(Des)vantagens do regime especial de tributação dos grupos de sociedades

Dissertação para obtenção do Grau de Mestre em Contabilidade e Finanças Orientador: Mestre, Gabriela Pinheiro

L’elusione fiscale nell’IVA e l’antielusione nell’esperienza comunitaria e nazionale in Europa

La ricerca oggetto della tesi riguarda la disamina delle esperienze comunitarie e nazionali in Europa in materia di elusione IVA ed antielusione IVA, al fine di esaminare le utilizzabili esperienze in materia per la Cina che dovrebbe iniziare a prendere le giuste azioni per fronteggiare il problema della crescente diffusione dei fenomeni dell’elusione IVA, in particolare nel contesto della riforma perdurante dell’IVA cinese verso il modello moderno. A questo fine, prima la tesi ha analizzato dettagliatamente le seguenti principali questioni sulla base delle esperienze comunitarie e nazionali dei determinati Stati Membri dell’UE: la definizione dell’elusione fiscale generale (a tale proposito, più rilevanti le differenze tra elusione fiscale ed altri relativi concetti come risparmio d’imposta, evasione fiscale e simulazione e la relazione intrinseca tra elusione fiscale ed altri relativi concetti come frode alla legge ed abuso del diritto), la definizione dell’elusione IVA (a tale proposito, più rilevanti gli aspetti di particolare interesse ai fini della definizione dell’elusione IVA), i principi e metodologie dell’elusione IVA, le applicazioni delle varie misure antielusive rivolte all’elusione IVA nell’ordinamento comunitario e negli ordinamenti interni degli alcuni principali Stati Membri dell’UE (a tale proposito, più rilevanti l’applicazone del principio Halifax, quale norma antielusiva generale basata sul principio di divieto dell’abuso del diritto, e la considerazione delle altre soluzioni antielusive applicabili nell’IVA, comprese correzioni normative e clausole antielusive specifiche), gli effetti dell’antielusione IVA e i limiti entro cui l’autorità impositiva può esercitare l’antielusione IVA per la tutela degli interessi legittimi dei soggetti passivi come certezza giuridica ed autonomia contrattuale. Poi, la tesi ha avanzato le proposte relative al perfezionamento delle soluzioni antielusive IVA nell’ordinamento tributario cinese, dopo presentati i principali regimi attuali dell’IVA cinese e analizzate le situazioni attuali realtive all’elusione IVA e all’antielusione IVA nel sistema fiscale cinese.

On the relation between tax rates and evasion in a multi-period economy

We extend the basic tax evasion model to a multi-period economy exhibiting sustained growth. When individuals conceal part of their true income from the tax authority, they face the risk of being audited and hence of paying the corresponding fine. Both taxes and fines determine individual saving and the rate of capital accumulation. In this context we show that the sign of the relation between the level of the tax rate and the amount of evaded income is the same as that obtained in static setups. Moreover, high tax rates on income are typically associated with low growth rates as occurs in standard growth models that disregard the tax evasion phenomenon.

Tax performance and reform in the Organization of Eastern Caribbean States (OECS)

Includes bibliography

Energy saving and solar electricity in fan-ventilated greenhouses

Greenhouse cultivation is an energy intensive process therefore it is worthwhile to introduce energy saving measures and alternative energy sources. Here we show that there is scope for energy saving in fan ventilated greenhouses. Measurements of electricity usage as a function of fan speed have been performed for two models of 1.25 m diameter greenhouse fans and compared to theoretical values. Reducing the speed can cut the energy usage per volume of air moved by more than 70%. To minimize the capital cost of low-speed operation, a cooled greenhouse has been built in which the fan speed responds to sunlight such that full speed is reached only around noon. The energy saving is about 40% compared to constant speed operation. Direct operation of fans from solar-photovoltaic modules is also viable as shown from experiments with a fan driven by a brushless DC motor. On comparing the Net Present Value costs of the different systems over a 10 year amortization period (with and without a carbon tax to represent environmental costs) we find that sunlight-controlled system saves money under all assumptions about taxation and discount rates. The solar-powered system, however, is only profitable for very low discount rates, due to the high initial capital costs. Nonetheless this system could be of interest for its reliability in developing countries where mains electricity is intermittent. We recommend that greenhouse fan manufacturers improve the availability of energy-saving designs such as those described here.

