INTERNATIONAL TAX LAW

As part of the “Global Development and Entrepreneurship” master’s degree course, aimed at training experts in the analysis of global development, with particular reference to the role of entrepreneurship, as a vehicle for growth in the economic, legal, cultural and social fields, the course “International Tax Law” aims to provide students with the knowledge tools essential to develop a correct international tax planning, aimed at favoring, in increasingly interdependent markets and jurisdictions, the rules of fair competition and tax compliance.

At the end of the course, students will have acquired a systematic approach to international taxation, both with regard to the fundamental principles of cross-border taxation on income, capital and the exchange of goods and services, both with regard to the comparative study of the main tax systems and, finally, to the main models of international conventions on the prevention of double taxation and the so-called "double non-taxation".
To this aim, the concepts of "residence", "place of business" and "permanent establishment"for tax purposes, and the methods of attribution of profits, as well as the measures to combat international tax avoidance and fraud, mutual administrative and criminal assistance, arising from international and supranational conventions, will be particularly deepened.
In this context, learning will make extensive use of the analysys of "case studies", aimed at fostering the development of students' capacity building.

The minimum curricular requirements for access to the GDE Master's Degree Program provided for by art. 5 of the Didactic Regulations for the Academic Year 2021 - 22 (possession of at least a three-year degree; basic knowledge, as to the legal disciplines, of Commercial Law, Law of Economics, International Law, European Union Law, Tax Law), satisfy the conditions for a serene and effective course attendance.

1. Direct taxation: The fundamental principles of international tax law.

2.The main national instruments of taxation: personal income tax; corporation tax; consumption or turnover tax. The factors of taxation: the tax base, the rate, the
anti-avoidance provisions. Tax havens and harmful tax competition.

3. The concept of residence for tax purposes.

4. Double taxation conventions: OECD and UN models.

5. Permanent establishments.

6. Transfer pricing.

7. The "Controlled Foreign Companies"

8. Taxation of dividends, interest and royalties.

9. The challenges of the digital economy.

10. OECD-G20 Action on BEPS

11. International cooperation on taxation: exchange of information and mutual administrative and judicial assistance in tax matters.

12. Indirect taxation: VAT, GST, similar taxes and their operation. Excise duties. VAT carousel fraud and preventing measures.

Reuven S. Avi-Yonah, Advanced Introduction to International Tax Law, Edward Elgar Publishing, (2019);

• Lynne Oats, Principles of International Taxation, Bloomsbury Professional, (2021);

• Mindy Herzfeld, International Taxation, West Academic Publishing, (2020).

During the course the students will be informed about the parts of the above mentioned texts that better deepen the single topics covered.
Students will also be provided at the end of each lesson, with the slides already prepared by the teacher with the relevant documents, constituting didactic material of the course, through the access to the Moodle platform of the Course ('Didactic materials' and 'Slides of Lectures').

The final exam will be held, on student's choice,:
- in a written form, consisting of a questionnaire of 30 multiple choice questions, 1 point for any correct answer no penalty for the mistakes OR
- in an interview, consisting of two topics: one chosen by the student, the other proposed by the teacher.

Lectures (30 hours), Workshop and Case studies.

English

Lectures, Workshops and Case studies will be held in English.

written and oral

This subject deals with topics related to the macro-area "International cooperation" and contributes to the achievement of one or more goals of U. N. Agenda for Sustainable Development