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.

Teaching goals are the understanding and learning of the principles of International Tax Law and of the internal provisions related to transnational operations and economic relationships and of the principles set for the main extraordinary corporate transactions as part of the consultancy activity addressed to individuals and companies, of the companies’ fulfillment and best management choices.

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;

4. Communication skills
- ability to express notions in a clear way and with a proper language.
5. Learning skills
- ability to internalize, rework and apply notions faced during lessons and individual study sessions.

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, latest edition: 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 26 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.

Procedures for online examinations (only in cases provided for by the University):
The written test will be carried out on the Moodle platform with Safe Exam Browser (SEB) and will consist of 11 multiple choice questions.
The assessment will be as follows: -1 point for the first and second wrong or blank answer, - 2 points for each wrong or blank answer to follow.
Duration: 18 minutes.
Students who get a mark of 26 or higher in the written test will have to take an additional oral test on the Google Meet/Zoom platform.

written and oral

The written test without any mistake allows the candidate to obtain a maximum score of 28.
Passing the written test without any mistake will result in an additional oral test if the candidate wants to
gain a higher score.
Scores in the 28-30L range will be assigned in the presence of:
- very good knowledge and ability to apply understanding in reference to the course program;
- very good ability to apply knowledge by formulating independent judgments;
- very good ability to understand the text of the open question and to answer thoroughly and briefly;
- very good communication skills, especially in relation to the use of specific language that pertains to
the course program.
Honors will be awarded in the presence of: excellent knowledge and applied understanding regarding the
exam program, excellent judgment and communication.
Scores in the 26-27 range will be assigned in the presence of:
- good knowledge and ability to apply understanding in reference to the course program;
- good ability to apply knowledge by formulating independent judgments;
- good ability to understand the text of the open question and to answer thoroughly and briefly;
- good communication skills, especially in relation to the use of specific language that pertains to the
course program.
Scores in the 24-25 range will be assigned in the presence of:
- fair knowledge and ability to apply understanding in reference to the course program;
- fair ability to apply knowledge by formulating independent judgments;
- fair ability to understand the text of the open question and to answer thoroughly and briefly.
Scores in the 18-23 range will be assigned in the presence of:
- sufficient/limited knowledge and ability to apply understanding in reference to the course program;
- sufficient/limited ability to apply knowledge by formulating independent judgments;
- sufficient/limited ability to understand the text of the open question and to answer thoroughly and
briefly.

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.