Student guide Faculty of Law A.Y. 2010/11

Tax Law (Advanced Course)
Aim of the course
The course is designed to provide students, within a framework of essential concepts relating to constitutional principles, with basic information about the substantial and procedural law governing the main taxes charged on business activities: income tax and value added tax.
The part devoted to the substantial aspects will mainly focus on company incomes, with examination of the general and special rules governing their determination.
In the part devoted to procedural aspects, examination of the role and contents of the numerous acts (returns, assessment notices and collection) included in the implementing stage of taxation and the investigative powers held by the Inland Revenue will be followed by study of tax proceedings.
The approach to the subjects covered is designed to develop students' ability to identify and analyse issues, partly through discussion of cases drawn from the case law and Ministry circulars.
1.   Taxation of groups and extraordinary operations.
    1.1 National consolidation and taxation of notional income.
    1.2 Conversions.
    1.3 Sale of companies and of controlling shareholdings.
    1.4 Share exchanges.
    1.5 Mergers.
    1.6 Demergers.
2.   International and EU tax law.
    2.1 Double taxation and measures designed to prevent it (national law and conventions).
    2.2 Residence.
    2.3 Taxation of non-residents: business income, dividends, interest and royalties.
    2.4 The transfer price.
    2.5 Tax havens and legislation aimed at counteracting them.
    2.6 EU taxation principles.
 3.   Tax planning and tax avoidance.
    3.1 National and international tax planning.
    3.2 Tax avoidance and s. 37-bis of Presidential Decree no. 600/1973.
An oral exam will be held at the end of the course.
Reading list
For students who attend lectures, the reading list will be supplied at the beginning of the course.
For students who do not attend lectures, the reading list must be agreed with the lecturers.