…al fiscalitatii directe, desigur. Se incinge povestea.
What constitutes abuse (could you give some examples)?
According to the doctrine of abuse of rights developed by the ECJ in its (mainly non-tax) case law, abuse occurs only where the purpose of law is defeated despite formal observance of the conditions laid down in the law, and there is an intention to obtain an advantage by artificially creating the conditions for obtaining it.
On direct taxation, in addition, the ECJ has held that the need to prevent tax avoidance or abuse can constitute an overriding reason in the public interest capable of justifying a restriction on fundamental freedoms. The notion of tax avoidance is however limited to wholly artificial arrangements aimed at circumventing the application of the legislation of the MS concerned.
Tax avoidance or abuse needs to be distinguished from tax fraud which involves deliberate unlawful behaviour which is generally punishable by law (e.g. submission of deliberately false statements or fake documents).
What are anti-abuse rules?
The notion of “anti-abuse rules” covers a broad range of rules, measures and practices through which Member States seek to protect their (corporate and individual) tax bases. For example, MS may apply a general concept of abuse based on legislation or developed in case law and/or more specific anti-abuse provisions, such as Controlled Foreign Corporation (CFC) and thin capitalisation rules which aim to protect the tax base from particular types of erosion (see below). Other types of specific anti-abuse provisions include, for instance, switch-over from exemption to credit method in certain cross-border situations and provisions explicitly targeted at passive investment in other countries.
What are Controlled Foreign Corporation (CFC) and thin capitalisation rules?
These are the most common types of specific anti-avoidance rules with which many MS seek to protect their tax bases against particular types of cross-border tax avoidance schemes. In brief, their scopes and objectives could be summarised as follows.
CFC rules: The main purpose of CFC rules is to prevent resident companies from avoiding domestic tax by diverting income to subsidiaries in low tax countries. The scope of CFC rules is generally defined by reference to criteria regarding control, effective level of taxation, activity and type of income of the CFC. They typically provide that profits of a CFC may be attributed to its domestic shareholders (usually a parent company) and subjected to current (immediate) taxation in the hands of the latter (whereas normally the parent company would be taxed on the profits of its foreign subsidiary only at the time of repatriation).
Thin capitalisation rules: There are many different approaches to the design of thin capitalisation rules but the background to these rules is similar. Debt and equity financing attract different tax consequences. Financing a company by means of equity normally results in a distribution of profits to the shareholder in the form of dividends, but only after taxation of such profits at the level of the subsidiary. Debt financing, in turn, will result in a payment of interest to the creditors (who can also be the shareholders), but such payments generally reduce the taxable profits of the subsidiary. Dividend and interest may also attract different withholding tax consequences. As the source state’s taxing rights on interest are generally more limited than on dividends, debt financing can lead to the erosion of the tax base in the state of the subsidiary. To counter this problem, many MS have introduced specific thin capitalisation provisions dealing with structured debt financing schemes. Typically these limit the deductibility of interest paid on loans taken with (or otherwise arranged by) shareholders to the extent that the subsidiary is considered to be excessively “thinly” capitalised.
Why has the Commission issued this Communication?
As with other coordination initiatives in the direct tax field the obvious catalyst for the need to address issues related to the application of MS’ anti-abuse rules lies with the development of the European tax law. Over the past few years the European Court of Justice (ECJ) has handed down a number of important judgments in this area in which it has clarified the limitations on the lawful use of anti-avoidance rules. The judgments will have a significant impact on the existing rules which have not been formulated with these constraints in mind. There is thus a need for a general review by MS of their anti-avoidance rules.
While it is important to ensure that there are no undue obstacles to the exercise of the rights conferred upon individuals and economic operators by Community law provisions, MS also need to be able to operate effective tax systems and prevent their tax bases from being unduly eroded because of abuse.
It is also vital that MS avoid overreacting to the case law. It would be regrettable if, in order to avoid the charge of discrimination, MS simply extended the application of anti-abuse measures designed to curb cross-border tax avoidance to purely domestic situations where no possible risk of abuse exists. Such unilateral remedies only add unnecessary red tape – and thus, they undermine the competitiveness of the MS’ economies, and are not in the interest of the Internal Market. Moreover, it remains debatable whether such extensions can successfully bring all restrictive measures into line with MS’ EC Treaty obligations
Moreover, and notwithstanding the guidance laid down by the ECJ to date, there remains scope for exploring the practical application of the relevant principles beyond the circumstances of the particular contexts in which they arose. The Commission therefore wishes to invite the MS and other stakeholders to work with it to promote a better understanding of the implications for MS’ tax systems.
