equilibrated and sustainable development of the economic activities of the whole Community. This Mission must be achieved by establishing a Common Market, an Economic and Monetary Union and the realization of Common Policies. One of the instruments to obtain these objectives is the use of free circulation of people, services and capitals inside the Common and Interior Market of the European Union. The European Union is characterized by the confirmation of the total movement of capitals, services and individuals and legal peoples’ freedom; freedom that was already predicated by the Maastricht Treaty, through the suppression of whatever obstacles which are in the way of the objectives before exposed. The old TEC in its Title III, now Title IV of the Treaty on the Functioning of the European Union, covered the free circulation of people, services and capitals. Consequently, the inclusion of this mechanism inside one of the regulating texts of the European Union indicates the importance this freedom supposes for the European Union objectives’ development. Once stood up the relevance of the free movement of people, services and capitals, we must mention that in this paper we are going to centre our study in one of these freedoms of movement: the free movement of capital. In order to analyze in detail the free movement of capital within the European framework, we are going to depart from the analysis of the existent case law of the Court of Justice of the European Union. The use of jurisprudence is basic to know how Community legislation is interpreted. For this reason, we are going to develop this work through judgements dictated by the European Union Court. This way we can observe how Member States’ regulating laws and the European Common Law affect the free movement of capital. The starting point of this paper will be the Judgement C-67/08 European Court of Justice of February 12th 2009, known as Block case. So, following the argumentation the Luxemburg Court did about the mentioned case, we are going to develop how free movement of capital could be affected by the current disparity of Member States’ legislation. This disparity can produce double taxation cases due to the lack of tax harmonized legislation within the interior market and the lack of treaties to avoid double taxation within the European Union. Developing this idea we are going to see how double taxation, at least indirectly, can infringe free movement of capital.

Dimensionality of drinking consequences - cross-cultural comparability and stability over time

Despite the long tradition for asking about the negative social and health consequences of alcohol consumption in surveys, little is known about the dimensionality of these consequences. Analysing cross-sectional and longitudinal data from the Nordic Taxation Study collected for Sweden, Finland, and Denmark in two waves in 2003 and 2004 by means of an explorative principal component analysis for categorical data (CATPCA), it is tested whether consequences have a single underlying dimension across cultures. It further tests the reliability, replicability, concurrent and predictive validity of the consequence scales. A one-dimensional solution was commonly preferable. Whereas the two-dimensional solution was unable to distinguish clearly between different concepts of consequences, the one-dimensional solution resulted in interpretable, generally very stable scales within countries across different samples and time.

Relationship of aerobic fitness and motor skills with memory and attention in preschoolers (Ballabeina): a cross-sectional and longitudinal study.

BACKGROUND: The debate about a possible relationship between aerobic fitness and motor skills with cognitive development in children has recently re-emerged, because of the decrease in children's aerobic fitness and the concomitant pressure of schools to enhance cognitive performance. As the literature in young children is scarce, we examined the cross-sectional and longitudinal relationship of aerobic fitness and motor skills with spatial working memory and attention in preschool children. METHODS: Data from 245 ethnically diverse preschool children (mean age: 5.2 (0.6) years, girls: 49.4%) analyzed at baseline and 9 months later. Assessments included aerobic fitness (20 m shuttle run) and motor skills with agility (obstacle course) and dynamic balance (balance beam). Cognitive parameters included spatial working memory (IDS) and attention (KHV-VK). All analyses were adjusted for age, sex, BMI, migration status, parental education, native language and linguistic region. Longitudinal analyses were additionally adjusted for the respective baseline value. RESULTS: In the cross-sectional analysis, aerobic fitness was associated with better attention (r=0.16, p=0.03). A shorter time in the agility test was independently associated with a better performance both in working memory (r=-0.17, p=0.01) and in attention (r=-0.20, p=0.01). In the longitudinal analyses, baseline aerobic fitness was independently related to improvements in attention (r=0.16, p=0.03), while baseline dynamic balance was associated with improvements in working memory (r=0.15, p=0.04). CONCLUSIONS: In young children, higher baseline aerobic fitness and motor skills were related to a better spatial working memory and/or attention at baseline, and to some extent also to their future improvements over the following 9 months. TRIAL REGISTRATION: clinicaltrials.gov NCT00674544.

