8301 - INTERNATIONAL AND COMPARATIVE TAXATION
MM-LS - AFC-LS - CLAPI-LS - CLEFIN-LS - CLELI-LS - DES-LS - CLG-LS - M-LS - IM-LS - ACME-LS - EMIT-LS
Department of Legal Studies
Course taught in English
CARLO GARBARINO
Course Objectives
The course is divided in two Sections, which are aimed to combine the international and comparative approach to the study of international investments.
Section One deals with international and EU tax law covering intra-group flows of income, holding/intermediary structures and group taxation and is aimed at providing a general framework of the topic matter, without specific reference to national tax systems.
Section Two deals with the taxation of group of companies, with particular attention to comparative analysis, with the aim to outline the basic variables 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, with particular attention to EU tax law.
Course Content Summary
Section One
- Taxation of non residents and worldwide taxation
- International tax treaties and OECD Model
- Basic international taxation rules (tax residency, permanent establishment)
- UE tax law (tax coordination, ECJ case law)
Section Two
- Comparative analysis of corporate taxation
- Principles of international tax planning
- The taxation of multinational group of companies
- Transfer price
Detailed Description of Assessment Methods
Attending studens and non-attending students: take-home paper.
Textbooks
- Course material provided by instructors
- K. Van Raad, Materials on international and EC tax law, Leiden, International Tax Center Leiden, 2005, 5th ed.