Is there (still) scope for application of anti-abuse measures within the EU/EEA?
As the ECJ has confirmed in a number of occasions, the need to prevent tax avoidance or abuse can constitute an overriding reason in the public interest capable of justifying a restriction on fundamental freedoms. But in order to be lawful national anti-avoidance rules must be proportionate and serve the specific purpose of preventing wholly artificial arrangements. It is in particular clear that those rules must not be framed too broadly but be targeted at situations where there is no genuine establishment or more generally where there is a lack of commercial underpinning.
It is clear from the case law of the ECJ that, for instance, CFC and thin capitalisation rules are generally apt to achieve their intended purpose and that they are not per se incompatible with the EC Treaty freedoms. However, such rules must be accurately targeted at situations of abuse and proportionate to the objective of preventing abuse.
Moreover, as Community law does not require MS to avoid discrimination in relation to the establishment of their nationals outside the Community, or the establishment of third-country nationals in a MS the issue of discrimination does not arise, for instance, in the cases of a controlled company or a creditor/shareholder resident in a third country. MS should therefore not be precluded from applying CFC and thin cap rules in relation to third countries.
How does this initiative relate to those on “harmful tax competition”?
MS cannot hinder the exercise of the rights of freedom of movement simply because of lower levels of taxation in other MS. This is the case even in respect of special favourable regimes in the other MS’ tax systems.
Moreover, distortions to the location of business activities due to EC Treaty incompatible state aid and to harmful tax competition do not entitle MS to take unilateral measures intended to counter their effects by limiting freedom of movement; rather they need to be resolved at source through the appropriate judicial or political procedures. The Commission will continue to monitor the application of the EC Treaty state aid rules in the direct tax area and to lend its full support to the work undertaken in the Council by the Code of Conduct Group.
Why does the Commission not just litigate?
The number of infringement proceedings begun by the Commission has increased over the last few years. It is not always necessary for such cases to end up before the Court because often MS respond by removing the unlawful restriction.
But while the Commission has the legal obligation to ensure that MS observe their EC Treaty obligations it also has a political responsibility to seek and promote constructive tax policy solutions to that end. Moreover, through constructive solutions we may avoid situations where, in order to avoid the charge of discrimination, MS resort to extending the application of anti-abuse measures designed to curb cross-border tax avoidance to purely domestic situations where no possible risk of abuse exists. Such unilateral remedies only undermine the competitiveness of the MS’ economies, and are not in the interest of the Internal Market.
What could be achieved in this area by coordination?
Coordination and cooperation between the MS can enable them to attain their tax policy goals and protect their tax bases while observing their EC Treaty obligations and ensuring the elimination of double taxation.
It is in the interest of all MS and other stakeholders, that MS remain capable of operating effective tax systems and that their anti-abuse rules are accurately targeted at situations of abuse and are predictable and proportionate. It is also in the general interest of the Internal Market that the ECJ’s case law does not result in more draconian tax systems due to overreaction on the part of the MS. This could be the case if MS’ unilateral remedies extended existing restrictions on cross-border activities also to purely domestic operations. Coordination is a flexible approach which can take many forms and which could provide adequate solutions to challenges faced by the MS in this area. Therefore the Commission considers it useful to explore the scope for possible specific co-ordinated solutions with a view to:
Why is there a need to distinguish between the application of anti-abuse rules within the EU and in relation to third countries?
As regards the EC law compatibility of national anti-abuse measures, a distinction has to be drawn between their application within the EU/EEA, (where the four fundamental freedoms apply) and their application vis-à-vis third countries (where only the free movement of capital applies). The application of anti-abuse rules targeted at arrangements entered into by corporate groups beyond the geographical limits of the EU/EEA is thus generally less restricted by the EC Treaty. Community law does not require MS to avoid discrimination in relation to the establishment of their nationals outside the Community, or the establishment of third country nationals in a MS. Therefore, MS should not be precluded from applying CFC and thin capitalisation rules, for example, in relation to third countries.
