26512 - Internal and International Fiscal Planning Fundamentals

Course contents

Tax planning aimed at legal saving in national and international tax law

Legislation against tax avoidance in national and international tax law

Incomes from abroad and tax credit on abroad incomes

The transfer of a company's seat abroad

Fictitious foreign companies

Incomes in local currency

Transfer price and Black list purchases

Anti-tax haven legislation: limitations to the transfer of residence, taxation of controlled and related undertakings in tax havens and Black list purchases

The global tax consolidation

Non-residents incomes: dividends outflows and permanent establishment

Tax system in the European Union: internal market and European harmonization

International tax system: sources, the OECD model, conditions, residence, permanent establishment and business incomes

Dividends, interest, fees, other incomes and foreign tax credit

Cooperation between states and information exchange

The principle of non-discrimination and amicable agreements

European and international extraordinary operations

Tax havens

Custom duty

Readings/Bibliography

TESAURO, Istituzioni di diritto tributario, Vol. 2, Parte speciale, Utet, Torino, 2012:

FIRST PART:

CHAPT. III, Sect. I, II (par. 13 and 14),

CHAPT.IV,

FOURTHPART

and

TOSI L. - BAGGIO R- Lineamenti di diritto tributario internazionale, Cedam, Padova, 2011

Office hours

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