Cross-border Loss Utilization Concerning the Tax Treatment of a Taxpayer’s Own Losses Attributable to a Permanent Establishment in Relation to the Territoriality Principle –From an International and EU law Perspective

The European Commission has acknowledged the lack of cross-border utilization of losses. Companies operating internationally want to have a possibility to offset losses against taxable profits at the same time or as soon as possible after the losses incurred. If no such possibility is at hand, a cash-flow disadvantage arises and also, it leads to segmentation of the internal market. The asymmetries occur while Member States enjoy sovereignty and a broad competence to levy taxes and determine the geographical extent of their tax jurisdiction. Member States are competent to apply a territorial taxation system and thereby limit the utilization of companies’ losses in cross-border situations. However, the meaning of territorial taxation differs depending on if it is seen from an international law or international tax law perspective. The European Court of Justice recognises a territorial taxation system from an international law perspective. This includes a right for the Member States to tax residents on their worldwide income and non-residents on their territorial income. Member States limit cross-border utilization of losses in order to preserve their tax bases. A territorial tax system can be achieved in two different ways. The first is by a definition of the tax base for income tax purposes, i.e. by limiting the tax base to locally sourced income and capital. The second is by exempting foreign-sourced income through unilateral, bilateral or multilateral conventions. The issue arises when Member States apply a double taxation convention with the exemption method. In that case, there is no possibility to utilize the losses in either the host State or the home State. However, the European Court of Justice may in certain situations require Member States to make it possible to utilize cross-border losses, whereas in other situations the European Court of Justice has recognised Member States sovereignty by stating that Member States do not need to utilize cross-border losses. In the latter situation, the European Court of Justice recognises Member States sovereignty and it may express an underlying principle, in terms of territoriality. The examination implies that the territoriality principle is more a consequence of Member States sovereignty than a self-supporting principle. Furthermore, the concept of territoriality falls into the background of other conceded concepts, such as the balanced allocation of taxing powers and symmetry. Yet, the concept of territoriality is still evolving within the European Union and will certainly be affected by the growing work on international level. When evolving the concept of territoriality, the European Union has to find a balance between the concept of an internal market and the Member States’ sovereignty. At the moment, the European Court of Justice recognises the Member States’ sovereignty even if it contradicts the concept of an internal market. Thus, cross-border losses attributable to permanent establishments are stranded when the Member States apply the exemption method in their double taxation conventions. In order for the territoriality principle to be a self-supporting principle it needs to get a clear definition and a consistent applicability

Genome-wide association studies identify 137 genetic loci for DNA methylation biomarkers of aging

Background Biological aging estimators derived from DNA methylation data are heritable and correlate with morbidity and mortality. Consequently, identification of genetic and environmental contributors to the variation in these measures in populations has become a major goal in the field. Results Leveraging DNA methylation and SNP data from more than 40,000 individuals, we identify 137 genome-wide significant loci, of which 113 are novel, from genome-wide association study (GWAS) meta-analyses of four epigenetic clocks and epigenetic surrogate markers for granulocyte proportions and plasminogen activator inhibitor 1 levels, respectively. We find evidence for shared genetic loci associated with the Horvath clock and expression of transcripts encoding genes linked to lipid metabolism and immune function. Notably, these loci are independent of those reported to regulate DNA methylation levels at constituent clock CpGs. A polygenic score for GrimAge acceleration showed strong associations with adiposity-related traits, educational attainment, parental longevity, and C-reactive protein levels. Conclusion This study illuminates the genetic architecture underlying epigenetic aging and its shared genetic contributions with lifestyle factors and longevity.Peer reviewe

Association of respiratory symptoms and lung function with occupation in the multinational Burden of Obstructive Lung Disease (BOLD) study

Background Chronic obstructive pulmonary disease has been associated with exposures in the workplace. We aimed to assess the association of respiratory symptoms and lung function with occupation in the Burden of Obstructive Lung Disease study. Methods We analysed cross-sectional data from 28 823 adults (≥40 years) in 34 countries. We considered 11 occupations and grouped them by likelihood of exposure to organic dusts, inorganic dusts and fumes. The association of chronic cough, chronic phlegm, wheeze, dyspnoea, forced vital capacity (FVC) and forced expiratory volume in 1 s (FEV1)/FVC with occupation was assessed, per study site, using multivariable regression. These estimates were then meta-analysed. Sensitivity analyses explored differences between sexes and gross national income. Results Overall, working in settings with potentially high exposure to dusts or fumes was associated with respiratory symptoms but not lung function differences. The most common occupation was farming. Compared to people not working in any of the 11 considered occupations, those who were farmers for ≥20 years were more likely to have chronic cough (OR 1.52, 95% CI 1.19–1.94), wheeze (OR 1.37, 95% CI 1.16–1.63) and dyspnoea (OR 1.83, 95% CI 1.53–2.20), but not lower FVC (β=0.02 L, 95% CI −0.02–0.06 L) or lower FEV1/FVC (β=0.04%, 95% CI −0.49–0.58%). Some findings differed by sex and gross national income. Conclusion At a population level, the occupational exposures considered in this study do not appear to be major determinants of differences in lung function, although they are associated with more respiratory symptoms. Because not all work settings were included in this study, respiratory surveillance should still be encouraged among high-risk dusty and fume job workers, especially in low- and middle-income countries.publishedVersio

Common variants in Alzheimer’s disease and risk stratification by polygenic risk scores

