INTERNATIONAL TAX LAW

Single discipline educational activity

Course Sheet

Course code:

00034L

Academic Year of enrolment:

2020

Year of supply:

2020/2021

Type of Course:

Related/Supplementary

Degree:

Course of 2nd Cycle Degree in ECONOMICS AND COMMERCE

Disciplinary Sector:

Tax Law

Language:

Italian

Location:

PESCARA

Credits:

Programme Year:

Cycle:

Second semester

Hours of classroom activity:

Individual study hours:

102

Prerequisites:

It is advisable to take the exam only after having passed the exams of International Law, Community Law, Commercial Law and Tax Law (when these exams are part of the study program).

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INTERNATIONAL TAXATION

LEGAL SCIENCES FOR INTERNATIONALISATION AND BUSINESS INNOVATION

Objectives

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.
A MODULE of the course - articulated in completely optional seminars - will be dedicated to the study of materials of international taxation in English.

Contents

DIRECT TAXATION OF NON-RESIDENTS AND DOUBLE TAXATION CONVENTIONS
1) Birth and development of international tax law.
2) The cases with elements of extraneousness.
3) The power of taxation and the ability to contribute beyond the territory.
4) 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 tax claims in foreign territory.
9) International double taxation.
10) The OECD model against international double taxation.
11) The treatment of individual income categories.
VALUE ADDED TAX: TRANSACTIONAL AND EUROPEAN PROFILES.
12) The principle of territoriality.
13) Intra-EU transactions.
14) Extra-EU transactions. Imports.
15) VAT warehouses.
(16) Exports.
(17) Non-taxable domestic supplies and triangulations.
(18) Non-taxable supplies and usual exporters.
19. The permanent establishment.
20) Direct electronic commerce.
21) Carousel fraud.
CUSTOMS DUTIES.
22) Imports and customs duties.
A MODULE of the course - consisting of fully optional seminars - will be devoted to the study of materials of international taxation in English.

Extended Syllabus

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
E-mail:
lorenzo.delfederico
@ unich.it
RECEPTION students: Wednesday afternoon from 2.30 to 4.30 pm at the Department
SEMESTER: II
CONTENTS:
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.
16) Exports.
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.
CUSTOMER TAXES.
22) Imports and customs duties.
REFERENCE TEXTS:
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:
Marjaana Helminen,
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
TARGETS:
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.
DIDACTIC METHODS:
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

Recommended Bibliography

For ATTENDING STUDENTS we recommend:
Pasquale Pistone, International Tax Law, Giappichelli, Turin, last edition.
NOT- ATTENDING are advised:
Roberto Cordeiro Guerra, International Tax Law. Institutions, Cedam, Padua, last edition; together with Francesco Tesauro, Institutions of Tax Law Vol. 2 (special part), last edition, limited to the part relating to Value Added Tax- transnational profiles, and customs duties.
FOR WHO CHOOSES TO ATTEND OPTIONAL SEMINARS IN ENGLISH we recommend:
Marjaana Helminen, EU Tax Law - Direct Taxation, IBFD, Amsterdam, latest edition IN E-BOOK VERSION
All national, conventional and EU legislation, as well as legal documentation and administrative practice, can be found on Ministry of Economy and Finance website http://def.finanze.it, on International Bureau of Fiscal Documentationwebsite www.ibfd.com, and on OECD website http://www.oecd.org/tax

Methods of Provision

Conventional

Teaching Methods

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.

Evaluation methods

Verification of learning:

The exam consists of two parts, a first written and a second oral. In the first part, the exam is based on a multiple choice questions (15 questions to be processed within 30 minutes); each question / answer will have the same weight; the mark of the written part will be expressed in thirtieths. In the second part, oral, for those who have shown adequate knowledge of the subject, the exam is completed, by formulating three questions, on different parts of the program. Each question / answer will be given the same weight; the overall and final marks will be expressed in thirtieths.
It is strongly recommended to support it only after having taken the Tax Law exam.

Contacts/More Information

Student reception: Wednesday afternoon from 2.30 to 4.30 pm at the Department of Legal and Social Sciences
E-mail:
lorenzo.delfederico
@ unich.it; phone number: 085/4537621.
Thesis
Students who are interested in the assignment of theses are strongly advised to attend classes.

Università degli Studi
"G. d'Annunzio"

Chieti - Pescara

Aree