The course aims at providing the students with a knowledge of the main principles and rules pertaining to international tax law, namely to Double Tax Treaties Practice and EU tax law.

Knowledge and understanding: The course will offer key theoretical tools to acquire knowledge of international and EU taxation principles and concepts (as permanent establishment, residence, harmonization, abuse od law) as well as the main sources of international and EU legislation and case law pertaining international and EU taxation. The knowledge acquired will be verified through discussions during the classes and will be decisive for passing the final oral exam. Applying knowledge and understanding: By attending this course students are expected to be able to analyze international ed EU tax cases and examine major developments of international and EU taxation sources. Students must be able to elaborate the topics studied during the course, apply the knowledge acquired and identify possible solutions to problems posed by the rapid evolution of tax legislation. The knowledge acquired will be verified through discussions during the classes and will be decisive for passing the final oral exam. Making judgements: Students must be able to collect the relevant data observing the real world in order to evaluate it on the basis of the knowledge acquired. They will be able to evaluate data independently and to solve cases applying relevant laws and the relevant judges. Students will be required to apply the concepts learned to deepen their knowledge and competence. Communications Skills: This course will give the students the possibility to acquire and understand major terms and concepts in order to communicate their ideas, proposals, analysis and critical reasoning in the field of international and EU taxation. Through the various activities that will take place during the course – lessons with discussion, oral exams, moot courts, workshops – the students will be able to put these communication skills into practice in various contexts, by adapting the terms used to the interlocutor in the specific case, thus gaining advanced rhetorical skills necessary for their professional career. Learning skills: Students must demonstrate they developed an ability to learn and to update themselves through the study of literature and case law positions. This ability is particularly relevant in the fields of international and EU tax laws which are noteworthy for sudden changes given the need to adapt tax rules to the ever-changing economic reality. The acquired solid knowledge of the fundamental aspects of the matter will allow them to carry on also independently further study as well as to undertake different postgraduate training activities.

The course will: - first analyze international tax law general principles; - then provide a detailed view of the main models commonly adopted for the bilateral DTTs; - finally focus on several practical cases giving the students the opportunity to test acquired tools of knowledge by an interactive experience. Followingly, it will focus, on European Taxation law. The course aims to provide students with the main concepts of EU tax law, also through the analysis of the legislation (the Treaty on Functioning of the EU, directives, etc..) and, in particular, the jurisprudence of the Court of Justice of the EU (CJEU). At the end of the course, students are expected to be comfortable with the OECD Model Convention, the jurisprudence of the CJEU and with the trends in EU tax law.

International Taxation - OECD, Model Tax Convention on Income and Capital, 2017 (selected articles) - K. Vogel, “Klaus Vogel on double taxation convention”, Chapter “Introduction” p. 1-7, 16-17 and 31-36, 2015, Kluwer Law. - M. Lang, “Introduction to the law of Double Taxation Conventions”, Chapter 7 (Persons covered and residence), 2024, IBFD. - M. Lang, “Introduction to the law of Double Taxation Conventions”, Chapter 9 (Allocation rules), 2024, IBFD. - G. Gallo, “Roy Rohatgi on International Taxation”, Chapter 11 (Active Income of Companies) pag. 1-27, 2018, IBFD. - C. Hamra – J.J. A.M, “Beneficial ownership interpreted, to what extent are the OECD and the EU on the same wavelength?”, 2021, Intertax (extract pag. 254-265). - S. V. Kostic, “OECD / UN / International - In Search of the Digital Nomad – Rethinking the Taxation of Employment Income under Tax Treaties” World Tax Journal, 2019. - A. Silvestri, “Holding companies in the BEPS era”, 2017, Intertax. Slides that will be distributed EU Taxation Mandatory Materials: slides that will be distributed Optional Materials: Terra-Wattel, European Tax Law, Seventh edition, 2019, Abridged Student edition (selected chapters)

Lectures and presentations on relevant topics. Presentations will be made available to students. Considering the structure of the course, class attendance is highly recommended. Class attendance at least equal to 75% of the total class time and student’s active participation during classes will be positively considered in the final assessment. INTERNATIONAL AND EUROPEAN TAX MOOT COURT COMPETITION Starting from the academic year 2004-2005, Luiss Guido Carli takes part to the International and European Tax Moot Court Competition. This is a competition that simulates a process, in which the delegations (consisting of a maximum of 4 persons) of selected EU and non-EU universities face off on a specific topic of International and/or European tax law. Simulating an oral hearing before an international court, the different teams draft a written memorandum and plead before the court, illustrating the relevant arguments. Participation to this project requires a research activity to be carried out at LUISS in order to properly draft the written memorandum. The oral phase will take place in Belgium (at the Katholieke Universiteit Leuven) and will be concentrated in one week. During this week seminars on topics of International and EU law also takes place. Students will be invited to apply via email for the participation to the Moot Court. Specific details on the selection procedures will be communicated in due time. INTERNATIONAL AND EUROPEAN TAX MOOT COURT COMPETITION - BENEFITS FOR PARTICIPANTS Students selected as participants to the International and European Tax Moot Court will receive the following benefits: - in the final oral exam, one question will refer to one of the topics covered by the case of the International and European Tax Moot Court; - in the final oral exam, the student will receive a consideration ranging from positive up to excellent depending on: (i) the extensiveness and quality of the research activities carried out on the topics relevant for the case of the International and European Tax Moot Court; (ii) the quality of the written memorandum drafted as of the date of the final exam.

Midterm exam: written exam with question(s) covering the topics discussed during the first 6 weeks of classes. Final exam: oral exam In the midterm and oral exams the students are required to show that they know and understand notions and principles of international taxation. The students are expected to be able to independently analyze sources and relevant theories of tax law and to use the appropriate technical and legal vocabulary, thus proving that they have acquired the study method and the learning ability for carrying on, also independently, further study of the matter. Learning gaps concerning one or more notions or principles will lead to an insufficient evaluation, even in presence of a basic knowledge of the matter.

As for the thesis, first of all the student should have attended the course. Once the topic is identified and defined with the professor, the student is required to: 1. Carry out a preliminary research on the topic; 2. Draft a preliminary bibliography; 3. Read the materials; 4. Draft a preliminary outline of the thesis; 5. Submit the preliminary outline to the professor for his approval. After the approval of the outline, the student can start writing the thesis, under the supervision of either the professor or one of the teaching assistants.