L'attuale disciplina delle CFC alla luce del recepimento della Direttiva ATAD

L’elaborato si presta a trattare sinteticamente e, con un focus sulla normativa italiana, quello che è il tema delle società estere controllate da soggetti residenti, meglio note con il termine controlled foreign company o con l’acronimo CFC. Si è pensato di incentrare l’analisi partendo, attraverso una parte introduttiva, di come i cambiamenti nel percepire la ricchezza cambi da parte degli individui grazie al fenomeno di una sempre più intensa globalizzazione e di come questa influenzi le decisioni che i singoli ordinamenti devono prendere per evitare un depauperamento delle proprie finanze attraverso sempre più facili e complessi fenomeni distrattivi della base imponibile. Tra i diversi rimedi vi è, per l’appunto, quello delle CFC, la cui ricostruzione dal punto di vista storico è demandata al capitolo primo, in cui vengono esposti quelli che possiamo individuare come elementi caratterizzanti la disciplina, che accomunano i diversi ordinamenti. Nel secondo capitolo si passa in rassegna quello che è l’excursus storico della normativa italiana in tema di imprese estere controllate da soggetti residenti in vigore fino a dicembre 2018, per poi sottolineare nel capitolo successivo quali siano i diversi presupposti della disciplina, andando sul finale ad analizzare le fattispecie di esclusione e gli aspetti procedimentali. La trattazione si chiude con un quarto capitolo in cui il tema è incentrato sull’analisi della “Anti Tax Avoidance Directive” e di come quest’ultima abbia cambiato la disciplina italiana attraverso l’entrata in vigore del D.Lgs. n. 142/2018 il quale recepisce le modifiche suggerite in ambito europeo

Balance sheet method assessment for nitrogen fertilization in winter wheat: II. alternative strategies using the CropSyst simulation model

It is important, both for farmer profit and for the environment, to correctly dose fertilizer nitrogen (N) for winter wheat growth. Balance-sheet methods are often used to calculate the recommended dose of N fertilizer. Other methods are based on the dynamic simulation of cropping systems. Aim of the work was to evaluate the balance-sheet method set up by the Region Emilia-Romagna (DPI), by comparing it with the cropping systems simulation model CropSyst (CS), and with an approach based on fixed supplies of N (T). A 3-year trial was structured as a series of N fertility regimes at 3 sites (Papiano di Marsciano, Ravenna, San Pancrazio). The N-regimes were generated at each site-year as separate trials in which 3 N rates were applied: N1 (DPI), N2 (DPI+50 kg ha-1 N at spike initiation), N3 (DPI + 50 kg ha-1 N at early booting). Above ground biomass and soil data (NO3-N and water) were sampled and used to calibrate CS. Doses of fertilizer N were calculated by both DPI and CS for winter wheat included in three typical rotations for Central and Northern Italy. Both these methods and method T were simulated at each site over 50 years, by using daily generated weather data. The long-term simulation allowed evaluating such alternative fertilization strategies. DPI and CS estimated comparable crop yields and N leached amounts, and both resulted better than T. Minor risk of leaching emerged for all N doses. The N2 and N3 rates allowed slightly higher crop yields than N1

Balance sheet method assessment for nitrogen fertilization in bread wheat: I. yield and quality

In the European Union the production of high quality wheat is mainly located in the Mediterranean regions where the climatic conditions positively affect protein concentration in the grain. High quality wheat calls for proper management of nitrogen fertilization, thus there is a need to verify whether the limitations imposed by local governments on maximum rate of nitrogen fertilization admitted may affect bread making quality. Trials were conducted in fourteen environments (E) to study the effects of different nitrogen fertilizations on eight cultivars (C), belonging to four quality grades (Q). Nitrogen (N) was applied to crops according to three rates/modalities: N1 corresponding to the maximum rate admitted calculated according to a balance sheet method and distributed at the stage of spike initiation; N2 with 50 kg ha-1 of nitrogen more than N1, also distributed at the stage of spike initiation; N3 with 50 kg ha-1 of nitrogen more than N1 but distributed at the stage of flag leaf appearance. The effects of environment, nitrogen and cultivar were significant for grain yield, test weight, 1000 kernel weight, heading time, plant height and for quality traits (protein content and alveograph indices). The existence of variability among cultivars and quality grades in the response to rate and timing of nitrogen fertilization was demonstrated by the significance of NxC and NxQ interactions. Dry matter and nitrogen contents of plant at anthesis and at harvest were significantly affected by the main sources of variation. High quality cultivars yielded more grain of better quality with higher N rates (N2 and N3) as compared to the maximum rate of nitrogen admitted by the local government (N1). These results demonstrated that the adopted balance sheet method for the calculation of N requirements of wheat crop adversely affects the full potential expression of the cultivars belonging to superior bread making quality grades