Monogeneans of leatherjackets, Oligoplites spp. (Osteichthyes: Carangidae), with the description of a new species of Metacamopia (Monogenea: Allodiscocotylidae) from the coast of the State of Rio de Janeiro, Brazil

Metacamopia oligoplites n. sp., a gill filament parasite of carangid fishes of three species of Oligoplites Gill, O. palometa (Cuvier), O. saurus (Bloch & Schneider), and O. saliens (Bloch), from the coast of the State of Rio de Janeiro, Brazil, is described and illustrated. Metacamopia oligoplites n. sp. differs from M. indica by: the shape of the body; the pre-, para-, and post-germarial testes; vaginas lacking sclerotized structures; well-developed seminal receptacles; muscular sleeves around the constriction between the vaginas and the seminal receptacles; and the haptor highly asymmetric, with a large, heel-like area; and differs from M. chorinemi by: the esophagus lacking diverticles; a larger number of testes (26-55) and not just, approximately 10; and the vaginas lacking sclerotized structures of any kind. This is the first record of Metacamopia in the South Atlantic Ocean. The generic diagnosis of Metacamopia is emended. Hargicola oligoplites is reported for the first time in the South Atlantic Ocean. Oligoplites palometa and O. saliens are new host records for Hargicola oligoplites.

The Maggia cross-fold: An enigmatic structure of the lower Penninic nappes of the Lepontine Alps

The geometry and kinematics of the map scale Maggia cross-fold structure has been studied by several generations of geologists over seventy years and different models have been proposed for its formation. New observations indicate that the Maggia structure is a SW-verging cross-fold created after earlier NW-directed overthrusting of the Maggia nappe onto the deeper Simano and Antigorio recumbent fold nappes. The nappe emplacement and later cross-folding occurred under amphibolite facies conditions by detachment of the upper European crust during its SE-directed underthrusting below the Adriatic plate.

Trypanorhynch Cestodes of Commercial Fishes from Northeast Brazilian Coastal Waters

A large scale investigation on trypanorhynch cestode infestation of tropical marine fishes was carried out along the Northeast Brazilian coast in the summer of 1991 and 1993. A total of 798 fish specimens belonging to 57 species and 30 families were examined. Metacestodes of 11 different trypanorhynchs were found: Callitetrarhynchus gracilis, Dasyrhynchus giganteus, Grillotia sp., Nybelinia edwinlintoni, N. indica, N. senegalensis, Nybelinia c.f. lingualis, Otobothrium cysticum, Pseudolacistorhynchus noodti, Pseudotobothrium dipsacum and Pterobothrium kingstoni. Scanning electron microscopy was used to clarify details of the tentacular armature of some species. Rose-thorn shaped hooklets, regularly arranged like microtriches, are described from the bothridial surface of N. edwinlintoni. Of the 57 fish species, 15 harboured trypanorhynch cestodes. Of these the mullid Pseudupeneus maculatus was the most heavily infested fish species, harbouring 5 different trypanorhynch species. P. noodti in P. maculatus had the highest prevalence (87%) and intensity (maximum = 63) of infestation. C. gracilis was the parasite with the lowest host-specificity. It could be isolated from 10 fish species. The cestode fauna of the Northeast Brazilian coast appears to be similar to that of the West African coast. Five of the trypanorhynch cestodes found during this study are common to both localities. The two single cases of intra musculature infestation in Citharichthys spilopterus and Haemulon aurolineatum by trypanorhynch cestodes indicate that marketability of the investigated commercially exploited fish species is inconsequential.

Insight into cross-talk between intra-amoebal pathogens.

Abstract: Background: Amoebae are phagocytic protists where genetic exchanges might take place between amoeba-resistant bacteria. These amoebal pathogens are able to escape the phagocytic behaviour of their host. They belong to different bacterial phyla and often show a larger genome size than human-infecting pathogens. This characteristic is proposed to be the result of frequent gene exchanges with other bacteria that share a sympatric lifestyle and contrasts with the genome reduction observed among strict human pathogens.Results: We sequenced the genome of a new amoebal pathogen, Legionella drancourtii, and compared its gene content to that of a Chlamydia-related bacterium, Parachlamydia acanthamoebae. Phylogenetic reconstructions identified seven potential horizontal gene transfers (HGTs) between the two amoeba-resistant bacteria, including a complete operon of four genes that encodes an ABC-type transporter. These comparisons pinpointed potential cases of gene exchange between P. acanthamoebae and Legionella pneumophila, as well as gene exchanges between other members of the Legionellales and Chlamydiales orders. Moreover, nine cases represent possible HGTs between representatives from the Legionellales or Chlamydiales and members of the Rickettsiales order.Conclusions: This study identifies numerous gene exchanges between intracellular Legionellales and Chlamydiales bacteria, which could preferentially occur within common inclusions in their amoebal hosts. Therefore it contributes to improve our knowledge on the intra-amoebal gene properties associated to their specific lifestyle.

