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The article analyses the latest international tax law developments in dispute resolution settlement protocols and the need for effective multilateral solutions to prevent international double taxation. While several treaties currently minimise the risks of international double taxation, more must be achieved to provide judicial remedies in cases where two states want to tax the same income simultaneously. The OECD has developed a dispute resolution system based on arbitration clauses to be introduced in conventions signed by the state and a brand-new MLI (multilateral instrument) that should be applicable on a broader scale. These remedies have proven unsatisfactory as the taxpayer is not entitled to play any role in these (arbitration) procedures and cannot stand personally in front of any panel. The authors argue that such a scenario is inconsistent with the rule of law and the due process clauses and should be amended. Creating a supranational court with the entitlement to adjudicate the power to tax would be the optimal solution, but this would collide with the position of several states and their distrust of the international judiciary in tax matters. [ABSTRACT FROM AUTHOR]

In 2022, the European Commission introduced, for the first time in its history, a windfall profit tax to be applied on "excessive" profits realized by qualified businesses operating in the "Oil and Gas" sector. Immediately after its implementation, questions arose as to its sustainability and its consistency with constitutional principles of the different member states regulating the domestic power to tax. To assess the consistency with the aforesaid rules, the article samples two countries, inside and outside the EU (Italy and Australia, respectively), and the historical precedents of the matter. Italy has been chosen due to the particularly stringent set of principles regulating the power of the legislature to tax, and Australia has been chosen because of the long-standing experience with superprofit taxes. In most of the scenarios analyzed, one common feature emerged: the complexity in defining the "Extra" nature of the profits and, consequently, the uncertainties in the calculation of the taxable base. In the case of Italy, for instance, the legislator had to intervene in several different moments to fine-tune the taxable base and restore certainty to the tax system. As a conclusion, while the taxation of extra profits should not per se be disregarded, its implementation demands a more robust and precise legal framework together with the understanding that the introduction of such a levy would be a one-way journey for the tax systems: windfall profits taxes would be here to stay. [ABSTRACT FROM AUTHOR]

Aim: To establish the ability of magnetic resonance (MR) and computer tomography (CT) to predict pathologic dimensions of pancreatic neuroendocrine tumors (PanNET) in a caseload of a tertiary referral center., Methods: Patients submitted to surgery for PanNET at the Surgical Unit of the Pancreas Institute with at least 1 preoperative imaging examination (MR or CT scan) from January 2005 to December 2015 were included and data retrospectively collected. Exclusion criteria were: multifocal lesions, genetic syndromes, microadenomas or mixed tumors, metastatic disease and neoadjuvant therapy. Bland-Altman (BA) and Mountain-Plot (MP) statistics were used to compare size measured by each modality with the pathology size. Passing-Bablok (PB) regression analysis was used to check the agreement between MR and CT., Results: Our study population consisted of 292 patients. Seventy-nine (27.1%) were functioning PanNET. The mean biases were 0.17 ± 7.99 mm, 1 ± 8.51 mm and 0.23 ± 9 mm, 1.2 ± 9.8 mm for MR and CT, considering the overall population and the subgroup of non-functioning- PanNET, respectively. Limits of agreement (LOA) included the vast majority of observations, indicating a good agreement between imaging and pathology. The MP further confirmed this finding and showed that the two methods are unbiased with respect to each other. Considering ≤ 2 cm non-functioning-PanNET, no statistical significance was found in the size estimation rate of MR and CT ( P = 0.433). PBR analysis did not reveal significant differences between MR, CT and pathology., Conclusion: MR and CT scan are accurate and interchangeable imaging techniques in predicting pathologic dimensions of PanNET., Competing Interests: Conflict-of-interest statement: None of the authors have received fees for serving as a speaker or are consultant/advisory board member for any organizations; None of the authors have received research funding from any organizations; None of the authors are employees of any organizations; None of the authors own stocks and/or share in any organizations; None of the authors own patents.