50077 - INTERNATIONAL AND COMPARATIVE TAXATION
CLMG - M - IM - MM - AFC - CLAPI - CLEFIN-FINANCE - CLELI - ACME - DES-ESS - EMIT
Course taught in English
Go to class group/s: 31
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.
Section One 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.
Section Two 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.
- 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
- 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
A take-home paper of about 8 pages (35.000 to 40.000 characters spaces included) is required. The paper is about a specific issue of the course and the topic is assigned by the professor. Specific sessions of the course are devoted to the definition of the issues of the paper together with the students and a note on how to prepare the paper is distributed. The paper must be handed out by email within specific deadlines which are indicated in the syllabus. There is no need for the students to be present in a specific classroom on a specific exam date. There is no oral examination. The paper is graded according to the normal system of grading adopted in Bocconi. The exam is the same for attending and non attending students. It is possible to follow a stage during the course period.
Students must register for the exam at Punto Blu at the scheduled exam dates; if there is no registration the take-home paper cannot be graded.
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, Amsterdam, IBFD, 2007.