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Objective: To assess MRI derived radiomics features of liver fat collected from a cohort of individuals without prior cardiovascular events as imaging biomarkers of type 2 diabetes mellitus (T2DM) and metabolic syndrome (MetS). Material and methods: 400 participants of the KORA MRI substudy underwent comprehensive whole body MRI imaging protocols including T1-weighted dual-echo Dixon (T1-DED), T1-weighted multi-echo Dixon (T1-MED) and magnetic resonance spectroscopy (MRS) sequences. A total of 684 radiomics features were extracted on T1-DED relative fat water content (rfwc) maps of 310 artefact free manually contoured liver volumes of interest (VOI). The corresponding individuals (n = 310, T2DM 12.6 %, MetS 34.5 %) were assigned to stratified training (n = 232, 75 %) and validation (n = 78, 25 %) sets. To assess feature stability, test-retest and inter-rater variance was approximated by generating noise augmented rfwc maps and computationally deformed VOIs, respectively. Feature stability was assessed in terms of the intraclass correlation coefficient (ICC) for test-retest reliability (ICC(1,1)) and inter-rater agreement (ICC(3,k)) on training set data. Stable features (ICC ≥ 0.85) were assessed as imaging biomarkers of T2DM and MetS in random forest (RF) models. For benchmarking, RF models were trained on the participants’ hepatic proton density fat fraction (PDFF) quantified previously on the T1-MED and MRS images as well as the body mass index (BMI). All RF models were evaluated on the validation set using the area under the curve of the receiver operating characteristic (AUROC) and the balanced accuracy (AccuracyB) as performance metrics. Results: The epidemiological characteristics in training and validation sets were not statistically significantly different (p < 0.001). Furthermore, training and validation sets showed strong associations for both test-retest reliability (β 1.027 [1.015 – 1.040]) and inter-rater agreement (β 1.072 [1.040 – 1.103]). A total of 171 features (25.0 %) met the stability threshold (ICC ≥ 0.85). In subsequent RF modelling radiomics features predicted T2DM with AUROC 0.835 and AccuracyB 0.822 and MetS with AUROC 0.838 and AccuracyB 0.787, thereby outperforming all benchmark RF models in both metric categories. Conclusion: In this single-center study radiomics features of MRI-derived hepatic fat were superior biomarkers of T2DM and MetS than hepatic PDFF and the BMI. In the future, hepatic radiomics features deserve further exploration and development as potential biomarkers in metabolic disease.

This is an Opinion Statement prepared by the CFE ECJ Task Force on Case C-172/13, European Commission v United Kingdom, which was decided by the Grand Chamber of the Court of Justice of the European Union (ECJ) on February 2015. This case is in some ways a follow-up to the ECJ's decision in Marks & Spencer and comments on whether the legislative amendments introduced by the United Kingdom are sufficient to ensure compliance with European Union law. After illustrating the case, arguments of the parties and decision of the Court, this Opinion Statement will focus on selected critical points from the Courts decision and Advocate General Kokott's opinion.

The cases Commission v. Spain (C-127/12) and Commission v. Germany (C-211/13) have common features and in both cases the ECJ (second and third chamber) held that the two national measures at issue were contrary to the free movement of capital ensured under Art 63 TFEU and under Art 40 of the EEA Agreement. Both cases were decided without an opinion from the designated Advocates General, Kokott and Mengozzi, respectively.

On 24 February 2015, the Grand Chamber of the ECJ handed down its decision in Case C-512/13, C.G. Sopora, concerning the question of whether a specific requirement to obtain a tax advantage for foreign (incoming) workers violates the freedom of movement of workers (Art. 45 TFEU). This case prominently raises the issue of a differentiation not between nationals and non-nationals (i.e., "vertical discrimination"), but rather between different non-nationals (i.e., "horizontal discrimination") in the context of the taxation of payments of deemed employment expenses ("extraterritorial costs"). By clearly accepting such "horizontal comparison" in the context of Art. 45 TFEU, it resolves a question where the Court "up to now" has "given varying signals". It also suggests that the Court's answer to that question might have wider application.

This is an Opinion Statement prepared by the CFE ECJ Task Force1 on Case C-386/14, in which the 2nd Chamber of the Court of Justice of the European Union (ECJ) delivered its judgment on 2 September 2015, following the opinion of Advocate General Kokott of 11 June 2015.3 The judgment, which has also been the object of an ECJ press release, is a further interpretation of the freedom of establishment in the context of the French "intégration fiscale" and clarifies that taxpayers can claim some benefits of group taxation regime even if EU law would not allow them the full benefit of such regime. It also confirms that an option granted to Member States in secondary EU legislation cannot justify a breach of the fundamental freedoms.

This is an Opinion Statement prepared by the CFE ECJ Task Force1 on Case C-164/12, DMC. After illustrating the facts of the DMC case and the preliminary questions, this document will focus on selected critical points from this case by pointing out some differences between it and its most immediate relevant precedent, National Grid Indus, which has been the subject of a previous Opinion Statement by the CFE.4

This Opinion Statement analyses the Court's decision in Joined Cases C‑39/13, C‑40/13 and C‑41/13, SCA Group Holding BV et al, of 12 June 2014, concerning the question whether the Netherlands violate the provisions on freedom of establishment if they refuse to form a "fiscal unity" ("fiscale eenheid") between domestic companies in cases where one or more intermediate companies are residents of another Member State (C-39/13 and C-41/13) or (2) the common parent company of two domestic sister companies is resident in another Member State (C-40/13). The Dutch "fiscal unity" treats separate entities as one taxable unit for corporate income tax purposes and hence enables, e.g., the full consolidation of profits and losses and disregarding of internal transactions, including reorganisations.

Submitted by rcaetano@stj.jus.br (rcaetano@stj.jus.br) on 2022-04-28T17:09:14Z No. of bitstreams: 2 10_planejamento_tributario_crime_gutmann.pdf: 1845194 bytes, checksum: 5c0a93a30b41517f9f8d3b319bfb6700 (MD5) license.txt: 1239 bytes, checksum: c9b4c351324448672315a00808efb725 (MD5) Approved for entry into archive by betanial@stj.jus.br (betanial@stj.jus.br) on 2022-07-04T18:19:41Z (GMT) No. of bitstreams: 2 10_planejamento_tributario_crime_gutmann.pdf: 1845194 bytes, checksum: 5c0a93a30b41517f9f8d3b319bfb6700 (MD5) license.txt: 1239 bytes, checksum: c9b4c351324448672315a00808efb725 (MD5) Made available in DSpace on 2022-07-04T18:19:41Z (GMT). No. of bitstreams: 2 10_planejamento_tributario_crime_gutmann.pdf: 1845194 bytes, checksum: 5c0a93a30b41517f9f8d3b319bfb6700 (MD5) license.txt: 1239 bytes, checksum: c9b4c351324448672315a00808efb725 (MD5) Previous issue date: 2011

Analysis of how foreign entities (mostly corporations) are being dealth with for domestic income tax purposes.