5459 Introduction to the International Aspects of Italian Corporate Taxation
Prof. Gianluigi Bizioli
Contact details
  • Type
  • Weekly hours
  • Language of instruction
02/10/22 to 02/13/22
Registration via LPIS
Notes to the course
Subject(s) Master Programs
Day Date Time Room
Tuesday 03/15/22 09:00 AM - 03:00 PM EA.5.030
Wednesday 03/16/22 09:00 AM - 03:00 PM D2.0.030
Thursday 03/31/22 10:00 AM - 12:00 PM D1.1.074


Introduction to Italian International Tax Law will be discussed to enable the students a comprehensive education in tax law.
      A. Domestic rules on International income taxation
      1) Outline of the taxable income, and, in particular, of the different categories of income

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)

Learning outcomes

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.

Attendance requirements

> 70% attendance requirement

Teaching/learning method(s)

Frontal Lecture


discussion (5%), participation (5%), positive degrees on written exam (90%)


Further specific lecturing material will be provided by the institute 2 weeks before the lecture starts.The offered courses change each semester and are usually held by foreign guest professors.
Last edited: 2022-01-21