000111R - INTERNATIONAL TAX LAW

1) TAXATION OF NON-RESIDENTS AND THE CONVENTIONS AGAINST THEMDOUBLE TAXATION- The sources.- The differences in tax forms between residents and non-residents.- The place of production of the income and the residence of the natural persons eof companies.- The determination of the taxable income of commercial entities and companiesnon-residents and the notion of permanent establishment.- Methods of elimination of double taxation.- Conventions against double taxation.2) MULTINATIONAL COMPANIES AND INCOME FLOWSINTRACOMPANY.- Multinational companies. Joint ventures and groups of companies.- Groups of companies in the Italian legal system.- Taxation of intragroup dividends.- Consolidated taxation of groups of companies in Italy.- The regime of foreign dividends (European and non-EU) in the legal systemnational.- The problem of legal double taxation. Tax credit edexemption.- The taxation of dividends in the OECD Model (art. 10) and the notion of“beneficial owner”.- The Directive (n. 90/435/EC).- The taxation of interests and royalties in the legal systemcommunity and in the OECD Model.3) VALUE ADDED TAX. TRANSNATIONAL PROFILES.- The sources.- Intra-community VAT. Taxation in the country of origin or destination.- VAT, consumption taxation and customs duties.- VAT transfers on exports and imports.- Electronic commerce.- Tax controls and information exchange.4) INTERNATIONAL TAX PLANNING- Tax evasion, avoidance and legitimate savings.- Intragroup evasive techniques.- Transfer pricing. The different methods of determining the price oftransfer. The elimination of double taxation in the event of rectificationof transfer prices.- Thin capitalization.- The regulations on Controlled Foreign Companies.- Interposition and trust.