Sensitivity of Leishmania spp. to Glibenclamide and 4-Aminopiridine: A Tool for the Study of Drug Resistance Development

We have demonstrated that Leishmania spp. grown as promastigotes, are sensitive to the K+ channel inhibitors 4-aminopyridine and glibenclamide. Their host cells, the macrophages, are not affected by similar concentrations of the drugs. We have also initiated the molecular characterization of the mechanisms involved in the development of drug resistance to glibenclamide by the parasite. Therefore, we have selected experimentally and begun to characterize the Venezuelan Leishmania (Leishmania) strain, NR resistant to glibenclamide [NR(Gr)]. The analysis of genomic DNA evidenced the existence of a fragment which apparently is amplified in NR(Gr). The fragment recognized by the pgpA probe, related to the Leishmania P-glycoprotein family and which was originally isolated from L. tarentolae, showed a size polymorfism between the sensitive and the resistant strain. These results suggest that the development of resistance to glibenclamide in the strain NR(Gr) might be associated with the amplification of the ltpgpA or related gene(s)

The Influence of Self-fertilization performance and Copulation Behaviour in Reproduction by Cross-fertilization in Groups of Biomphalaria tenagophila (Mollusca, Planorbidae)

The following hypotheses were tested for groups of simultaneous hermaphrodites Biomphalaria tenagophila: (a) snails that have low reproductive success during the process of self-fertilization do not increase their reproductive success after the end of grouping; (b) the copulation behaviour and the presence of one snail whose eggs have a low viability rate influence the partner's reproductive success by cross-fertilization. Groups were constituted by a homozygous pigmented snail and two albinos: one with a viability rate higher than 70% ("good reproducers") and the other less than 10% ("bad reproducers"). All pigmented snails had viability rates higher than 70%. The "good" and "bad" reproducer albino snails had similar copulation behaviour. However, after the end of grouping, the "bad reproducers" continued to have viability rates less than 10% over 30 days. In 100% of the cases that pigmented snails copulated (performing either a male role or simultaneously male and female roles) exclusively with "good" reproducer albinos, they presented high reproductive success (producing, on average of 8.4 pigmented embryos/egg-mass). However, in 100% of the cases that pigmented snails copulated with both partners, the "good" reproducer albino snails produced none or very few embryos (the highest average was 2.2 pigmented embryos/egg-mass). Therefore, the production of viable embryos by cross-fertilization was more influenced by self-fertilization performance than by copulation behaviour. The presence of a snail whose eggs have a low viability rate could decrease their partners reproductive success

Cross-country polarisation in CO2 emissions per capita in the European Union: changes and explanatory factors

In this study, we analyse the degree of polarisation-a concept fundamentally different from that of inequality-in the international distribution of CO2 emissions per capita in the European Union. It is analytically relevant to examine the degree of instability inherent to a distribution and, in the analysed case, the likelihood that the distribution and its evolution will increase or decrease the chances of reaching an agreement. Two approaches were used to measure polarisation: the endogenous approach, in which countries are grouped according to their similarity in terms of emissions, and the exogenous approach, in which countries are grouped geographically. Our findings indicate a clear decrease in polarisation since the mid-1990s, which can essentially be explained by the fact that the different groups of countries have converged (i.e. antagonism among the CO2 emitters has decreased) as the contribution of energy intensity to between-group differences has decreased. This lower degree of polarisation in CO2 distribution suggests a situation more conducive to the possibility of reaching EU-wide agreements on the mitigation of CO2 emissions.

Seguiment de la tortuga mediterrània (Testudo hermanni spp. hermanni) a Catalunya: història, hàbitat, cria i introducció (el cas del Parc del Garraf)

El present projecte pretén donar una visió de la situació actual de la tortuga mediterrània (Testudo hermanni hermanni) a Catalunya, incloent un estudi més exhaustiu del cas del Garraf. Aquesta subespècie, que segons el registre fòssil es present a Catalunya des del neolític, troba actualment espais com la Serra del Montsant, l’Albera, el delta de l’Ebre o el Massís de Garraf, hàbitats potencials per al seu desenvolupament. En el cas del Garraf, dels resultats obtinguts, cal destacar l’alt grau de desconeixença que els visitants del Parc tenen sobre la tortuga mediterrània, i es per això, que cal portar a terme un programa d’educació ambiental, amb efectes també de reduir el número d’espolis d’exemplars, que s’estima en 4 exemplars a l’any. Altres factors com els incendis o les depredacions també són factors importants en el declivi de les poblacions.