ARE THE NEW POLISH TAX RULES REGARDING PARTNERSHIPS LIMITED BY SHARES IN BREACH OF EU LAW? ANALYSIS OF AMENDMENTS TO THE POLISH INCOME TAX ACT 2014 IN THE LIGHT OF ECJ CASE LAW

With effect from 1 January 2014, the Polish Parliament introduced amendments to the Polish Corporate and Personal Income Tax Acts, which primarily affect the taxation of a partnership limited by shares (SKA) by including it into the category of corporate income tax subjects. Under the new regulations the general partners of an SKA should be treated in the same way as partners of any other Polish partnership and thus their income should be effectively taxed only once. In order to ensure the single-level taxation of general partner’s income a tax credit mechanism has been introduced. Though, the new Polish provisions permit the application of the tax credit mechanism only in relation to national cases. In the authors’ view this may constitute a restriction on freedom of establishment. This article analyses whether the new tax credit method is compatible with EU Law

Qualifikationskonflikte in Dreiecksachverhalten am Beispiel von grenzüberschreitender Mitunternehmerschaft

Der allgemeine Einflussfaktor für die Entstehung der Qualifikationskonflikte bei Personalgesellschaften ist die unterschiedliche Einordnung von ausländischen Personalgesellschaften durch einen Staat (auf Grundlage des Rechtstypenvergleichs). Wenn an einem Steuerfall drei Staaten beteiligt sind, deren nationale Zurechnungsvorschriften nicht übereinstimmen, kann es zu einer Mehrfachbelastung kommen. In manchen Fällen wird keine Möglichkeit zur Vermeidung dieser Mehrfachbesteuerung gesehen, wenngleich zwischen allen drei beteiligten Staaten ein Abkommen besteht.In these times of the integration of international markets, capital flow is a permanently increasing process. Cross-border investments can be implemented via various entities, for example via partnerships structures and take place in more than two countries, so called triangular cases. Since there is no uniform tax treatment of partnerships among domestic tax regimes, conflicts of qualification of these entities can easily occur. As a consequence of such conflicts are often double taxation or double no taxation

Scoping review of health promotion and disease prevention interventions addressed to elderly people

PRISMA Checklist for systematic reviews. (DOCX 27 kb

第780回千葉医学会例会・第5回神経内科例会・第263回脳研談話会 1.

List of systematic reviews and/or meta-analyses included in the scoping review with the classification results. (DOCX 60 kb

Genome-wide association study identifies a variant in HDAC9 associated with large vessel ischemic stroke

Genetic factors have been implicated in stroke risk but few replicated associations have been reported. We conducted a genome-wide association study (GWAS) in ischemic stroke and its subtypes in 3,548 cases and 5,972 controls, all of European ancestry. Replication of potential signals was performed in 5,859 cases and 6,281 controls. We replicated reported associations between variants close to PITX2 and ZFHX3 with cardioembolic stroke, and a 9p21 locus with large vessel stroke. We identified a novel association for a SNP within the histone deacetylase 9(HDAC9) gene on chromosome 7p21.1 which was associated with large vessel stroke including additional replication in a further 735 cases and 28583 controls (rs11984041, combined P = 1.87×10−11, OR=1.42 (95% CI) 1.28-1.57). All four loci exhibit evidence for heterogeneity of effect across the stroke subtypes, with some, and possibly all, affecting risk for only one subtype. This suggests differing genetic architectures for different stroke subtypes

ARE THE NEW POLISH TAX RULES REGARDING PARTNERSHIPS LIMITED BY SHARES IN BREACH OF EU LAW? ANALYSIS OF AMENDMENTS TO THE POLISH INCOME TAX ACT 2014 IN THE LIGHT OF ECJ CASE LAW

With effect from 1 January 2014, the Polish Parliament introduced amendments to the Polish Corporate and Personal Income Tax Acts, which primarily affect the taxation of a partnership limited by shares (SKA) by including it into the category of corporate income tax subjects. Under the new regulations the general partners of an SKA should be treated in the same way as partners of any other Polish partnership and thus their income should be effectively taxed only once. In order to ensure the single-level taxation of general partner’s income a tax credit mechanism has been introduced. Though, the new Polish provisions permit the application of the tax credit mechanism only in relation to national cases. In the authors’ view this may constitute a restriction on freedom of establishment. This article analyses whether the new tax credit method is compatible with EU Law