|About the Book|
This book is primarily written to be used as a teaching text for any course of corporate international tax law at the university level. It has arisen from more than a decade of professional practice and academic activity carried on at the BocconiMoreThis book is primarily written to be used as a teaching text for any course of corporate international tax law at the university level. It has arisen from more than a decade of professional practice and academic activity carried on at the Bocconi University (Milan) in the area of international tax law and it is addressed to diverse audiences, ranging from undergraduates with no practical experience, students of master courses, as well as postgraduates with little training.This book intends to disregard the background and the geographical location of its readers and thus covers both generic principles and specific topics of international taxation relating to corporate investments. In this sense, it does not look at any specific law, practice, experience or political economy of a given country, but rather aims at providing an overall understanding of the main concepts and framework underlying international tax law and double tax treaties based to the OECD Model.Even if taxation is narrowly linked to the territorial borders of any jurisdiction, international tax law has become a global phenomenon. States and international organisations share and establish common principles and models of rules, which are subsequently implemented by countries at their domestic level, considering the specific political features of their territory.This is why this book wants to have an international audience without focusing on any specific jurisdiction. The concepts developed in this book are therefore applicable to the corporate international tax systems of developed and developing countries. Its main goal is therefore to teach a methodology to be applied by students and tax practitioners when approaching any international corporate tax issue, which requires an analysis of the specific case and the identification of the correct applicable domestic and international tax rules in order to find the best solution.To that purpose, different practical examples are provided, so that the reader can easily translate into practice the theory of corporate taxation explained in its chapters. The reader is therefore encouraged to apply the theory to factual situations.The structure of this book consists of providing a narrative explanation of the main concepts of international tax law, the provisions of double tax treaties drafted according to the OECD Model and relating to corporate income, and the main issues and instruments currently adopted to curb international corporate tax evasion and abuse.In order to facilitate the reading and in order to stress the teaching and the learning nature of this book, footnotes have been reduced to the minimum. However, it still keeps its academic nature, as it is not aimed at being a manual for practitioners only.This book can be perceived as needed in the area of international tax law, because this academic discipline has always been conceived as a specific part of domestic tax law of each country. As mentioned above, current global economy has blurred the territorial borders of taxation in their traditional sense and domestic governments are establishing and sharing common rules and practices, which are valid to any State.