The Commission moreover considers that, in order to protect their tax bases, MS should seek to improve the coordination of the application of their anti-abuse measures in particular in respect of international tax avoidance schemes. Such co-ordination could usefully consist of administrative co-operation, (e.g. exchange of information and sharing of best practices). The Commission would also encourage MS, where appropriate, to enhance administrative co-operation with their non-EU partners.
How does this initiative affect Member States’ revenues?
The Commission supports MS’ efforts to prevent their tax bases from being eroded. The possible coordinated solutions should enable the MS to attain their tax policy goals and protect their tax bases while observing their EC Treaty obligations. The key objectives of this initiative are indeed to strike a proper balance between the public interest of combating abuse and the need to avoid disproportionate restrictions on cross-border activity within the EU as well as to improve the coordination of the application of MS’ anti-abuse rules in relation to international tax avoidance schemes in order to protect their tax bases.
How will taxpayers benefit from this initiative?
Taxpayers will benefit not only from the removal of disproportionate obstacles to their cross-border activities but also from successfully implemented coordinated solutions through improved clarity and predictability of the application of anti-abuse rules. It is equally in the interest of taxpayers if the coordinated solutions can help the MS to avoid extending existing restrictions on cross-border activities to purely domestic operations. Also, more generally, that MS remain capable of operating effective tax systems allows them to meet the requirement of equality – and it is not in the interest of honest taxpayers to finance the erosion of tax bases due to abusive practices and overtly aggressive tax planning schemes entered into by others.
(*)
Asta de stire! Din “Daily Mail“.
Pope Benedict XVI has launched a surprise attack on climate change prophets of doom, warning them that any solutions to global warming must be based on firm evidence and not on dubious ideology.
The leader of more than a billion Roman Catholics suggested that fears over man-made emissions melting the ice caps and causing a wave of unprecedented disasters were nothing more than scare-mongering.
The German-born Pontiff said that while some concerns may be valid it was vital that the international community based its policies on science rather than the dogma of the environmentalist movement.
His remarks will be made in his annual message for World Peace Day on January 1, but they were released as delegates from all over the world convened on the Indonesian holiday island of Bali for UN climate change talks.
The 80-year-old Pope said the world needed to care for the environment but not to the point where the welfare of animals and plants was given a greater priority than that of mankind.
“Humanity today is rightly concerned about the ecological balance of tomorrow,” he said in the message entitled “The Human Family, A Community of Peace”.
“It is important for assessments in this regard to be carried out prudently, in dialogue with experts and people of wisdom, uninhibited by ideological pressure to draw hasty conclusions, and above all with the aim of reaching agreement on a model of sustainable development capable of ensuring the well-being of all while respecting environmental balances.
“If the protection of the environment involves costs, they should be justly distributed, taking due account of the different levels of development of various countries and the need for solidarity with future generations.
“Prudence does not mean failing to accept responsibilities and postponing decisions; it means being committed to making joint decisions after pondering responsibly the road to be taken.”
Efforts to protect the environment should seek “agreement on a model of sustainable development capable of ensuring the well-being of all while respecting environmental balances”, the Pope said.
He added that to further the cause of world peace it was sensible for nations to “choose the path of dialogue rather than the path of unilateral decisions” in how to cooperate responsibly on conserving the planet.
The Pope’s message is traditionally sent to heads of government and international organisations.
His remarks reveal that while the Pope acknowledges that problems may be associated with unbridled development and climate change, he believes the case against global warming to be over-hyped.
A broad consensus is developing among the world’s scientific community over the evils of climate change.
But there is also an intransigent body of scientific opinion which continues to insist that industrial emissions are not to blame for the phenomenon.
Such scientists point out that fluctuations in the earth’s temperature are normal and can often be caused by waves of heat generated by the sun. Other critics of environmentalism have compared the movement to a burgeoning industry in its own right.
In the spring, the Vatican hosted a conference on climate change that was welcomed by environmentalists.
But senior cardinals close to the Vatican have since expressed doubts about a movement which has been likened by critics to be just as dogmatic in its assumptions as any religion.
In October, the Australian Cardinal George Pell, the Archbishop of Sydney, caused an outcry when he noted that the atmospheric temperature of Mars had risen by 0.5 degrees celsius.
“The industrial-military complex up on Mars can’t be blamed for that,” he said in a criticism of Australian scientists who had claimed that carbon emissions would force temperatures on earth to rise by almost five degrees by 2070 unless drastic solutions were enforced.