Fusarium DNA traceability along the bread production chain

Wheat grain contamination with toxigenic Fusarium spp. is of great economic concern to cereal producers and to the grain processing industry and is of great relevance for the quality and safety of the final products. In particular, the bread production chain can potentially be a vehicle for mycotoxin ingestion above the tolerable total daily intake. A quantitative polymerase chain reaction-based analytical approach has been developed as a possible tool to estimate and control the risk of mycotoxins, particularly deoxynivalenol (DON). This DNA-based analytical method has been applied to detect and quantify contamination levels of Fusarium graminearum and Fusarium culmorum in naturally infected wheat grain samples. The persistence of Fusarium contamination was also detected along the bread production chain in wholemeal, flour and bread. A significant correlation was found between Fusarium DNA and DON concentration in all samples

Un aiuto alla gestione della fusariosi della spiga

Information is included on a monitoring project conducted in Emilia Romagna, Italy, during 2002-04 to develop a strategy for integrated control of fungi responsible for accumulation of toxins in autumn-winter cereals. Samples taken during the trials were analysed for the presence of deoxynivalenol (DON) [vomitoxin], zearalenone (ZEN) and ochratoxin (OTA). A map is provided of various degrees of risk of cereal (soft and durum wheat, and barley) contamination with DON toxin. A decision support system designated FHB-DSS (Fusarium Head Blight u Decision Support System) was developed to determine the risk degree caused by the presence of mycotoxins. Mathematical models are also included to calculate the degree of risk from mycotoxins based on meteorological data. Application of the decision support system based on risk indexes in development of strategies of Fusarium control is outlined

The Vamos project: regional scale validation of two models predicting soil N availability for a more sustainable fertilization of wheat and peach crops

Models are potentially useful tools for both growers and policy makers, to guide the nitrogen fertilization in order to reconcile environmental and productive issues. This research, funded by the regional government of Emilia-Romagna and Crpv in view of testing the regional nitrogen application policies for a more sustainable crop production, aims at the extensive testing of water balance and nitrogen transport models in actual cropping conditions in a rather large area of the eastern Po river plain

Tocilizumab for patients with COVID-19 pneumonia. The single-arm TOCIVID-19 prospective trial

BackgroundTocilizumab blocks pro-inflammatory activity of interleukin-6 (IL-6), involved in pathogenesis of pneumonia the most frequent cause of death in COVID-19 patients.MethodsA multicenter, single-arm, hypothesis-driven trial was planned, according to a phase 2 design, to study the effect of tocilizumab on lethality rates at 14 and 30 days (co-primary endpoints, a priori expected rates being 20 and 35%, respectively). A further prospective cohort of patients, consecutively enrolled after the first cohort was accomplished, was used as a secondary validation dataset. The two cohorts were evaluated jointly in an exploratory multivariable logistic regression model to assess prognostic variables on survival.ResultsIn the primary intention-to-treat (ITT) phase 2 population, 180/301 (59.8%) subjects received tocilizumab, and 67 deaths were observed overall. Lethality rates were equal to 18.4% (97.5% CI: 13.6-24.0, P=0.52) and 22.4% (97.5% CI: 17.2-28.3, P<0.001) at 14 and 30 days, respectively. Lethality rates were lower in the validation dataset, that included 920 patients. No signal of specific drug toxicity was reported. In the exploratory multivariable logistic regression analysis, older age and lower PaO2/FiO2 ratio negatively affected survival, while the concurrent use of steroids was associated with greater survival. A statistically significant interaction was found between tocilizumab and respiratory support, suggesting that tocilizumab might be more effective in patients not requiring mechanical respiratory support at baseline.ConclusionsTocilizumab reduced lethality rate at 30 days compared with null hypothesis, without significant toxicity. Possibly, this effect could be limited to patients not requiring mechanical respiratory support at baseline.Registration EudraCT (2020-001110-38); clinicaltrials.gov (NCT04317092)