The course aims to provide students with the main elements of international tax law as a specific area of tax law. At the end of the course, students will have acquired a specific professionalism in the field of international taxation and will be able to identify the correct tax treatment of ordinary and extraordinary international transactions from the point of view of direct and indirect taxes.

At the end of the course, the student will have acquired the knowledge of the fundamental principles of international taxation, with an in-depth knowledge of the tax aspects of ordinary and extraordinary management operations of companies. Therefore, at the end of the course the student will be able to: identify the international regulatory sources applicable to income holders and, in particular, to the operations of companies; analyse the sources of case law relating to the cases dealt with; apply current legislation and practice to practical cases of ordinary and extraordinary transactions, tax planning; At the end of the course the student will have gained the ability to illustrate in an effective, clear and persuasive way the basic principles of international tax law learned through the acquisition of a method of exposure and synthesis of the topics studied. It will also be able to communicate the results of the practical cases analysed and studied and the consequent implications motivating them in an open and critical way. At the end of the course the student will be able to analyze the international tax cases, from the point of view of direct and indirect taxation, identify the regulatory sources and practices applicable to them with the ability to manage the work of case resolution both individually and as a group supervisor, all in compliance with times compatible with the concrete case.

The course focuses on the study of international taxation, with particular reference to international corporate taxation. The course will be divided into three parts, the first part dedicated to the general principles of international tax law: The sources of international tax law Typology of international tax rules Competition and taxation disputes International disputes The connection with constitutional principles Income taxation, general aspects. Residence and permanent organization. The taxation of residents' foreign source income The taxation of the Italian income of non-residents The second part is devoted to international taxation with particular regard to companies and groups of companies: OECD conventions and model Multinational companies Joint ventures and groups of companies Global Minimum Tax Groups of companies in the Italian legal system Consolidated taxation of groups of companies in Italy. The system of foreign dividends (European and non-EU) in the national system The taxation of dividends and capital gains The taxation of interest and royalties in community law and in the OECD model Value added tax. Transnational and Community profiles Intra-Community VAT. Taxation in the country of origin or destination VAT, consumption taxation and customs duties Vat supplies on export and import The provision of international services Intra-EU and import regime Brief notes on IRAP, IVIE, IVAFE and Registration Tax E-commerce Web Tax Tax controls and the exchange of information at international level. The third part is dedicated to international tax planning: Evasion, avoidance and legitimate tax savings The international ruling Elusive intragroup techniques Transfer pricing. The different methods of determining the transfer price The BEPS project Tax havens Interposition and trust

Pasquale Pistone, International Tax Law, Turin, GIAPPICHELLI, last edition. Francesco Tesauro, Institutions of Tax Law, 2-Special Part, UTET, latest edition It is recommended to use an updated tax code

The teaching activities will take place for the presentation and analysis of practical cases, conversation and debates, for the illustration of theoretical parts. In the lessons in attendance we will proceed with the analysis of practical and jurisprudential cases also with the possible formation of study groups. Lessons can be held with the help of slides presentations.

The verification of the student's learning takes place through the evaluation of: periodic content tests with mixed content (theory and practical cases) related to the first and second part of the course content, to be held at the end of each, to which a value of 60% of the total final grade will be assigned; the tests will be a quiz, each quiz consists of three questions of which, two multiple choice in which the student will have to tick the box, while the third will be free written; the two multiple answers will be assigned a weight of 50% of the total vote while the answer to free written conduct will be assigned the remaining 50% by weight of the overall vote; final exam in a single oral exam to which a value of 40% of the total final grade will be assigned. The final exam in a single oral exam will last about 20 minutes.

Interest in the subject Active participation in the course Quality and relevance of the proposed theme