77391 - International Taxation

Learning outcomes

In this course, students will gain an in-depth understanding of the challenges associated with taxing capital and income in open economies and the tax implications of globalization. The course will delve into the complexities surrounding the taxation of multinational companies, covering essential topics such as tax planning, taxation of cross-border investment, dividends, and the dynamics of shifting profits cross-jurisdictionally. Moreover, students will engage in a critical examination of the international tax landscape, also paying attention to the recent regulatory developments at both national and international levels.

Course contents

Module 1 – A. Zanardi (30 hours)

Principles of international corporate tax

• Conventions for the avoidance of double taxation
• Residence and source principles
• Efficiency in capital taxation
• Permanent establishment, corporate inversion, transfer pricing
• Taxation choices of national governments

• –Global and territorial systems
• –Tax rates

• Focus: the Google case
• The debate about the revision of corporate taxation in an international context
• The OECD agreement about Pillars 1 and 2
• The corporate tax coordination among EU member states

Principles of taxation on international trade

• Destination and origin principles
• Efficiency in the international trade taxation
• European Union’s Value Added Tax

• –The current transitional VAT regime
• –EU VAT rules for electronically supplied services

Module 2 – A. De Vito (50 hours)

• Introduction to Corporate Tax Environment

• Principles of Corporate Taxation

• Multinationals and Profit Shifting

• Transfer Pricing and its Implications

• Tax and Innovation

• Principles of International Taxation

• Anti-Tax Avoidance Rules

• Tax Transparency and Information Disclosure

• Tax Authorities Use of Tax Information

• ESG and Taxation

• Taxation and M&A Transactions

Readings/Bibliography

M.P. Devereux, A.J. Auerbach, M. Keen, P. Oosterhuis, W. Schön, J. Vella, Taxing Profit in a Global Economy, Oxford University press, 2021.

S. Scholes, Mark A. Wolfson, Merle M. Erickson, Michelle L. Hanlon, Edward L. Maydew, Terrence J. Shevlin, Taxes and Business Strategy, Person (5^th Edition), 2014.

Teaching methods

Lectures with theoretical and practical discussions. Case studies, including examples of transfer pricing, M&A, and anti-tax avoidance measures. Classroom discussions based on selected case studies.

Assessment methods

The assessment will consist of a written exam comprising six open-ended questions. There is no oral examination. No supporting material (e.g., textbooks, notes, electronic devices) is allowed during the exam. The maximum score for the exam is 30/30 with honors, and a minimum score of 18/30 is required to pass.

Grading scale:

• <18: Insufficient

• 18-23: Sufficient

• 24-27: Good

• 28-30: Very Good

• 30/30 with honors: Excellent

During the course, a mid-term exam will be conducted on the first part of the syllabus. To complete the exam, students must take the end-term exam on the second module by the official summer 2025 session. The overall grade will be the sum of the scores from the two mid-term and end-term exams.

Teaching tools

All teaching materials will be available on the course’s Virtual Learning Environment.

Office hours

See the website of Alberto Zanardi

See the website of Antonio De Vito