Property Exchange Rules Offer Tax Opportunities for Hotel Owners

One strategy often overlooked by hospitality owners in developing cost-saving strategies is the use of like-kind exchanges to acquire property. The author reviews some alternative methods of like-kind exchanges, which may not only provide new business opportunities for the hospitality owner, but lucrative tax benefits as well.

Saving our science from ourselves: the plight of biological classification

Saving our science from ourselves: the plight of biological classification. Biological classification ( nomenclature, taxonomy, and systematics) is being sold short. The desire for new technologies, faster and cheaper taxonomic descriptions, identifications, and revisions is symptomatic of a lack of appreciation and understanding of classification. The problem of gadget-driven science, a lack of best practice and the inability to accept classification as a descriptive and empirical science are discussed. The worst cases scenario is a future in which classifications are purely artificial and uninformative.

HTLV-1 Tax Specific CD8+ T Cells Express Low Levels of Tim-3 in HTLV-1 Infection: Implications for Progression to Neurological Complications

The T cell immunoglobulin mucin 3 (Tim-3) receptor is highly expressed on HIV-1-specific T cells, rendering them partially ""exhausted'' and unable to contribute to the effective immune mediated control of viral replication. To elucidate novel mechanisms contributing to the HTLV-1 neurological complex and its classic neurological presentation called HAM/TSP (HTLV-1 associated myelopathy/tropical spastic paraparesis), we investigated the expression of the Tim-3 receptor on CD8(+) T cells from a cohort of HTLV-1 seropositive asymptomatic and symptomatic patients. Patients diagnosed with HAM/TSP down-regulated Tim-3 expression on both CD8(+) and CD4(+) T cells compared to asymptomatic patients and HTLV-1 seronegative controls. HTLV-1 Tax-specific, HLA-A*02 restricted CD8(+) T cells among HAM/TSP individuals expressed markedly lower levels of Tim-3. We observed Tax expressing cells in both Tim-3(+) and Tim-3(-) fractions. Taken together, these data indicate that there is a systematic downregulation of Tim-3 levels on T cells in HTLV-1 infection, sustaining a profoundly highly active population of potentially pathogenic T cells that may allow for the development of HTLV-1 complications.

Tax Cost of Investment Projects: the case of ICMS credits

This article discusses the impact on the profitability of firms under Complementary Law 102/2000 (which abrogated the Law 89/96 - Kandir Law) allowing the appropriation of ICMS credits, due to investment in fixed assets goods, at a ratio of 1/48 per month. The paper seeks to demonstrate how this new system - which resulted in the transformation of the ICMS as a value added tax (VAT) consumption-type to an income-type - leads to a loss of approximately 30% of the value of credits to be recovered and the effect it generates on the cost of investment and the profits for small, medium and large firms. From the methodological point of view, it is a descriptive and quantitative research, which proceeded in three stages. Initially, we have obtained estimated value of net sales and volume of investments, based on report Painel de Competitividade prepared by the Federacao das Indtustrias do Estado de Sao Paulo (Fiesp/Serasa). Based on this information, it was possible to obtain estimates of the factors of generation of debits and credits for ICMS, using the model Credit Control of Fixed Assets (CIAP). Finally, we have calculated three indicators: (i) present value of debt recovery/value of credits, (ii) present value of debt recovery / investment value, (iii) present value of debt recovery / sales profitability. We have conclude that the system introduced by Complementary Law 102/2000 implicates great opportunity cost for firms and that legislation should be reviewed from this perspective, aiming to ensure lower costs associated with investment projects.

