BUSINESS TAX LAW

The course is finalized to provide to students a thorough and a professional knowledge tax law subject, with specific reference to most relevant interest sectors for economics graduating students. Main themes that will be analyzed are company income and national and international tax planning. The course will be organized to ensure the analysis of corporate taxation, national tax planning (extraordinary corporate transactions, national tax consolidation regime) and international tax planning (double taxation Conventions, transfer pricing, permanent establishment, international tax consolidation regime).

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The aim of the training activities is to develop in students skills to analyze the regulatory texts, as well as logical connections between institutions of common law and the discipline of corporate taxation, individual and collective, in the context of income tax and VAT. The student will master the implementation patterns of tax reports, with the acquisition of a method of approach to problems aware also of the practical implications. In this way, an interdisciplinary knowledge, required for the student who is interested in working professionally in the areas of business consulting, as well as in the exercise of judge of tax commissions, officials of the tax agencies and tax offices of public and private administrations, will be acquired. Skills will be acquired with the frequency of frontal lessons and with the constant use of references to concrete acts and cases. These skills will be verified by passing exams, classroom discussions, and case analysis, including using slides, materials and other multimedia content available on the platform. Working groups will also be organized among the students to be presented in the classroom. The student will learn an in-depth preparation on the issues of tax law concerning the taxation of the company, including special disciplines (tax consolidations, extraordinary operations), without neglecting, in addition, the most important profiles of transnational tax law (transfer pricing, stable organization, etc.). Knowledge is acquired with the frequency of frontal lessons and the constant use of references to acts and cases. This knowledge is verified by passing exams, classroom discussions, case analysis. The student will acquired an ability to assess and judge on tax issues with particular regard to the interpretation and application of national and international regulatory sources. It will then have acquired problem analysis skills, the ability to identify reference regulations, the appropriate procedures for situations and the consequent identification of solutions for practical cases. Specifically, critical thinking, problem solving, self-management, relationship and communication skills will be developed, which enhance and make disciplinary skills more expendable. These skills are verified not only through passing exams, but also in the classroom and in case analyses. The student will have to master the legal lexicon and acquire a terminology accuracy in the matter of tax law and an appropriate argumentative ability. The training course also guarantees appropriate language skills in at least one foreign language for the creation and development of professional relationships, communication and transmission of communications and acts in a European and international context. Communication skills are achieved and verified through examination tests requesting elaborate exhibition and argument capacity, as well as processing and discussing cases. The student at the end of the course will acquire the ability to identify and interpret any changes in legislation and new doctrinal and jurisprudential orientations, having acquired a degree of knowledge to develop learning skills that allow him to continue to update himself, even independently.

The course is finalized to examine the corporate taxation, with specific reference to income tax (IRPEF and IRES) and IVA. Furthermore, particular attention will be given to national and international tax planning. Therefore, the course will be divided in two parts. The course first part, foreword a general and introductory part on the tax system and its general principles (including the regulation of tax avoidance), will be concern company tax system. In particular, the following topics will be analyzed : • IRPEF taxpayers (company income holders) and IRES taxpayers; • Residence for tax purposes and the so-called “relocation abroad”; • Company income computation rules: “derivation principle”, others general principles, tax relevant revenues and costs, IAS-adopters company income computation rules. The second part will be concern national and international tax planning: • fiscal aspects about extraordinary corporate transactions; • national and international tax consolidation; • CFC rule; • transfer pricing; • world wide income taxation and the principle of source for non-resident tax system: the permanent estabilishment; • Agreements for the avoidance of double taxation, specifically company and financial income; • the VAT framework

Salvini L. Diritto tributario delle attività economiche, Giappichelli, Ultima edizione Teaching material will be distributed in class and inserted on the platform. The use of an up-to-date code of fundamental tax laws is also required.

- online and on-campus frontal lessons - discussion on selected topics - case studies Working groups will also be organized among students with presentation in the classroom and evaluation of the results achieved and the exhibition capacity

Attending students are required to: a) participate in one of the Working Groups; b) write a short essay (word document) on a topic of your choice among those that will be indicated at the beginning of the course, to be reported during the oral exam. For these attending students, the total activity carried out in points a) and b) above constitutes 70% of the final grade and the remaining 30% of the final grade is made up of the oral exam (i.e. questions on the entire program of the course). For non-attending students (or who have not profitably participated in the Working Groups and completed the brief memory), the final mark is entirely attributed (100%) during the oral exam (i.e. questions on the entire program of the course)

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