EUOBSERVER / BRUSSELS – The leaders of the three main European institutions on Wednesday (12 December) signed a charter of fundamental rights that will be annexed to the EU’s new treaty – but the ceremony faced vocal protests by eurosceptic MEPs demanding a referendum on the document.
The rights charter was signed in the Strasbourg seat of the European Parliament by parliament president Hans-Gert Poettering, European Commission chief Jose Manuel Barroso and Portuguese prime minister Jose Socrates, the current head of the Council of the EU representing member states.Calling the signature of the document “one of the most important events of my political career”, Mr Socrates also said the event was certainly “a fundamental date in the history of Europe”.
However, a standing ovation by a majority of parliamentarians clashed with jeers by eurosceptic MEPs brandishing banners in protest and wearing black t-shirts with a white “referendum” sign on them, delaying and interrupting the premier’s speech several times.
The parliamentarians were indicating their opposition to the Lisbon treaty and calling for it to be submitted to popular voting.
An “anti-European” incident
After calling on them to let their “guest” speak, the parliament’s president angrily asked them to leave the hemicycle. The protesters stayed however, and after the Portuguese prime minister’s speech, they booed the commission president as well.
“This is the new EU in action, showing the world a united face as they steam-roll towards their own super-state while totally refusing to allow anyone to see a different point of view”, UKIP leader Nigel Farage, who was one of the initiators of the protest, said.
Mr Farage’s party accused the parliament’s television channel of biased coverage and said it was trying to “avoid showing a serious protest in the debating chamber”.
The incident came as a PR blow to the Group of the European United Left – Nordic Green Left (GUE/NGL), which does not view itself as eurosceptic but which had initiated the protest, purely because it demands referendums on the treaty.
The booing eurosceptic MEPs subsequently joined the protest and hijacked it.
Francis Wuertz, president of the GUE/NGL group, distanced himself from the incident saying: “I would like on my personal behalf, and I hope – after what we have seen – on behalf of my group, to absolutely condemn the anti-European, chauvinistic and unworthy incident that took place this morning”.
“Of course, we are in favour of a referendum on the Treaty and certainly, we have issues with certain points of the Charter of Fundamental Rights, but this occurrence today was about something completely different (…) There is no space in our vision for chauvinism and for unworthiness”, he stated in a press release.
A fundamental date for Europe
The text of the Charter of fundamental rights of the EU lays out six categories of rights for all EU citizens and residents – dignity, freedoms, equality, solidarity, citizens’ rights and justice.
It will be annexed as a separate declaration to the new treaty that EU leaders will sign in Lisbon on Thursday (13 December) and will be legally binding as soon as the treaty itself enters into force.
“No matter how loud people yell to prevent [other] people from speaking, this is a date of fundamental importance for the history of Europe”, Mr Socrates said, addressing the jeering MEPs.
“This is a charter for equality and solidarity, for fighting against any form of discrimination”, he added.
Although the document will only apply to EU institutions and member states only as far as implementing European laws is concerned, and is not aimed at establishing new EU powers, two member states have decided to opt out from the charter.
The UK and Poland are worried that the European Court of Justice could use the document as a basis to impose certain rights in their countries – London fears the charter may give too many rights to trade unions, while Polish politicians are cautious about the charter’s supposed liberalism on moral issues.
Oren Gazal-Ayal, University of Haifa, Faculty of Law
What explains the popularity of law and economics (L&E) in some academic communities and the scarcity of such scholarship in others? Many explanations have been given for the centrality of economic analysis in American legal thought and its marginality in Europe. This article examines what drives scholars to select L&E as a topic for research. It does so by implementing the methodology of many papers in the field – by assuming that regulation and incentives matter. Legal scholars face very different academic incentives in different parts of the world. In some countries, the academic standards for appointment, promotion and tenure encourage legal scholars to concentrate on L&E. In others, they strongly discourage such research. Thus, we should expect wide variation in the participation rate of legal scholars in the L&E discourse across countries. On the other hand, economists are evaluated with similar yardsticks everywhere, and thus their participation rate is likely to vary much less. The hypothesis of this paper is that academic incentives are a major factor in the level of participation in L&E scholarship. This “incentives hypothesis” is presented and then examined empirically with data gathered from the list of authors in L&E journals and the list of participants in L&E conferences. The data generally support the hypothesis. In legal academia, the incentives to focus research on L&E topics are the strongest in Israel, weaker in North America, and weakest in Europe. In fact, the data reveal that lawyers’ authorship of L&E papers weighted by population is about ten times higher in Israel than in North America; while in Europe it is almost five times lower than in North America. By comparison, the weighted participation level of economists – who face relatively similar academic environments across countries – in L&E research is not significantly different across countries.
