CdLM Business Administration

The course has the purpose of providing the students the main tools to understand the general aspects and problems on international tax law, including e.g. issues on double taxation and double non-taxation; the role of multinationals enterprises within the international tax system; transfer pricing; issues on international tax avoidance and tax evasion and the role of exchange of information, among others important international tax law issues. 

The course should prepare the students with the necessary tools to develop a critical approach on the current international tax law developments, using as starting point the study of the OECD Model Tax Convention as well as some basic notions of European Tax Law.

The course is a 100% on-line.

Due to current circumstances, the exams will take place on-line, on the platform Webex.
They will consist of oral interviews with open-ended questions.

The exam is considered passed with a grade of at least 18/30.

For details see https://start.unito.it/

• Introduction: International Tax Law
• The Organization for Economic Co-operation and Development (OECD) and the role of the OECD Model Tax Convention
• General aspects on the OECD Model Tax Convention:
  • Persons and taxes covered
  • Residents for tax treaty purposes
  • Residence v. Source
  • The interaction between tax treaty law and domestic tax law
• Specific provisions of the OECD Model Tax Convention:
  • Interest
  • Dividends
  • Royalties
  • Capital Gains
  • Other income
  • Business Profits and the concept of Permanent Establishment (PE)
• Double Taxation (and Double Non-Taxation)
  • Credit method
  • Exemption method  
• International Tax Evasion, Tax Avoidance and Exchange of Information
  • Tax Evasion and Tax Avoidance as a global issue
  • The OECD Model Tax Convention and Exchange of Information
    • Types of Exchange of Information
    • Fishing Expeditions
    • Case Law (e.g. Julius Baer case -Switzerland)
  • National attempts on exchange of information, e.g. FATCA in the U.S./Intergovernmental Agreements (IGAs).
• Taxation of Multinationals and other International Tax Law Issues:
  • Transfer pricing
  • International Tax Planning
  • Base Erosion and Profit Shifting (BEPS) and other current international tax developments
• Basic notions on European Tax Law
  • Fundamental Freedoms
  • EU Directives concerning International Tax Law Issues
    • Interest and Royalty Directive (I&R)
    • Parent-Subsidiary Directive (PSD)
    • Anti-Tax Avoidance Directive (ATAD) I and II
  • Case Law of the CJEU