95030 - International Corporate Taxation

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

PISTONE P. Diritto tributario internazionale, 2a edizione, Giappichelli, Torino, 2019

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PISTONE P. Diritto tributario europeo, 2a edizione, Giappichelli, Torino, 2020

The students more interested, will can complete the textes above suggested with:

CORDEIRO GUERRA R., Diritto tributario internazionale. Istituzioni, Cedam, Padova, 2016

SACCHETTO (a cura di), Principi di diritto tributario europeo e internazionale, Giappichelli, Torino, 2015 (in particolare per le operazioni straordinarie, il regime cfc, il transfer price, l'abuso del diritto tributario europeo ed internazionale)

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TOSI L. - BAGGIO R., Lineamenti di diritto tributario internazionale, casa editrice Cedam, Padova, 2011 (in particolare per il diritto doganale).

Teaching methods

Lectures and (or) online lessons and possibly exercises on some of the subjects of the program.

Web Seminars

 

 

Assessment methods

Oral exam

The student's evaluation will be based upon his/her answers to questions on the subjects of the program. Questions will be at the teacher's discretion.

Teaching tools

The teaching supporting instruments will be the updated text of the D.p.r. December 22nd 1986, n. 917 (Tuir), the textbooks suggested by the teacher, the notes and the synthetic slides that will be made available to the attending students, in addition to any other material the teacher will deem it useful to supply during the lessons.

Graduation grid of marks:

- 18-23: sufficient preparation and ability to analyze but relating to a limited number of topics covered in the course, use of an overall correct language;
- 24-27: technically adequate preparation but with some limits with respect to the topics covered, good operational skills, even if not particularly articulated, expressed in correct language;
- 28-30: very good knowledge of a large number of topics covered in the course, good operational and critical skills, high-level usage of specific terminology;
- 30L: excellent and very in-depth and exhaustive knowledge of the topics covered in the course, critical analysis and connection skills, very high-level usage of specific terminology.

Office hours

See the website of Filippo Cicognani