David Bennett

Apple, Ireland, EU, Juncker, and Tax

From Marginal Seat 2 September 2016

Ireland has just confirmed that it will fight the EU tax bill imposed on Apple in Ireland.

The tax bill was imposed by Margarethe Vestager, the European Commissioner for Competition.

According to Reuter’s, Vestager said that

since being alerted to Apple’s methods and other cases by a U.S. Senate probe in 2013, the Commission has been looking through about 1,000 such instances in the EU

This row has been brewing for years.

In 2014, the Consortium of Investigative Journalists operating out of Washington DC disclosed leaked documents they said showed Luxembourg had become a centre of corporate tax avoidance for over three hundred major international companies.

And Jean-Claude Juncker, the current President of the European Commission, was prime minister of Luxembourg from 1995 to 2013, and is accused of being involved in the agreements.

As the Guardian revealed in 2014

The leaked papers show Luxembourg acting as a go-between, both enabling and masking tax avoidance, which always takes place beyond its borders. The documents are mainly Advance Tax Agreements – known as comfort letters. The leaked papers include 548 of these private tax rulings. These ATAs are typically schemes put to the Luxembourg tax authorities which, if implemented, reduce tax bills substantially. If the Luxembourg authorities approve the scheme they provide a comfort letter which is a binding agreement.

If the EU Commission wins on appeal, then a whole raft of tax matters will unravel and Luxembourg’s head will be on a plate.

It’s not just tax, though. As always, sweetheart deals are done for a reason. And if the deals are upset, there can be consequences.

In 2015, Vestager ordered Cyprus Airways to pay back millions in state aid it had received in a restructuring package.

Vestager said that under the EU rules, there must be ten years or more between state bailouts that companies receive, and Cyprus Airways had already been bailed out in 2007.

So another bailout was a disguised way for the state to subsidise the airline, which meant unfair competition with other airlines.

As a result, Cyprus Airways went out of business, jobs were lost and those ‘other’ airlines picked up the business.

So the result was that the office of the Commission for Competition in the EU reduced competition by driving one of the airlines out of business.

That may be necessary fallout of a decision to defeat tax avoidance in the EU.

But who know what the eventual consequences will be? 

And who knows what the politics within the EU will decide in the background to the forthcoming appeal, given the embarrassment to Juncker?

This could get messy.

I Heard A Woodpecker In Cambridge

I posted this on my wp dot com photography blog on 23rd April when this happened.

It’s sunny today. We live just a few hundred yards from the middle of town and yet there’s a Green – a large area of grass and trees in front of the houses in the Square – which is lovely. 

Given Corona lockdown, I went out to stand in the Green and look at the trees. It’s funny how isolation makes one see things anew, so I spent a bit of time looking at the trees and the houses, noticing things. Then I heard a repeated drumming sound. A woodpecker. In the middle of town. So I went walking towards the sound, and when I got near the trees where I thought it was, I saw a woman with a bicycle and she was looking into one particular tree.

I asked (from a social distance of several metres) whether she could see the bird. Yes, she said, and pointed out where it was. Then it flew to another tree and we agreed it was a spotted woodpecker. It was quite high up but we thought it was a lesser spotted woodpecker.

I said that I wondered whether it was in town because it was quiet or that we heard it because it was quiet. She said she thought the same. I said I had heard it from way over there (pointing from where I had come) and she said she had heard it from way over there, in the footpath that leads into town. We were smiling like crazy, happy at this truly lovely thing that was drumming in the tree.

I have the Golf Sight app on my phone. I use it to calculate distances. It knows where you are standing and you point it wherever and then tap. It said I was 162 yards from where I was standing when I first heard the woodpecker. 

When I walked back I heard the woodpecker over to my right. I could have gone looking, but that was so good that it was enough.

Pulmonary Surfactants

I came across pulmonary surfactants because I keep thinking about surfactants and Coronavirus. The Coronavirus is made up of a strand of RNA surrounded by a lipid membrane with little protein spikes sticking out of it like a crown (or corona).

Soap and washing-up liquid break up the lipid membrane that surround the Coronavirus. That’s how they destroy it. So I was thinking about people with COVID-19 respiratory inflammation and wondered whether it might be possible to wash out their lungs.

