37322 - International Taxation

Academic Year 2019/2020

  • Docente: Villiam Rossi
  • Credits: 12
  • SSD: SECS-P/03
  • Language: Italian
  • Teaching Mode: Traditional lectures
  • Campus: Bologna
  • Corso: Second cycle degree programme (LM) in Economics and Accounting (cod. 0900)

Learning outcomes

The course covers the principles and economic effects of companies’ income taxation and capital income taxation (interests, dividends and capital gains), the main features of the Italian and European income taxation systems and the economic effects of the current legislation, as well as of recent or under-discussion reforms.

Course contents

Fundamentals and sources of international taxation.

Conventional tax law; the OECD Model Tax Convention for the avoidance of double taxation.

Double taxation, methods to avoid or limit it; tax credit for foreign-earned income.

Community Law.

International administrative cooperation: the OECD Model and the European Union’s rules.

Transnational income taxation:

  • Country of residence and of source taxing power;
  • Individuals and companies’ residence;
  • The tax inversion phenomenon;
  • The permanent establishment;
  • Dividends, interest, royalties and capital gains.

Tax planning and international avoidance:

- Tax evasion, tax avoidance and abuse of law;

- Countries with preferential tax regime;

- Tax competition;

- Treaty abuse; treaty shopping;

- Motions against aggressive tax planning and international tax evasion and avoidance phenomena;

- Controlled foreign companies (CFC) rule;

- Interest limitation rule;

- Hybrid mismatches.

Tranfer pricing rule:

- OECD guidelines;

- Transfer pricing determination;

- Methods used for the prevention and settlement of disputes.

The Patent Box system.

Extraordinary cross-border transactions.

Common consolidated corporate tax base.

Community VAT.

VAT fraud. Law enforcement actions and instruments at Community and National level.

Readings/Bibliography

The teaching material will be available on the teacher’s website during the lessons. Supplementary readings and teaching materials will be recommended during the lessons.

Teaching methods

The course is held in Italian. Frontal lessons.

Assessment methods

Writte nexam.

Teaching tools

See Villiam Rossi’s website.

Office hours

See the website of Villiam Rossi