This course aims at providing the students the key concepts and structures that are needed to understand direct taxation from a cross-border perspective.  

It is focused on the needs of the next generation lawyer, which must take into account the tax variable in any corporate decision. Accordingly, this course will focus on: i) identifying the jurisdictions that may have a valid tax claim in any cross-border transactions; ii) determine to which extent double or multiple taxation arises; iii) understand the normative regimes that allow for the allocation and relief of double taxation. 

The broad understanding of the modus operandi of direct taxes at the cross-border level will allow the student to identify the main areas of risk and to plan to allow an optimisation of the tax outcome of any business entity, structure or transaction. 

The course will start with an overview of the main issues that multinationals face, from a direct tax perspective, when operating at a cross-border level. The course will continue with an introduction to the OECD Model Tax Convention on Income and Capital, so as to provide students with enough practical tools to tackle juridical double taxation issues arising in their day-to-day activities.