Submitted: June 12, 2006 · Accepted: April 16, 2007 · Published: December 11, 2007
(*)
Textul tratatului de la Lisabona (decembrie) aici (*).
“The government plans to let parliament ratify the treaty,” Danish Prime Minister Anders Fogh Rasmussen said after a cabinet meeting on 11 December.
The PM’s decision was confirmed by the Danish Parliament later in the same day, as a broad majority of MPs rejected a counter-proposal tabled by eurosceptic parties to force through a referendum.
Denmark had been considered as one of the few countries whose constitution could require it to consult its citizens on the text – a move feared by pro-EU politicians following the experience of 2005, when voters in France and the Netherlands rejected the draft EU Constitution in referenda, putting the brakes on important reform of European institutions following the Union’s enlargement.
The far-right Danish People’s Party, which, though it supports the governing coalition, still believes a referendum is necessary, says voters are being “cheated”.
According to the constitution, a referendum must take place if a legal review establishes that sovereignty is transferred from Denmark to the EU. However, Rasmussen says a Ministry of Justice review of the final treaty text, agreed by EU leaders last October, has found that the document does not transfer sovereignty from Denmark and that the government is therefore not obliged to call a public consultation.
The decision will come as a relief to many EU leaders as they prepare for the official signing of the Treaty on 13 December in Lisbon. Indeed, the text is expected to easily win the approval of the Danish Parliament, notably after the opposition Social Democrats and Social Liberals gave their backing to Rasmussen’s decision.
A referendum, on the other hand, would have been a riskier option, given Denmark’s ambivalent relationship with the EU. In a 1992 referendum, Danes declined to adopt the Maastricht Treaty, only approving it one year later after the government negotiated a series of opt-outs, notably in the fields of justice and home affairs and defence co-operation. In a separate ballot in 2000, Danes also rejected the euro in favour of the Danish crown.
Following his re-election for a third term as Danish prime minister last month though, Rasmussen hopes to put an end to these opt-outs, with a second round of referenda, most notably on the adoption of the euro.
Rasmussen said he did not know whether his decision would influence the political decision-making process in other countries. “Each country has a sovereign right to make its decision based on constitutional requirements, traditions and customs. We have made our decision based on Danes’ traditions and customs,” he said.
Ireland is now the only country which is constitutionally bound to a popular vote. Other potential candidates for a referendum, including France, the Netherlands and the UK, have all said they would also have the new EU Treaty passed through their national parliaments, despite citizens’ pressure for a public consultation.
(*)
Stirea suna asa:
Jailed killer has right to father a child, European Court rules (*)
Britain breached the human rights of a murderer and his wife by refusing them access to IVF treatment, the European Court ruled yesterday.
Kirk Dickson, 35, and his wife Lorraine now have the right to start a family even though he is serving a life sentence.
The couple, who met via a pen pal network while Mrs Dickson was also in prison, were determined to have a baby but Dickson’s earliest release date from a minimum 15-year sentence is 2009, when Mrs Dickson, of Beverley, East Yorkshire, will be 51.
The Dicksons, who married in 2001, argued that artificial insemination was their only chance to have a child of their own and that a Home Office decision to deny them access to treatment breached their human rights.
They had launched a legal battle in October 2001, but David Blunkett, then Home Secretary, rejected their claim. The Dicksons took their fight to the European Court of Human Rights in Strasbourg, where, in April 2006, they lost again.
However, the court’s Grand Chamber overturned that ruling yesterday, voting 12 to 5 in favour of allowing the couple access to the treatment and awarding them €5,000 (£3,500) in damages and €21,000 in costs.
The couple’s lawyer, Elkan Abrahamson, said last night that they were both elated at the decision. However, it would make little difference because Dickson was now in an open prison and allowed home leave.
Decizia CEDO aici (*).
