Learning objectives
The course is designed to provide knowledge of the fundamental concepts in international and European tax law, offering an overall framework of the aspects determining taxation of income from abroad, with particular regard to income earned by companies and their multinational structure, and to operations between resident and non-resident companies.
Course unit content
International tax law. International tax planning and conventions regarding double taxation. Tax harmonisation in the EU and the principles of non-discrimination and non-restriction. Residence and the multinational company. Taxation of multinational company income. The stable organization and determination of income according to the OECD convention model. Trusts and segregated assets. Tax avoidance and evasion. Rulings in accordance with international standards. Inter-state information exchange according to article 26 of the OECD convention model, and amongst EU countries.
Bibliography
1. Armonizzazione fiscale nella comunità europea - in Enciclopedia giuridica Treccani, Sacchetto (Rome, 1989) <br />
2. Corso di diritto tributario internazionale, Uckmar Victor (2005), Cedam <br />
3. Diritto internazionale tributario, in Digesto discipline privatistiche, sezione commerciale, Croxatto (Turin, 1989), Utet <br />
4. Doppia imposizione internazionale, in Digesto discipline privatistiche, sezione commerciale, Fantozzi-Vogel, Utet – Turin <br />
5. Evasione ed elusione tributaria, in Enciclopedia giuridica, Treccani, Rome; Course of international tax law, coordinated by V.Uckmar, Padua, (2002), chapters: IV, VIII, X, XI, XVIII. <br />
Teaching methods
The specialised nature of the subjects examined during the course means that attendance of lessons is recommended.
