8301 - INTERNATIONAL AND COMPARATIVE TAXATION

The course is divided in two sections, which are aimed to combine the international and comparative approach to the study of international investments.
The object of section one is international taxation of individuals and corporations, with particular attention to intra-group flows of income, holding-intermediary company structure and group taxation. The aim of section one is to provide advanced skills to implement tax planning strategies for  group of companies at the international level.
Section two deals with the taxation of groups of companies, with particular attention to comparative analysis, with the aim to provide the basic elements for effective tax planning within group structures. The aim of section two  is to cover the basic issues of corporate taxation with a comparative approach, focusing  on the connections between taxation and business strategy.

Section one

• Introductory aspects
• Taxation of non residents and worldwide taxation
• International tax treaties and OECD Model
• Basic international taxation ruleS (tax residency, permanent establishment)
• Intra-group flows of income (dividends, interest, royalties)
• Other classes of transnational income
• UE tax law (tax coordination, ECJ case law, tax Directives)
• The taxation of multinational group of companies
• Transfer price 

Section two

• Comparative analysis of corporate taxation
• Structural elements of group taxation
• Basic elements of tax planning
• Tax aspects of participation exemption
• Tax rules on thin capitalization
• Fiscal unity at domestic level
• Worldwide fiscal unity
• Tax aspects of reorganizations

Written examination and take-home paper

• International and EU tax materials will be distributed to the students;
• K. VAN RAAD, Materials on international and EC tax law, Leiden, International Tax Center Leiden, 2005, 5^th ed.