INTERNATIONAL TAX LAW
TEACHER: Lorenzo del Federico
DEGREE COURSES: CLEC / M and CLEA / M professional path, 6 CFU
Other Degree Courses: exam of your choice
DEPARTMENT of Legal and Social Sciences
Phone number: 085/4537621
RECEPTION students: Wednesday afternoon from 2.30 to 4.30 pm at the Department
DIRECT TAXATION OF NON-RESIDENTS AND CONVENTIONS AGAINST DOUBLE TAXATION
1) Birth and development of international tax law.
2) The offenses with elements of extraneousness.
3) The tax authority and the extra-territorial contribution capacity.
4) The sources.
5) International treaties on human rights and applicability in tax matters.
6) The law of the European Union.
7) International tax cooperation and exchange of information.
8) The implementation of the tax claims in the foreign territory ..
9) International double taxation.
10) The OECD model against international double taxation.
11) Treatment of individual income categories.
VALUE ADDED TAX: TRANSACTIONAL AND EUROPEAN PROFILES.
12) The principle of territoriality.
13) The intra-EU operations.
14) Extra-EU operations. Imports.
15) VAT deposits.
17) Non-taxable internal transfers and triangulations.
18) Non-taxable sales and usual exporters.
19) The permanent organization.
20) Direct electronic commerce.
21) Carousel fraud.
22) Imports and customs duties.
FOR THE ATTENDANTS we recommend:
Pasquale Pistone, International Tax Law, Giappichelli, Turin, last edition.
FOR NON-ATTENDANTS we recommend:
Roberto Cordeiro Guerra, International Tax Law. Institutions, Cedam, Padua, last edition; together with Francesco Tesauro, Institutions of Tax Law Vol. 2 (special part), the latest edition, limited to the part concerning Value Added Tax -transnational profiles and to the Customs Tributes.
FOR THOSE CHOOSING TO ATTEND SEMINARS IN ENGLISH we recommend:
EU Tax Law - Direct Taxation, IBFD, Amsterdam, latest edition IN E-BOOK VERSION
All national legislation, both conventional and community, as well as the jurisprudential documentation and administrative practice, can be found on the website of the Ministry of Economy and Finance http://def.finanze.it, on International Bureau of Fiscal Documentationwebsite www.ibfd.com
and on the OECD website http://www.oecd.org/tax
The course aims to provide an in-depth and specialized preparation on the European framework, on the fundamental tax models of the States and cross-border taxation. The issues of international taxation of individuals and companies with particular reference will be examined. to intra-corporate income flows, to international tax planning; finally, the European and international profiles of indirect taxation will be examined, with particular reference to international trade.
In-depth seminars are offered alongside the classic classroom lessons.
A MODULE of the course - articulated in completely optional seminars - will be dedicated to the study of materials of international taxation in English.
LEARNING PROCEDURE METHODS:
The exam is oral and it is strongly recommended to support it only after having taken the Tax Law exam, and where possible the exams of International Law and European Union Law