ADVANCED TAX LAW B – INTERNATIONAL TAXATION AND EXTRAORDINARY OPERATIONS

The teaching falls within the characterizing teaching of the Master's Degree in Administration, Finance and Control, which aims to train experts in administrative management, design of management control systems, formulation of competitive and financial strategies, control of business risks, as well as people addressed to the free professions. Targets of the course are the understanding and learning of the principles of International Taxation Law and of the Taxation Law internal regulations disciplining transnational operations and economic relationships and the main extraordinary transactions, given to deal with fiscal consultancy, with fulfillments of the companies and with the decisions making on the convenience of the operations related to the management of them.

1. Knowledge and understanding
know the rules relating to international taxation
to know the fiscal provisions concerning extraordinary operations
2 Ability to apply knowledge and understanding
know how to solve problems of interpretation of the provisions that regulate international taxation
know how to apply the rules to specific cases concerning the taxation of extraordinary operations
3. Ability to judge
to be able to critically assess the ratio and function of the regulatory provisions
be able to identify the most correct and efficient choices regarding the taxation of trans-national income and extraordinary operations

Basic Commercial Law.
Taxation Law.

1. General aspects of International Taxation Law: terms, International Taxation Law sources, concept of International Double Taxation, Tax Treaties.

2. Basic principles of EU Taxation Law.

3. Income taxation: fiscal Residence and World-wide Income taxation Principle, Foreign Tax Credit, non-resident taxation, notion of Permanent Establishment.

4. The enterprise extraordinary operations with a focus on the taxation of the operations of conversion, merger, split and conferment.

For the international tax law part.
TOSI, BAGGIO, Lineamenti di diritto tributario internazionale, Padova, Cedam, latest edition.

For the enterprise extraordinary operations part:
FALSITTA, Corso Istituzionale di Diritto tributario, Padova, Cedam, last available edition:chapter XXV, sez. II, "Le operazioni straordinarie"
A. VIOTTO (a cura di), La tassazione del reddito delle società di capitali, Giappichelli, Torino, latest edition: chapter IV,"Le operazioni straordinarie".

Papers of the lesson, prepared by the teacher, on various topics.

The exam consists in a written text with 9 multiple choice and 2 open questions.
To pass the first open question is a necessary, but not sufficient, condition to pass the exam.
The exam evaluation will be the following:
- multiple choice: starting with 26/30, -2 points for each wrong or blank answer;
- open question: a score from -2 to +2.
During the written exam it is not allowed to use books, tax codes, notes or electronic media.

The teaching will consist in lessons and seminars.

Accessibility, Disability and Inclusion

Accommodation and support services for students with disabilities and students with specific learning impairments

Ca’ Foscari abides by Italian Law (Law 17/1999; Law 170/2010) regarding support
services and accommodation available to students with disabilities. This includes students with
mobility, visual, hearing and other disabilities (Law 17/1999), and specific learning impairments (Law 170/2010). If you have a disability or impairment that requires accommodations (i.e., alternate testing, readers, note takers or interpreters) please contact the Disability and Accessibility Offices in Student Services: disabilita@unive.it.

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