Course 2026-2027 a.y.

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.
• Pillar One and Two OECD Inclusive Framework
• 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.

• Recognize the key issues of international taxation.
• Illustrate the principles of tax planning.
• Explain the most relevant aspects of comparative business law.
• Identify the main features in cases from the Court of Justice of the European Union.
• Select the most relevant aspects of a tax treaty.

• Analyze and interpret the most relevant and widespread elements of international taxation.
• Compare different situations in business taxation.
• Discuss on problems concerning cross-border taxation.
• Arrange a presentation on a case of the Court of Justice of the EU or on a tax treaty.
• Organize and develop a paper on an international tax theme.

• Lectures
• Guest speaker's talks (in class or in distance)
• Individual works / Assignments
• Interaction/Gamification

During the course, external guest speakers  give talks on specific issues of international taxation.

There is the possibility for students to give a presentation on a case study, concerning one of the topics of the course.

The assessment includes two compulsory components. First, an in-class presentation worth up to 16 points, which will be completed iin groups; all the students belonging to a group and presenting together will receive the same mark. Second, a multiple-choice final examination - also carrying a maximum of 16 points - will be held  during the scheduled exam session.

The in-class presentation is aimed at assessing students’ ability to analyze and discuss issues related to international taxation, cross-border taxation, EU Court of Justice cases or tax treaties, and to present their arguments in a clear and structured way. It also allows students to demonstrate their ability to compare different business taxation situations and to organize and develop a reasoned analysis on an international tax topic.

The multiple-choice final examination is aimed at assessing students’ knowledge and understanding of the key issues of international taxation, the principles of tax planning, the most relevant aspects of comparative business law, the main features of EU Court of Justice cases, and the relevant aspects of tax treaties

The course textbooks are:

• C. Garbarino, Taxation of Bilateral Investments, Cheltenham, Elgar, 2019.

• C. Garbarino, Judicial Interpretation of Tax Treaties, Cheltenham, Elgar, 2019