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, Lezioni sull'IRES delle società di capitali residenti, Cacucci Editore, Bari, 2020: Chapter V, "Le operazioni straordinarie".

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

The exam consists of a written test and an optional oral examination.
The written test will be held in person and will be divided into 10 multiple choice questions and an open question to reach a final grade of 28/30.
Marking criteria:
- for multiple choice questions: starting from 26, -1 point for the first and second wrong or blank answer, followed by - 2 points for each wrong or blank answer;
- the open question is evaluated from +2 to -2 points.
Students who obtain a grade equal to or greater than 27 in the written test will be able to take a supplementary oral test in person.
The use of tax codes, books, notes and electronic media is not allowed during the test.

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.

written and oral