An initial assessment of policies for saving a rare Australian glider: Experimental results, economics and ecology

Reviews the ecological status of the mahogany glider and describes its distribution, habitat and abundance, life history and threats to it. Three serial surveys of Brisbane residents provide data on the knowledge of respondents about the mahogany glider. The results provide information about the attitudes of respondents to the mahogany glider, to its conservation and relevant public policies and about variations in these factors as the knowledge of participants of the mahogany glider alters. Similarly data is provided and analysed about the willingness to pay of respondents to conserve the mahogany glider. Population viability analysis is applied to estimate the required habitat area for a minimum viable population of the mahogany glider to ensure at least a 95% probability of its survival for 100 years. Places are identified in Queensland where the requisite minimum area of critical habitat can be conserved. Using the survey results as a basis, the likely willingness of groups of Australians to pay for the conservation of the mahogany glider is estimated and consequently their willingness to pay for the minimum required area of its habitat. Methods for estimating the cost of protecting this habitat are outlined. Australia-wide benefits seem to exceed the costs. Establishing a national park containing the minimum viable population of the mahogany glider is an appealing management option. This would also be beneficial in conserving other endangered wildlife species. Therefore, additional economic benefits to those estimated on account of the mahogany glider itself can be obtained.

Heterogeneity, saving-investment dynamics and capital mobility in Latin America

The purpose of this paper is to analyze the dynamics of national saving-investment relationship in order to determine the degree of capital mobility in 12 Latin American countries. The analytically relevant correlation is the short-term one, defined as that between changes in saving and investment. Of special interest is the speed at which variables return to the long run equilibrium relationship, which is interpreted as being negatively related to the degree of capital mobility. The long run correlation, in turn, captures the coefficient implied by the solvency constraint. We find that heterogeneity and cross-section dependence completely change the estimation of the long run coefficient. Besides we obtain a more precise short run coefficient estimate compared to the existent estimates in the literature. There is evidence of an intermediate degree of capital mobility, and the coefficients are extremely stable over time.

Optimizing the CAMCOG test in the screening for mild cognitive impairment and incipient dementia: saving time with relevant domains

Objective: To identify the CAMCOG sub-items that best contribute for the identification of patients with mild cognitive impairment (MCI) and incipient Alzheimer`s disease (AD) in clinical practice. Methods: Cross-sectional assessment of 272 older adults (98 MCI, 82 AD, and 92 controls) with a standardized neuropsychological battery and the CAMCOG schedule. Backward logistic regression analysis with diagnosis (MCI and controls) as dependent variable and the sub-items of the CAMCOG as independent variable was carried out to determine the CAMCOG sub-items that predicted the diagnosis of MCI. Results: Lower scores on Language, Memory, Praxis, and Calculation CAMCOG sub-items were significantly associated with the diagnosis of MCI. A composite score obtained by the sum of these scores significantly discriminated MCI patients from comparison groups. This reduced version of the CAMCOG showed similar diagnostic accuracy than the original schedule for the identification of patients with MCI as compared to controls (AUC = 0.80 +/- 0.03 for the reduced CAMCOG; AUC = 0.79 +/- 0.03 for the original CAMCOG). Conclusion: This reduced version of the CAMCOG had similar diagnostic properties as the original CAMCOG and was faster and easier to administer, rendering it more suitable for the screening of subtle cognitive deficits in general clinical practice. Copyright (C) 2010 John Wiley & Sons, Ltd.

The net benefit of saving the Asian Elephant: A policy and contingent valuation Study

Reports results from a contingent valuation survey of willingness to pay for the conservation of the Asian elephant of a sample of urban residents living in three selected housing schemes in Colombo, the capital of Sri Lanka. Face–to–face surveys were conducted using an interview schedule. A non-linear logit regression model is used to analyse the respondents’ responses for the payment principle questions and to identify the factors that influence their responses. We investigate whether urban residents’ willingness to pay for the conservation of elephants is sufficient to compensate farmers for the damage caused by elephants. We find that the beneficiaries (the urban residents) could compensate losers (the farmers in the areas affected by human–elephant conflict) and be better off than in the absence of elephants in Sri Lanka. Therefore, there is a strong economic case for the conservation of the wild elephant population in Sri Lanka. However, we have insufficient data to determine the optimal level of this elephant population in the Kaldor-Hicks sense. Nevertheless, the current population of elephant in Sri Lanka is Kaldor-Hicks preferable to having none.