Università degli Studi di Napoli "Parthenope"

Teaching schedule

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First Semester
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Course description

The objective of this course is to familiarize students with the principles and underlying policies of the Italian tax system concerning tax income, for national and international companies. The course focuses on double taxation problems and their solution.


Formally none; basic knowledge in tax law facilitate the understanding of the topics


The taxation of income of the company operating at national and international level. The internal and international regulations that operate in this field to avoid double taxation.
Tax residence. The distinction between residents and non-residents. The Italian taxation of non-residents and the taxation of residents for income produced abroad. The role of international conventions as instruments for avoiding international double taxation and ensuring the exchange of information between the tax administrations of the various countries.
Branches and foreign subsidiaries and their tax operations

This course examines how income taxation applies to national and multinational companies, and considers tax law that operates at national and international levels. In the first part of the course will be introducted some key foundation concepts that are needed in the study of international double taxation: the tax definition of resident; the distinction between domestic and foreign persons or entities; the role of tax treaties and, in particular, of bilateral income tax conventions between countries to alleviate double taxation of income from international investments and activities and to provide for exchanges of tax information and consultation between tax authorities.
The focus is on rules that operate at an international or supra-national level, though we will look at some domestic rules that are important to international taxation and that can be found in a number of important tax systems. The course will look at a series of international transactions, starting with the very basic example of an export and import of goods and culminating with the treatment of some complex or artificial structures (Branch, Subsidiaries and Controlled Foreign Companies).

Teaching Methods

Lectures, tutorials and discussions of case law


FALSITTA, Manuale di diritto tributario, Parte speciale, Cedam 2016 capp. 2, 3, 4, 5, 6 e 12.
TOSI – BAGGIO, Lineamenti di diritto tributario internazionale, Cedam, 2016

Learning assessment

Oral examination

More information

Knowledge and ability to understand: the student must demonstrate how to assess the tax issues related to the exercise of business, both nationally and in multinational level

Ability to apply knowledge and understanding: the student must demonstrate that he understands the methods and limits of the tax planning allowed by our tax system

Making judgments: the student must demonstrate that he has developed an autonomous critical capacity to evaluate the problems and solutions adopted at the level of national and international corporate taxation

Communication skills: the student must be able to respond clearly to the oral test questions, thus demonstrating the ability to move within a system of opportunities and particularly complex regulatory sources

Learning skills: the student must demonstrate that he has developed a learning ability that allows him to be able to face the problems of tax planning, also from a professional point of view.