Insegnamento a.a. 2017-2018

50077 - INTERNATIONAL AND COMPARATIVE TAXATION


CLMG - M - IM - MM - AFC - CLEFIN-FINANCE - CLELI - ACME - DES-ESS - EMIT - GIO

Department of Law

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) - 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) - GIO (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 for those Students interested in international corporate taxation and related job opportunities in private practice and in the corporate sector. The course is the only elective course in international taxation offered in the graduate degrees. The course which pairs seminars and case studies to traditional lectures - provides a sound theoretical framework as well as practical tools for dealing with the typical issues encountered in global tax consulting.
The course is divided in two sections, which are aimed to combine the international, EU and comparative approaches to the transnational dimension of taxation.
The first section deals with international and EU tax law: this section is aimed at providing a general framework of the subject matter, together with the discussion of case studies. The second section aims at covering the basic issues of corporate taxation with a comparative approach, focusing on the connections between taxation and business strategy.

Course Content Summary

Section One (International and EU Tax Law).
  • International tax treaties and the OECD Model Tax Convention (tax treaty formation, tax treaty interpretation and key definitions).
  • Basic international taxation rules (tax residence, permanent establishment).
  • Investment income: dividends, interest, royalties.
  • Other categories of transnational income.
  • Principles of international tax planning and analysis of tax treaty case law (including optional presentations by Students).
  • EU tax law (general principles, sources, tax coordination).
  • The case law of the Court of Justice of the European Union in income tax matters (including optional presentations by Students).
Section Two (Comparative Business Tax Law).
  • Basic concepts on the taxation of business income.
  • Basic methods of comparative taxation.
  • Comparative analysis of corporate taxation and circulation of models.
  • The taxation of multinational group of companies.
  • Selected Issues (Distribution of profits; Intra-group financing; global tax consolidation; CFC rules).
In addition, the course provides some practical instruction on how to conduct bibliographic research on international taxation using the resources available through the Bocconi Library and on the drafting and editing of the final paper.

Detailed Description of Assessment Methods

During the semester, a set deadline is scheduled (on 15 May of each year) for the assignment of the titles of the take home paper, which is the only exam assessment method. Therefore, it is not possible to include the course in the study plan in a given academic year and take the exam in the same year unless the Student has not been formally assigned a paper title by the agreed deadline. For the assignation of the final paper title, students should wait for the publication of the list of available titles (released each year by late March/early April) and then forward their preferences to the Professors. The exam consists exclusively in the submission of the final paper in electronic format by the deadlines established in the Syllabus (typically 10 days before the date of each exam session).


Textbooks

The course is based on materials that are placed in the course platform.
The suggested reference book is:
  • A.K. HOLMES, International Tax Policy and Double Tax Treaties. An Introduction to Principles and Application, Amsterdam, IBFD, 2014, 2nd edition.
  • Exam textbooks & Online Articles (check availability at the Library).
Exam textbooks & Online Articles (check availability at the Library)

Prerequisites

There are no prerequisites for the course. The course is open also to Students who have not previously taken a course in tax law or international law.
Last change 05/06/2017 14:26