Transfer pricing en het conceptwetsvoorstel ‘Wet tegengaan mismatches bij toepassing zakelijkheidsbeginsel’

Op 4 maart 2021 werd het conceptwetsvoorstel ‘Wet tegengaan mismatches bij toepassing zakelijkheidsbeginsel’ (hierna: het conceptwetsvoorstel) ter consultatie aangeboden. Publiek commentaar was mogelijk tot 2 april 2021. Staatssecretaris Vijlbrief heeft in een brief van 5 juli 2021 aangegeven dat het conceptwetsvoorstel naar verwachting deze zomer wordt ingediend bij de Tweede Kamer, naast het pakket Belastingplan 2022. De beoogde ingangsdatum van het conceptwetsvoorstel is 1 januari 2022. De algemene reacties die tot dusverre publiekelijk beschikbaar zijn op https://www.internetconsultatie.nl/verrekenprijsverschillen zijn fors kritisch op het conceptwetsvoorstel. Op basis daarvan leek het vooralsnog onzeker dat het conceptwetsvoorstel in haar huidige vorm gestand blijft. Op 1 september 2021 heeft de Afdeling Advisering van de Raad van State een advies vastgesteld en naar de Tweede Kamer gestuurd, dat later deze maand aan de orde komt. Hierna bespreken wij het conceptwetsvoorstel en kijken we met name naar de betekenis ervan voor de verrekenprijspraktijk. We sluiten af met een aantal aanbevelingen

Daily Affect and Daily Prospective Memory in People after Stroke and Their Partners: The Moderating Role of Resting Heart Rate

Introduction: Experimental research suggests that affect may influence prospective memory performance, but real-life evidence on affect-prospective memory associations is limited. Moreover, most studies have examined the valence dimension of affect in understanding the influence of affect on cognitive performance in daily life, with insufficient consideration of the arousal dimension. To maximize ecological validity, the current study examined the relationships between daily affect and daily prospective memory using repeated daily assessments and the role of resting heart rate on these relationships. We examined both valence and arousal of daily affect by categorizing affect into four dimensions: high-arousal positive affect, low-arousal positive affect, high-arousal negative affect, and low-arousal negative affect. Method: We examined existing data collected from community-dwelling couples, of which at least one partner had a stroke history. The analytic sample included 111 adults (Mage = 67.46 years, SD = 9.64; 50% women) who provided 1,274 days of data. Among the participants, 58 were living with the effects of a stroke and 53 were partners. Participants completed daily event-based prospective memory tasks (in morning and/or evening questionnaires), reported daily affect in the evening, and wore a wrist-based Fitbit device to monitor resting heart rate over 14 consecutive days. Results: Results from multilevel models show that, within persons, elevated high-arousal negative affect was associated with worse daily prospective memory performance. In addition, lower resting heart rate attenuated the inverse association between high-arousal negative affect and lowered prospective memory performance. We did not find significant associations of high- or low-arousal positive affect and low-arousal negative affect with daily prospective memory. Discussion: Our findings are in line with the resource allocation model and the cue-utilization hypothesis in that high-arousal negative affect is detrimental to daily prospective memory performance. Lower resting heart rate may buffer individuals’ prospective memory performance from the influence of high-arousal negative affect. These findings are consistent with the neurovisceral integration model on heart-brain connections, highlighting the possibility that cardiovascular fitness may help maintain prospective memory into older adulthood

The role of genetics and epigenetics in the pathogenesis of systemic sclerosis

Systemic sclerosis (SSc) is a complex autoimmune disease of unclear aetiology. A multitude of genetic studies, ranging from candidate-gene studies to genome-wide association studies, have identified a large number of genetic susceptibility factors for SSc and its clinical phenotypes, but the contribution of these factors to disease susceptibility is only modest. However, in an endeavour to explore how the environment might affect genetic susceptibility, epigenetic research into SSc is rapidly expanding. Orchestrated by environmental factors, epigenetic modifications can drive genetically predisposed individuals to develop autoimmunity, and are thought to represent the crossroads between the environment and genetics in SSc. Therefore, in addition to providing a comprehensive description of the current understanding of genetic susceptibility underlying SSc, this Review describes the involvement of epigenetic phenomena, including DNA methylation patterns, histone modifications and microRNAs, in SSc

Unraveling the Impact of Malaria Exposure Before Birth

Lars Hviid discusses a research article in PLoS Medicine that explores whether prenatal exposure to malaria is associated with increased susceptibility to malarial infection and anemia in infancy

The immunologic etiology of psychiatric manifestations in systemic lupus erythematosus: a narrative review on the role of the blood brain barrier, antibodies, cytokines and chemokines

Introduction: The aim of this narrative review is to provide an overview of the literature on the possible immunologic pathophysiology of psychiatric manifestations of neuropsychiatric systemic lupus erythematosus (NPSLE).Methods: A systematic search on PubMed was conducted. English studies with full text availability that investigated the correlation between blood-brain barrier (BBB) dysfunction, intrathecal synthesis of antibodies, antibodies, cytokines, chemokines, metalloproteinases, complement and psychiatric NPSLE manifestations in adults were included.Results: Both transient BBB-dysfunction with consequent access of antibodies to the cerebrospinal fluid (CSF) and intrathecal synthesis of antibodies could occur in psychiatric NPSLE. Anti-phospholipid antibodies, anti-NMDA antibodies and anti-ribosomal protein p antibodies seem to mediate concentration dependent neuronal dysfunction. Interferon-a may induce microglial engulfment of neurons, direct neuronal damage and production of cytokines and chemokines in psychiatric NPSLE. Several cytokines, chemokines and matrix metalloproteinase-9 may contribute to the pathophysiology of psychiatric NPSLE by attracting and activating Th1-cells and B-cells.Discussion: This potential pathophysiology may help understand NPSLE and may have implications for the diagnostic management and therapy of psychiatric NPSLE. However, the presented pathophysiological model is based on correlations between potential immunologic etiologies and psychiatric NPSLE that remain questionable. More research on this topic is necessary to further elucidate the pathophysiology of NPSLE.Paroxysmal Cerebral Disorder

