Syllabus
Registration via LPIS
2) The notion of tax Residence for:
a. Individuals
b. Companies and other entities
3) Income sourced in Italy and, in particular,
a. Work exercised in Italy;
b. Activities exercised in Italy;
c. Permanent establishment
4) Rules on the determination of taxable income for non-resident companies and other entities
5) Rules for the avoidance of international double taxation
B. Specific International tax rules
a. Transfer-pricing;
b. Controlled foreign companies rule;
c. Exit and entry taxation
d. Branch exemption
C. International and domestic income tax law
1) The prevalence of International tax law
2) Outline of the Italian tax treaty network
3) The Italian approach to International tax avoidance
D. EU and domestic income tax law
1) The prevalence of EU tax law over domestic and International tax law
2) Outline of the impact of the fundamental freedoms
3) Outline of the impact of the Directives on direct taxation (Parent-Subsidiary Directive, Interest and Royalties Directive, ATAD 1 and 2)
After this course, students will be able to:
- Analyze EU and International tax law questions related to the Italian tax regime;
- Evaluate, comprehensively, and solve cases, concerning European and international tax law, in the context of the Italian legal system;
- Describe the cornerstones of the Italian tax regime, with regard to its European and international profiles;
- Compare foreign tax law systems with the Italian tax regime, in order to gain a broader perspective thereon.
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