Learning outcomes of the curricular unit
Via court decisions, have the necessary knowledge of the tax planning limits; linedrawing beetween licit and ilicit tax planning; Understand the main legal tools to avoid abusive tax planning
Syllabus
The law and limits of the tax planning; When starts the tax crime; tax inaction; the legal option rights; general clauses and indetermination concepts; the use of the tax and structural benefits; the holding tax regime; the merger tax neutral regime; specific anti abuse clauses (by time, partial limitation of benefits, normal prices); the transfer price regime; general anti-avoidance clause.