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Course 2015-2016 a.y.

50077 - INTERNATIONAL AND COMPARATIVE TAXATION


CLMG - M - IM - MM - AFC - CLAPI - CLEFIN-FINANCE - CLELI - ACME - DES-ESS - EMIT
Department of Legal Studies

Course taught in English


Go to class group/s: 31

CLMG (6 credits - II sem. - OP  |  IUS/12) - M (6 credits - II sem. - OP  |  IUS/12) - IM (6 credits - II sem. - OP  |  IUS/12) - MM (6 credits - II sem. - OP  |  IUS/12) - AFC (6 credits - II sem. - OP  |  IUS/12) - CLAPI (6 credits - II sem. - OP  |  IUS/12) - CLEFIN-FINANCE (6 credits - II sem. - OP  |  IUS/12) - CLELI (6 credits - II sem. - OP  |  IUS/12) - ACME (6 credits - II sem. - OP  |  IUS/12) - DES-ESS (6 credits - II sem. - OP  |  IUS/12) - EMIT (6 credits - II sem. - OP  |  IUS/12)
Course Director:
CARLO GARBARINO

Classes: 31 (II sem.)
Instructors:
Class 31: CARLO GARBARINO


Course Objectives

The course is particularly suited to those students interested in international corporate taxation and related job opportunities in private practice and in the corporate sector. The course is open also to students who have not taken previously a tax course. The course is the only elective course in taxation offered in the graduate degrees. It is possible to follow a stage during the course period. The course complements the basic tax courses and adopts an international tax planning approach, thereby providing the correct tools for dealing with the typical issues encountered in global tax consulting. The course is preliminary to tax stages in business taxation (usually offered in the second semester of the last year) and the teaching method, which is structured through case studies and seminars, is aimed at providing the main tools of international tax consulting.The course is divided in two sections, which are aimed to combine the international and comparative approach with the study of international investments.
The first section addresses the issues of tax treaties and deals with international and EU tax law covering intra-group flows of income, holding/intermediary structures and group taxation; this section is aimed at providing a general framework of the subject matter, together with the discussion of case studies. 
The second session deals with the taxation of group of companies, with particular attention to comparative analysis, with the aim to identify the basic variables for effective tax planning within group structures. The aim of this section is to cover the basic issues of corporate taxation with a comparative approach, focusing on the connections between taxation and business strategy, with particular attention to EU tax law.  


Course Content Summary

 Section One

  • Basic concepts on the taxation of business income.
  • International tax treaties and OECD Model.
  • Basic international taxation rules (tax residency, permanent establishment).
  • Investment income: dividends, interest, royalties.
  • Other classes of transnational income.
  • UE tax law (general principles, sources, tax coordination).
  • The tax decisions of ECJ.

Section Two

  • Comparative analysis of corporate taxation and circulation of models.
  • Basic methods of comparative taxation.
  • Principles of international tax planning.
  • The taxation of multinational group of companies.
  • Transfer price.
  • Distribution of profits.
  • Intra-group financing.
  • Global tax consolidation.
  • CFC rules.

Detailed Description of Assessment Methods

During the semester of lessons a set deadline is scheduled (on 20 May of each year) for assigning the titles of the take home paper which is the unique exam assessment method. Therefore, it is not possible to include the course in the study plan and sit for the relating exam if, by such deadline, the student has not been included in the list prepared by the professors including the titles of the take home papers assigned to each single student with the purposes of preparing the paper and submitting it (10 days before the dates of each session available).


Textbooks

The course is based on materials that are placed in the course platform. The materials are aimed at providing all the essential documentation for the students to write the take-home paper required for the exam. There is no required text for the exam, as the exam is based on course material and is in the form of a take-home paper. The suggested reference book is:

  • A.K. Holmes, International Tax Policy and Double Tax Treaties. An Introduction to Principles and Application, II Edition, Amsterdam, IBFD, 2014.
Last change 27/03/2015 12:44