Funder: Funder: Fundación bancaria ‘La Caixa’ Number: LCF/PR/PR16/51110003 Funder: Grifols SA Number: LCF/PR/PR16/51110003 Funder: European Union/EFPIA Innovative Medicines Initiative Joint Number: 115975 Funder: JPco-fuND FP-829-029 Number: 733051061Genetic discoveries of Alzheimer's disease are the drivers of our understanding, and together with polygenetic risk stratification can contribute towards planning of feasible and efficient preventive and curative clinical trials. We first perform a large genetic association study by merging all available case-control datasets and by-proxy study results (discovery n = 409,435 and validation size n = 58,190). Here, we add six variants associated with Alzheimer's disease risk (near APP, CHRNE, PRKD3/NDUFAF7, PLCG2 and two exonic variants in the SHARPIN gene). Assessment of the polygenic risk score and stratifying by APOE reveal a 4 to 5.5 years difference in median age at onset of Alzheimer's disease patients in APOE ɛ4 carriers. Because of this study, the underlying mechanisms of APP can be studied to refine the amyloid cascade and the polygenic risk score provides a tool to select individuals at high risk of Alzheimer's disease

Author Correction:Study of 300,486 individuals identifies 148 independent genetic loci influencing general cognitive function

Christina M. Lill, who contributed to analysis of data, was inadvertently omitted from the author list in the originally published version of this article. This has now been corrected in both the PDF and HTML versions of the article

Cohort Profile: Burden of Obstructive Lung Disease (BOLD) study

The Burden of Obstructive Lung Disease (BOLD) study was established to assess the prevalence of chronic airflow obstruction, a key characteristic of chronic obstructive pulmonary disease, and its risk factors in adults (≥40 years) from general populations across the world. The baseline study was conducted between 2003 and 2016, in 41 sites across Africa, Asia, Europe, North America, the Caribbean and Oceania, and collected high-quality pre- and post-bronchodilator spirometry from 28 828 participants. The follow-up study was conducted between 2019 and 2021, in 18 sites across Africa, Asia, Europe and the Caribbean. At baseline, there were in these sites 12 502 participants with high-quality spirometry. A total of 6452 were followed up, with 5936 completing the study core questionnaire. Of these, 4044 also provided high-quality pre- and post-bronchodilator spirometry. On both occasions, the core questionnaire covered information on respiratory symptoms, doctor diagnoses, health care use, medication use and ealth status, as well as potential risk factors. Information on occupation, environmental exposures and diet was also collected

Factors affecting health professionals’ attitudes toward patients with hepatitis C

Bakgrund: Hepatit C är en virusinfektion som smittar via blodkontakt. I Sverige finns idag ca 50 000 kroniska bärare av viruset. Den vanligaste smittvägen i västvärlden är via delning av injektionsutrustning. Ny, effektiv behandling finns att tillgå som gör att infektionen läker ut i 90 procent av fallen. Tidigare forskning visar att patienter med hepatit C känner sig diskriminerade inom vården och upplever att vårdpersonalen särbehandlar dem. Syfte: Syftet med studien var att undersöka vilka faktorer som påverkar sjukvårdspersonalens attityder gentemot patienter med hepatit C. Metod: En litteraturstudie inkluderande nio vetenskapliga artiklar, varav åtta kvantitativa och en kvalitativ, genomfördes. Analysen genererade fem kategorier. Resultat: Vårdpersonalen har generellt sett positiva attityder till att vårda patienter med hepatit C. Samtidigt har de generellt negativa attityder mot de patienter som ådragit sig hepatit C via att injicera narkotika. Viljan att vårda patienter med hepatit C är kopplat till personalens rädsla att själv smittas av sjukdomen. Kunskap om hepatit C har en positiv korrelation till att vårda patienter med hepatit C och högre utbildning eller specifik utbildning inom hepatit C har ett samband med hög kunskap om ämnet. Slutsats: Utbildning kring hepatit C och narkotikabruk samt ett professionellt förhållningssätt behövs för att minska särbehandlingen av dessa patientkategorier

Study of 300,486 individuals identifies 148 independent genetic loci influencing general cognitive function.

General cognitive function is a prominent and relatively stable human trait that is associated with many important life outcomes. We combine cognitive and genetic data from the CHARGE and COGENT consortia, and UK Biobank (total N = 300,486; age 16-102) and find 148 genome-wide significant independent loci (P < 5 × 10-8) associated with general cognitive function. Within the novel genetic loci are variants associated with neurodegenerative and neurodevelopmental disorders, physical and psychiatric illnesses, and brain structure. Gene-based analyses find 709 genes associated with general cognitive function. Expression levels across the cortex are associated with general cognitive function. Using polygenic scores, up to 4.3% of variance in general cognitive function is predicted in independent samples. We detect significant genetic overlap between general cognitive function, reaction time, and many health variables including eyesight, hypertension, and longevity. In conclusion we identify novel genetic loci and pathways contributing to the heritability of general cognitive function

Genome-wide association studies identify 137 genetic loci for DNA methylation biomarkers of aging.

BackgroundBiological aging estimators derived from DNA methylation data are heritable and correlate with morbidity and mortality. Consequently, identification of genetic and environmental contributors to the variation in these measures in populations has become a major goal in the field.ResultsLeveraging DNA methylation and SNP data from more than 40,000 individuals, we identify 137 genome-wide significant loci, of which 113 are novel, from genome-wide association study (GWAS) meta-analyses of four epigenetic clocks and epigenetic surrogate markers for granulocyte proportions and plasminogen activator inhibitor 1 levels, respectively. We find evidence for shared genetic loci associated with the Horvath clock and expression of transcripts encoding genes linked to lipid metabolism and immune function. Notably, these loci are independent of those reported to regulate DNA methylation levels at constituent clock CpGs. A polygenic score for GrimAge acceleration showed strong associations with adiposity-related traits, educational attainment, parental longevity, and C-reactive protein levels.ConclusionThis study illuminates the genetic architecture underlying epigenetic aging and its shared genetic contributions with lifestyle factors and longevity