Unibo Principal Investigator: Prof. Adriano Di Pietro, Dept. of
Legal Studies (DSG), Director of European School of Advanced Fiscal Studies
Brazilian Principal Investigator: Prof. Heleno Taveira Torres, Universidade de Sao Paulo (USP) , Faculdade de Direito
The research is aimed to verify the sustainability of European model for the Brazilian tax system related to international business, and viceversa: as a renown European model is based on harmonization of indirect taxation and coordination of direct taxation.
The benefits for Brazil and Europe are double: in internal market, it serves to rationalize the taxation of international and national business; in regional markets of Latin America ,the Brazilian business would allow to get benefit from the economic integration with the garantee of fiscal neutrality.
The taxation models and supranational limits adopted - following the European experience - could also be at the base of a Latin-American tax system. This could represent a best practice for economic integration in regional markets.
Project guidelines
- neutrality of taxation as common need for granting freedom of choosing legal form and territory for de-localising legal and economic aspects
- the role of European Treaties and case law dealing with Latin-American Treaties
- legal instruments for intrnationalization of business
- national power taxation and freedom of movement for business: exit tax in Europe and Latin- America
- group companies as economic and financial integration: legal acknowledgment of group for taxation of the overall profit
- intragroup relations and certainty for investment: transfer pricing on good and services
- legal double taxation as obstacle for the internationalization of business: the role of Conventions an the relation with national systems
- tax reliefs for relocation: constitutional coherence and prohibition of State aids in European fiscal system and WTO, the role of internal territorial differences: comparison of federal States and federal models.
Research group
ALMA MATER STUDIORUM-UNIVERSITA DI BOLOGNA
- Prof. Andrea Carinci, DSG
- Prof. Adriano DI Pietro, DSG
- Dr. Giangiacomo D'Angelo, DSG
BRAZIL
- Prof. Heleno Taveira Torres, USP
- Prof. Paulo Ayres Barreto, USP
- Prof. José Maria Aruda de Andrade, USP