I googled and found that pulmonary surfactants are part and parcel of lung design. Here’s a quote from an article about surfactant in asthma:

Pulmonary surfactant with an optimal function in the airways is important because it stabilizes the conducting airways, prevents fluid accumulation within the airway lumen, improves bronchial clearance, acts as a barrier against the uptake of inhaled agents and has important immunomodulatory properties. In asthma, it has been demonstrated that there is a surfactant dysfunction mainly due to inhibition by proteins that enter the airways during the inflammatory process

The Coronavirus is small

Human hairs vary in thickness. Chinese, Japanese, Thai, and Korean hair is about 90,000 nm in diameter. Indian and Spanish hair is about 80,000 nm in diameter. European hair is about 70,000 nm in diameter. 

There are one billion (one thousand million) nanometres (nm) in one metre.

The Coronavirus family varies in diameter from 80 – 160nm. This Coronavirus (severe acute respiratory syndrome coronavirus 2, or SARS-CoV-2 or the Covid-19 virus) is 125nm in diameter

So approximately 560 Covid-19 viruses laid side by side would be about the same width as a typical European hair.

How Far Does The Virus Travel

So if someone sneezes, does the virus fall to the ground in a gentle arc, bound up in sneeze droplets? Or does it get wafted away on the wind? The consensus seems to be that staying two metres from another person isolates you from them. Does that apply if they sneeze or cough in your direction?

Does it suggest infected people have a miasma of viruses in the air around them that tapers off to nothing within two metres? There have been several studies, criticised for not being real-world studies, showing how far the virus can travel. In a worst-case scenario, two metres seems nowhere near far enough.

A few weeks ago on TV I saw a Sky News report with the reporter driving around the medieval city centre of Bergamo in Lombardy in Italy. Bergamo was the epicentre of the Italian outbreak. The streets were narrow and the buildings were tall. I could imagine the air recirculating in the streets, full of virus.

Viral Load

Which leads to another thought, that the severity of the effect is dependent on the viral load. The more viruses one takes in, the more the chance they will overwhelm the body before it has chance to develop antibodies.

It also explains or suggests why nurses and doctors who are young or otherwise healthy are dying from COVID-19, namely that they are coming into contact with large quantities of the virus.

There’s a YouTube video I saw of people at a New York hospital explaining how they have rigged up negative pressure rooms in the hospital with negative pressure cages around the patients’ beds. They put large-bore tubing leading from the rooms, out of the windows and up to extractor fans with filters on the roof.

That directs virus-laden air out of the rooms and limit the risk of exposure to nursing staff. Additionally, the cages around the patients pull the virus-laden air that patients expel, away from the patients and out of the rooms. It seems sensible and logical to think that viruses rotating around a patient’s mouth and nose would be sucked in again unless swept away.

Invisible Smiles

I just read an article entitled Invisible Smiles, reproduced in the 4 April issue of the Week. It reports on a study carried out at Kyoto University. The article says the report was published in the journal Royal Society Open Science.

The study compared the ability of young people in their 20s and people in the 70s to recognise facial expressions. In particular, the participants were shown a smile, an annoyed face, and a neutral face. The study showed that older people were good at recognising annoyed expressions but not smiles.

Younger people were better at recognising smiles. Older people found it harder to classify an expression as a smile or a neutral face.

The conclusion was that older people need to be more protective, so they hone their skill in recognising threats.

Well yes, possibly.

The faces the subjects were shown were real faces. The following quote is from the Invisible Smiles review at Royal Society Open Science. The review is under the title Older adults detect happy facial expressions less rapidly. And it was published 25 March 2020 by Akie Saito , Wataru Sato and Sakiko Yoshikawa

“Photographs of real faces displaying normal expressions and anti-expressions of anger and happiness served as target stimuli; neutral facial expressions served as distractor stimuli.”

Here’s another interpretation of the results: Perhaps the older people were wiser and more adept at seeing behind the smile.

Compare This To Estimating The Passage Of Time

It would be different if for example the older group were unable to judge the passage of time. Let’s say the older group were unable to estimate five minutes as accurately as the younger group. Unless one wants to be truly solipsist, we can all agree that the measurement of time is independent of interpretation. We can all verify how much time has passed by looking at a watch. In the absence of a timepiece we are all either good or bad at knowing how much time has passed.

But any study that depends on the interpretation of a facial expression depends on something else. It depends on the universality of agreement as to what the expression signifies. So let’s say an older age group of people see the facial expressions differently. What does it mean? It may mean that they are more able to discriminate facial expressions.