30173 - Advanced Tax Law

Learning outcomes

The course aims to develop the knowledge required to correctly apply the tax regulations governing the most complex business and professional decisions, with particular focus on extraordinary events affecting the company and the operations of corporate groups. By the end of the course, students will be able to: - interpret the regulatory framework to correctly fulfil the obligations required by tax laws; - provide tax advice on extraordinary events affecting companies and on the taxation of corporate groups; - understand the main rules governing corporate taxation in domestic and international law.

Course contents

General overview of IRES in the income tax system

IRES taxpayers

Companies, commercial entities and non-commercial entities

Taxation of non-commercial entities

Associative entities

Third sector entities (TSE)

Cross-border income (income of non-residents generated in Italy and income of residents generated abroad)

Participation exemption

Loss carry-forward

Tax implications of IAS/IFRS international accounting standards

International VAT

Tax transparency

National consolidation

General profiles of extraordinary transactions Transformations

Mergers Demergers

Company contributions

Business transfers

Voluntary liquidation

Taxation of instruments for resolving corporate crises

Tax debt agreements

Judicial liquidation

International taxation (overview)

Italian municipal property tax (IMU)

Registration tax

Inheritance and gift tax

Other indirect taxes (stamp duty, mortgage and cadastral taxes, web tax, excise duties, customs duties, etc.)

Local taxation

Taxation of the digital economy, blockchain and cryptocurrencies, use of artificial intelligence in taxation.

Readings/Bibliography

In addition to the updated text of Italian Presidential Decree No. 917 of 22 December 1986 (which can be downloaded from the Internet or found in a tax code),

the textbook adopted is:

TESAURO, Istituzioni di diritto tributario, Vol. 2. Parte speciale, Utet, Turin, latest edition available (13th edition, 2023):

PART ONE:

CHAPTER I, PAR. 1

CHAPTER II, Sections II and V

CHAPTER III, SECTION I, II (only par. 6, 6.1., 6.2., 9.1., 9.2., 9.3., 12), and III.

CHAPTER III SECTION III

CHAPTER V

CHAPTER VI SECTION III CHAPTER VII, VIII, IX, X

CHAPTER VIII, IX, X

N.B.: This book must be read and studied carefully without summarising the information as the text is already concise.

N.B.: It is assumed that students have knowledge of the preparatory topics and concepts covered in the three-year first-cycle degree programme which are present in the parts of this volume that I have not included here as part of this programme.

We recommend that students consult a collection of essential regulations, the recommended volume being:

LOGOZZO, Codice tributario 2025, Pacini Giuridica, Pisa 2025

For further reading and additional information, we recommend

MELIS, Manuale di diritto tributario, seventh edition, Giappichelli editore, Turin 2025, in the sections relating to the topics covered in the programme.

Teaching methods

Lectures and possible exercises on certain topics covered in the programme

N.B. Teaching methods may be subject to change (e.g. distance learning) if required in response to health emergencies

Assessment methods

The examination will be oral.

Students will be assessed based on their responses to questions on the course topics, formulated at the discretion of the lecturer.

Grading scale:

18-23: sufficient preparation and analytical skills but relating to a limited number of topics covered in the course, use of generally correct language;

24-27: technically adequate preparation but with some limitations regarding the topics covered, good analytical skills, although not particularly articulate, expressed in correct language;

28-30: excellent knowledge of a wide range of topics covered in the course, good analytical and critical skills, mastery of specific terminology;

30L: excellent, in-depth and comprehensive knowledge of the topics covered in the course, critical analysis and connection skills, mastery of specific terminology.

N.B. Examination methods may be subject to change (e.g. written or remote examination) in the event of a health emergency.

Teaching tools

The updated text of Italian Presidential Decree No. 917 of 22 December 1986 (Italian Tax Code), textbooks recommended by the lecturer as well as any other material that the lecturer deems useful to provide during the lessons will be used for teaching purposes.

N.B.: the study of the above-mentioned textbooks (TESAURO and MELIS) covers the topics of the programme explained in class and is essential for achieving a solid preparation and passing the exam.

Lessons may be enriched by practical examples and exercises

Office hours

See the website of Filippo Cicognani