International tax policy

• Comparative Corporate Tax Polices
  The course is aimed at those students who, having taken domestic and international tax courses, are interested in understanding how tax systems compete and evolve: the course provides an introduction to the comparative dimensions of tax law and endeavors to bridge the gap between domestic and international taxation. We will focus mainly on selected issues of corporate taxes having an international impact and use a comparative approach to analyze the evolution and circulation of tax models. In this approach, tax reforms are viewed as the result of the selection through legal transplants and similar techniques, by domestic policy-makers, of alternative solutions circulating in the market for tax ideas. We will also consider certain “top-down constraints” in the EU process of tax coordination, with specific attention to the “negative integration” prompted by the leading cases of the European Court of Justice in tax matters protecting the four freedoms enshrined in the EC Treaty. We will study the arguments and the reasoning adopted by the ECJ in these cases and their impact on domestic legislation and tax policy. Finally, we will combine the comparative/evolutionary approach and the case method to depict an evolutionary map for EU corporate taxes which reveals a “common core” in respect to cross-border tax consolidation of groups of companies; within this framework we will consider the EU proposal for a common consolidated tax base (CCCTB) and the US proposals for adopting formulary apportionment.
• Comparative Tax Systems
  The course provides students with a comparative overview of the tax systems of various countries, with a view to developing a conceptual and practical understanding of the reasons why tax systems differ (and why they are sometimes so similar). The objectives of the course are to help students understand the characteristics that tax systems have in common, the areas in which tax systems differ, and the factors (legal, institutional, political, economic, social, and cultural) that cause the similarities and differences. The course covers areas such as tax structures, tax at different government levels, different types of tax (including income taxes, consumption taxes, capital and wealth taxes, and environmental taxes), tax operating costs, tax administration, and tax policymaking and reform.
• Justice, Equality and Tax Law
  The goal of the course is to outline the main approaches to improve justice both in the domestic and the international tax regime. This includes a broad discussion about the interaction between taxation and redistribution. The latter is of particular importance as the level of inequalities varies significantly around the word and it is questionable whether the international tax regime should and can lead to a more balanced system. The course also discusses the interaction between justice as a normative goal and the international law regime as a partly value based legal system. During the lecture reference is also made to some of the latest global policy projects with a particular focus on how justice considerations have influenced these projects.
• Tax and Technology
  Domestic and international taxation is rapidly evolving in light of technological advancements (e.g., blockchain, machine learning) and new business models (e.g., digital platforms). Also, international cooperation, digitalization, and shifts in geopolitical weights are challenging the traditional norms of taxation as never before. Not only the boundaries and norms of substantive taxation are under scrutiny, but new technologies also create opportunities and challenges to transform the traditional ways of interaction between states and taxpayers and between tax administrations. This course will serve as a guide through these developments and will highlight core developments in substantive and procedural tax law.
• Trends in EU Tax Law
  The ECJ's direct tax case law based on the EU fundamental freedoms seems to have evolved over the last thirty years. Fairly simple, though general, EU Treaty provisions – as interpreted by the ECJ in direct tax cases - have led to substantial changes in the direct tax laws of EU Member States. For the last few years, the jurisprudence of the Court attempts to explore the boundaries of the impact of the EU Treaty on the domestic tax legislation of Member States. The course entails an analysis of the recent trends in the ECJ's case law in this area. It will endeavor to analyze the ECJ's understanding of the basic concepts on which the EU direct tax case law is based and its application in the current jurisprudence.