A replication study confirms the association of TNFSF4 (OX40L) polymorphisms with systemic sclerosis in a large European cohort

<p><b>Objectives</b> The aim of this study was to confirm the influence of TNFSF4 polymorphisms on systemic sclerosis (SSc) susceptibility and phenotypic features.</p> <p><b>Methods</b> A total of 8 European populations of Caucasian ancestry were included, comprising 3014 patients with SSc and 3125 healthy controls. Four genetic variants of TNFSF4 gene promoter (rs1234314, rs844644, rs844648 and rs12039904) were selected as genetic markers.</p> <p><b>Results</b> A pooled analysis revealed the association of rs1234314 and rs12039904 polymorphisms with SSc (OR 1.15, 95% CI 1.02 to 1.31; OR 1.18, 95% CI 1.08 to 1.29, respectively). Significant association of the four tested variants with patients with limited cutaneous SSc (lcSSc) was revealed (rs1234314 OR 1.22, 95% CI 1.07 to 1.38; rs844644 OR 0.91, 95% CI 0.83 to 0.99; rs844648 OR 1.10, 95% CI 1.01 to 1.20 and rs12039904 OR 1.20, 95% CI 1.09 to 1.33). Association of rs1234314, rs844648 and rs12039904 minor alleles with patients positive for anti-centromere antibodies (ACA) remained significant (OR 1.23, 95% CI 1.10 to 1.37; OR 1.12, 95% CI 1.01 to 1.25; OR 1.22, 95% CI 1.07 to 1.38, respectively). Haplotype analysis confirmed a protective haplotype associated with SSc, lcSSc and ACA positive subgroups (OR 0.88, 95% CI 0.82 to 0.96; OR 0.88, 95% CI 0.80 to 0.96; OR 0.86, 95% CI 0.77 to 0.97, respectively) and revealed a new risk haplotype associated with the same groups of patients (OR 1.14, 95% CI 1.03 to 1.26; OR 1.20, 95% CI 1.08 to 1.35; OR 1.23, 95% CI 1.07 to 1.42, respectively).</p> <p><b>Conclusions</b> The data confirm the influence of TNFSF4 polymorphisms in SSc genetic susceptibility, especially in subsets of patients positive for lcSSc and ACA.</p&gt

The course of mental health after miscarriage and induced abortion: a longitudinal, five-year follow-up study

BACKGROUND: Miscarriage and induced abortion are life events that can potentially cause mental distress. The objective of this study was to determine whether there are differences in the patterns of normalization of mental health scores after these two pregnancy termination events. METHODS: Forty women who experienced miscarriages and 80 women who underwent abortions at the main hospital of Buskerud County in Norway were interviewed. All subjects completed the following questionnaires 10 days (T1), six months (T2), two years (T3) and five years (T4) after the pregnancy termination: Impact of Event Scale (IES), Quality of Life, Hospital Anxiety and Depression Scale (HADS), and another addressing their feelings about the pregnancy termination. Differential changes in mean scores were determined by analysis of covariance (ANCOVA) and inter-group differences were assessed by ordinary least squares methods. RESULTS: Women who had experienced a miscarriage had more mental distress at 10 days and six months after the pregnancy termination than women who had undergone an abortion. However, women who had had a miscarriage exhibited significantly quicker improvement on IES scores for avoidance, grief, loss, guilt and anger throughout the observation period. Women who experienced induced abortion had significantly greater IES scores for avoidance and for the feelings of guilt, shame and relief than the miscarriage group at two and five years after the pregnancy termination (IES avoidance means: 3.2 vs 9.3 at T3, respectively, p < 0.001; 1.5 vs 8.3 at T4, respectively, p < 0.001). Compared with the general population, women who had undergone induced abortion had significantly higher HADS anxiety scores at all four interviews (p < 0.01 to p < 0.001), while women who had had a miscarriage had significantly higher anxiety scores only at T1 (p < 0.01). CONCLUSION: The course of psychological responses to miscarriage and abortion differed during the five-year period after the event. Women who had undergone an abortion exhibited higher scores during the follow-up period for some outcomes. The difference in the courses of responses may partly result from the different characteristics of the two pregnancy termination events

Taxes, Trading or Both?: An Experimental Investigation of Abatement Investment under Alternative Emissions Regulation

Emissions taxes and emissions permit trading schemes are designed to reduce greenhouse gas (GHG) emissions by providing incentives for large emitters to invest in less emissions-intensive production technologies. Whereas taxes place a fixed price on emissions, tradable permit schemes include a secondary permit market, from which allowance prices emerge after the regulation enters into force. Under a newly imposed regulation, the delay in price information contributes to uncertainty about the future cost of compliance that liable emitters will face, thereby challenging liable entities’ ability to make optimal abatement investment decisions. Using laboratory experiments, this thesis examines the effects of a policy regime that is similar to the one implemented in Australia in 2012. The regime includes a staged transition over time from a regulation-free environment, to an emissions tax and then to emissions trading. The thesis examines the effects of such a staged transition on investment decisions, the level of emissions, permit prices and trading behavior, comparing it to standard policy regimes of only an emissions tax and only emissions permit trading. The findings suggest that a regime based on a staged transition from a tax to permit trading results in lower compliance costs and higher overall allocative efficiency compared to a regime based solely on emissions trading in a market of heterogeneous producing firms