International tax coordination

Pasquale PISTONE International tax coordination

0222200047
DIPARTIMENTO DI SCIENZE ECONOMICHE E STATISTICHE
EQF7
ECONOMICS
2016/2017

YEAR OF DIDACTIC SYSTEM 2014
SECONDO SEMESTRE
CFUHOURSACTIVITY
1060LESSONS
Objectives
KNOWLEDGE AND UNDERSTANDING:
STUDENTS WILL ACQUIRE AN ADVANCED KNOWLEDGE OF PRINCIPLES AND RULES, FROM A GENERAL AND PRACTICAL VIEWPOINT, RELATED TO EUROPEAN AND INTERNATIONAL TAX LAW. THIS AIM WILL BE REACHED ALSO THROUGH THE ANALYSIS OF CASE LAW AND DISCUSSION OF CASE STUDIES.

APPLYING KNOWLEDGE AND UNDERSTANDING:
STUDENTS WILL BE ABLE TO APPLY THE KNOWLEDGE WITH A VIEW TO SOLVING ISSUES OF EUROPEAN AND INTERNATIONAL TAXATION. THE STUDENT WILL BE ABLE INDEPENDENTLY TO ANALYSE TAX LEGISLATION IN THE EU AND THE EUROPEAN COURT OF JUSTICE CASE LAW, AND HE WILL BE ABLE TO UNDERSTAND AND INTERPRET TAX TREATY LAW.

MAKING JUDGMENTS:
STUDENTS ARE REQUIRED TO ACQUIRE CRITICAL SKILLS AND COMPETENCES IN THE FIELD OF EUROPEAN AND INTERNATIONAL TAX LAW, WITH A VIEW TO FORMULATING AUTONOMOUS CRITICISM.

COMMUNICATION SKILLS:
STUDENTS WILL BE ABLE TO INTERACT WITH THIRD PARTIES DURING THEIR PROFESSIONAL PRACTICE.

LEARNING SKILLS
STUDENTS WILL BE ABLE TO SOLVE ISSUES OTHER THAN THOSE DISCUSSED DURING THE COURSE. STUDENTS WILL BE ABLE TO DEVELOP THEIR KNOWLEDGE THROUGH EUROPEAN AND INTERNATIONAL TAX JOURNALS, TAX AND ACCOUNTING DATA BANKS, DOCUMENTS OF THE EU INSTITUTIONS AND OF THE OECD.
Prerequisites
NONE
Contents
COURSE DESCRIPTION:
EUROPEAN TAX LAW: THE IMPLICATIONS OF EUROPEAN INTEGRATION FOR ITALIAN TAXATION; THE SOURCES OF EU LAW; DIRECT AND INDIRECT TAXATION; THE APPLICATION OF THE FUNDAMENTAL FREEDOMS IN TAX MATTERS; THE NON-DISCRIMINATION PRINCIPLE, INFRINGEMENT OF THE FUNDAMENTAL FREEDOMS AND THE RELEVANT JUSTIFICATIONS; STATE AID IN TAX MATTERS; SECONDARY LAW (THE PARENT-SUBSIDIARY DIRECTIVE AND THE MERGER DIRECTIVE; THE INTEREST AND ROYALTY DIRECTIVE, THE SAVINGS DIRECTIVE AND THE DIRECTIVE ON ADMINISTRATIVE COOPERATION IN THE FIELD OF TAXATION).
INTERNATIONAL TAX LAW: THE SOURCES; LIMITATIONS TO NATIONAL TAX SOVEREIGNTY AND THE CONNECTING FACTORS; INTERNATIONAL DOUBLE TAXATION AND METHODS FOR ELIMINATION OF IT; DOUBLE TAX TREATIES; THE OECD MODEL (THE PERSONAL AND MATERIAL SCOPE, THE NOTION OF PERMANENT ESTABLISHMENT, THE ALLOCATION RULES, THE MUTUAL AGREEMENT PROCEDURE AND EXCHANGE OF INFORMATION).
Teaching Methods
LECTURES, SEMINARS, DISCUSSION OF CASE STUDIES WORKSHOPS, DISCUSSION IN CLASS, INDIVIDUAL PROBLEM SOLVING, INTERACTION WITH THE LECTURER THROUGH EMAILS.
Verification of learning
THE EXAM PROVIDES A TEST AROUND THE HALF OF SEMESTER AND AN ORAL EXAMINATION; FOR STUDENTS NOT FOLLOWING THE LESSONS, ORAL EXAMINATION ONLY.
THE EVALUATION WILL BE FORMULATED BY CONSIDERING THE CORRECTNESS AND COMPLETENESS OF THE CONTENTS, AS WELL AS THE CRITICAL AND ARGUMENTATIVE SKILLS OF THE STUDENT.
Texts
CORDEIRO GUERRA, R., DIRITTO TRIBUTARIO INTERNAZIONALE, CEDAM, PADOVA, LAST.ED.
STUDENTS ARE INVITED TO READ THE MAIN TAX RULES IN FORCE.
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