ID:
GDF032
Dettaglio:
SSD: Tax Law
Duration: 36
CFU: 6
Located in:
BERGAMO
Url:
LAW - 65GDF/PERCORSO COMUNE Year: 5
Year:
2025
The Course aims to provide advanced elements for the analysis of operations that present symptoms of abusiveness in a domestic, international and European dimension. Specifically, the concepts of abuse of law, legitimate tax savings and aggressive tax planning will be illustrated. The main objective is to understand the interaction between different regulatory sources and their mutual interaction.
Tax Law I and Tax Law II
Frontal Lectures
Mid-term written examination and oral examination
Abuse of tax law in the international dimension. The concept of beneficial ownership and principal purpose test. Treaty shopping. The prohibition of abuse of law in the case law of the European Union. The prohibition of abuse of tax law in the Parent-Subsidiary and Interest-Royalties Directives. The Directive for the fight against abusive practices (ATAD). Article 10-bis of the Taxpayer's Statute of Rights. The interposition of income in domestic law. The interrelation between the different normative sources and the effects.