Uite stire:
Lesbian couple demands child support money from sperm donor
The Telegraph in London has published the testimony of Andy Bathie, a 37 year-old British firefighter who regrets becoming a sperm donor for a lesbian couple that wanted to have a child. The two women, who have since separated, are demanding that Bathie pay child support for their two children.”These women wanted to be parents and take on all the responsibilities that brings. I would never have agreed to this unless they had been living as a committed family. And now I can’t afford to have children with my own wife – it’s crippling me financially,” he said.
Sharon and Terri Arnold, who were united in a homosexual “marriage,” told Bathie he would have no future responsibility for raising the children. Bathie has seen the children only a few times during his life.
But after the women separated, Bathie was contacted by the Child Support Agency and forced to make regular child support payments.
He is now bringing a legal challenge to remove his responsibilities as a parent to the two children in a case believed to be the first of its kind.
Bathie was approached by the couple five years ago after they had unsuccessfully asked other male friends, but no formal legal arrangement was put in place.
“When they (Terri and Sharon) first approached me I did look into the legal side and understood that as a couple they would be the parents, not me. I was never ‘Daddy’,” he told the newspaper.
Sursa (*)
… pe temeiul lipsei de legalitate a pedepselor. Adica nu fenomenul este condamnabil in sine, ci procedura…
Academics call for end to China camps
Wednesday, December 5, 2007
AFP
BEIJING — A group of top Chinese academics and lawyers called Tuesday on the communist government to abolish its labor camp system, saying the penal institutions violated basic human rights and the constitution.The call by 43 academics and lawyers was led by Mao Yushi, a legal scholar and economist at the prestigious China Academy of Social Sciences, and was addressed to the State Council, China’s Cabinet.
The open letter said China’s “re-education through labor” system was unconstitutional as it deprived the rights of those jailed to judicial procedures, a public trial and the right of appeal.
It was dated Tuesday, on China’s annual “law propaganda day,” and widely distributed on the Internet by the rights group Chinese Human Rights Defenders.
“The re-education through labor system has existed for over 50 years but now runs against the trends of the times and is a serious obstacle to the improvement of the state legal system,” He Weifang, a Beijing University legal scholar who signed the letter, told AFP.
“Essentially (penal) judgments are made by the police or the political leaders of the (Communist) party, which is a clear violation of the constitution.”
Besides violating constitutional guarantees to personal freedom, the system also contradicts Chinese laws as well as international human rights conventions signed by China, he said.
Other signers included Yu Meisun, a former secretary in the State Council office, Guo Shiyou, a law professor at the China Politics and Law University and Zhang Ming, a legal scholar at People’s University.
China’s “re-education through labor” system has long been viewed as part of an institutionalized form of human rights abuse by international rights groups like Amnesty International and Human Rights Watch.
The United Nation’s human rights commission has regularly urged China to abolish the system.
Sursa (*)
Am descoperit ceva f. f. interesant si frumos pe internet, un ghid interactiv al manastirilor din Romania; nu sunt toate, insa e f. util: cuprinde informatii de acces, de ordin istoric si chiar fotografii. Poate fi accesat la urmatoarea adresa (*).
Ei bine, din perspectiva istorica, la nivel comunitar, exista, in materia principiului precautiei, o comunicare a Comisiei (COM(2000)1).
“The aim of this Communication is to inform all interested parties, in particular the European Parliament the Council and Member States of the manner in which the Commission applies or intends to apply the precautionary principle when faced with taking decisions relating to the containment of risk. However, this general Communication does not claim to be the final word – rather, the idea is to provide input to the ongoing debate both at Community and international level”.
William V. Luneburg “Anonymity and Its Dubious Relevance to the Constitutionality of Lobbying Disclosure Legislation“.
Subject area: Administrative Law, Civil Rights, Constitutional Law, Legislation, Politics, Public Law and Legal Theory, State and Local Government Law (*)
John Burkoff “Search Me?“.
Subject area: Constitutional Law, Criminal Law and Procedure, Law and Society (*)
Vivian Grosswald Curran “The French Legal System: Laypeople and Professionals: La justice en France: Laïcs et professionnels“.
Subject area: Comparative Law, Jurisprudence (*)
Intrucat peste 3 zile este ziua Sf. Nicolae, episcopul Mirei, Lycia (Asia Mica), va recomand tuturor un site foarte interesant si ziditor (*).
