Insegnamento a.a. 2025-2026

20997 - GLOBAL CORPORATE TAXATION

Department of Law

Course taught in English
Go to class group/s: 31
AFM (6 credits - II sem. - OBS  |  IUS/12)
Course Director:
CARLO GARBARINO

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


Suggested background knowledge

It is recommended to have some knowledge in the principles of taxation law.

Mission & Content Summary

MISSION

This course examines the taxation of corporations and corporate groups—especially multinational enterprises (MNEs)—and equips students with the tools needed for sound, forward-looking tax planning. Drawing on accounting and business-law concepts, it tackles some of the most intricate issues in modern corporate taxation from a practitioner’s perspective. The course is split into two interconnected parts: 1. Foundations of Business Income Taxation - Establishes a common grounding in the basic concepts, principles and compliance mechanics of taxing corporate income, with special attention to the book–tax relationship and the fiscal adjustments required in the income-tax return. 2. Advanced Group & Cross-Border Taxation - Explores the taxation of corporate groups—domestic and multinational—through a comparative lens, emphasizing how tax strategy influences business decisions. Topics include participation-exemption regime, intra-group dividend relief, interest-deduction rules, fiscal consolidation and transparency regimes, and an introduction to tax planning. The module closes with an in-depth look at the OECD/G20 Inclusive Framework’s Pillar One and Pillar Two rules, including the 15 % global minimum tax and its expected impact on MNE structures

CONTENT SUMMARY

A. Business Income & Tax Accounting

  • Introduction to corporate taxation: the tax system
  • Interaction between statutory financial statements and the corporate income-tax return
  • General principles of corporate income taxation
  • Positive and negative components of income; book-to-tax adjustments

 

B. Taxation of Corporate Groups

  • Core features of group taxation and tax-planning techniques
  • Participation exemption for capital gains
  • Intra-group dividend taxation
  • Interest-deductibility limitations
  • Fiscal consolidation regimes
  • Permanent Establishment and Attribution of profit
  • Transfer Pricing
  • Controlled Foreign Companies regime
  • Global Minimum Tax

Intended Learning Outcomes (ILO)

KNOWLEDGE AND UNDERSTANDING

At the end of the course student will be able to...

• Describe the most complex aspects of corporate and group taxation.
• Identify and explain key book-to-tax adjustments.
• Expound the general principles governing business-income taxation in different jurisdictions.
• Recognise the building blocks of effective tax strategy, including the global minimum tax.

 

APPLYING KNOWLEDGE AND UNDERSTANDING

At the end of the course student will be able to...

• Anticipate major tax issues facing corporations and MNEs.

• Assess the tax risks associated with specific transactions.
• Assess whether the participation-exemption regime applies to specific gains.
• Apply statutory rules on interest deductibility.
• Analyse the taxation of intra-group dividends.
• Interpret court decisions on tax matters and relevant provisions of the Italian Consolidated Income-Tax Act (TUIR).


Teaching methods

  • Lectures
  • Guest speaker's talks (in class or in distance)
  • Practical Exercises
  • Collaborative Works / Assignments

DETAILS

  • Lectures
  • Guest Talks (in-person or online) from academics and practitioners who share real-world insights on corporate and international taxation
  • Practical Workshops featuring interactive case studies that translate theory into practice
  • Group Assignments in which students research a topical case, prepare a written report and present their findings to the class

 

During workshops and assignments, students confront real-life scenarios - such as modelling the Pillar Two top-up tax or evaluating the tax consequences of an intra-group restructuring - applying the analytical framework developed in lectures.


Assessment methods

  Continuous assessment Partial exams General exam
  • Written individual exam (traditional/online)
     x
  • Collaborative Works / Assignment (report, exercise, presentation, project work etc.)
 x    

ATTENDING STUDENTS

Students will be assessed on the basis of a group presentation and a final written examination.


NOT ATTENDING STUDENTS

Students that do not participate in the group presentation will be assessed on a final written examination, which will include also the topics of the presentations.


Teaching materials


ATTENDING AND NOT ATTENDING STUDENTS

Textbooks and reading lists will be distributed at the beginning of the course.

Last change 06/06/2025 15:39