50077 - INTERNATIONAL AND COMPARATIVE TAXATION
CLMG - M - IM - MM - AFC - CLEFIN-FINANCE - CLELI - ACME - DES-ESS - EMIT - GIO
Course taught in English
Go to class group/s: 31
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.
- 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).
- 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).
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).
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).