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 at providing 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”, 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 analysis 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. 14 of the Didactic Regulations for the Academic Year 2023 - 24 amended by D.R. n. 1349/2023 on December 4, 2023 (possession of at least a three-year degree; basic knowledge, as to the legal disciplines, of at least 60 ECTS (European Credit Transfer System credits) and art. 5 of the Regulation of the Department of Economics approved on June 18, 2021 in the following fields: Business, Economics, Law, Mathematics and Statistics), satisfy the conditions for a serene and effective course attendance.

Direct Taxation

1. The fundamental principles of international tax law: Source-based taxation and Worldwide taxation”.
2. «Double taxation» and «double non-taxation».
3. 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.
4. The concept of residence for tax purposes: natural persons, companies and corporations. Permanent Establishments. Controlled Foreign Companies.
5. Hard Law, Customary Law and Soft Law: the nature and contents of the UN-OECD Double Tax Convention Models. MLI of International Cooperation.
6. Transfer pricing and OECD principal Methods. The "At arms-lenght principle"
8.Taxation of dividends, interest and royalties.
9. The OECD-G20 Action on BEPS.
10. The “Global Minimum Tax”: challenges and opportunities.
11. International Cooperation on tax matters: Exchange of information and Mutual Administrative and Judicial Assistance in Tax Matters.

Indirect Taxation

12. VAT, GST, similar taxes and their functioning. Excise duties. VAT carousel fraud and preventing measures.
13. New Frontier for International Taxation?
14. Climate change and the EU CBAM.
15. the tariff war and the spillover effect on global development and growth.

• Reuven S. Avi-Yonah, Young Ran (Christine) Kim, The International Tax Revolution, Cambridge University Press, (2025);

During the course the students will be informed about the parts of the afore mentioned texts that better deepen the single topics covered.
At the end of each lecture students will also be provided, 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 ('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
- or in an interview, consisting of two topics: one chosen by the student, the other proposed by the teacher.

written and oral

The assignment of the vote in the written test is very simple: the correct answer to the 30 questions of the questionnaire will result in a score of 30/30. In order to obtain the honours or praise (laude) the student concerned must undergo an interview on a single subject chosen by the teacher. It will assess the ability to tackle the subject, which can be seen in the brilliance of the exhibition and the depth of the topics.
In the oral test, the praise is attributed on the same parameters, but the topics are two: one at the choice of the candidate, in which it is assumed the maximum capacity for expression and the level of depth, the other proposed by the teacher. The praise follows from the student’s ability to maintain the same level of "performance" for both subjects under assessment.

Lectures (30 hours), Workshops and Case studies.

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

Goal 16: peace, justice and strong institutions
Goal 17: partnerships for the goals