Course Content (Syllabus)
In the Tax-Fiscal Law II course, issues of International Tax Law are examined. In particular, the relations of domestic tax law with international conventional tax law, Double Taxation Avoidance Conventions, as well as recent actions at the international level to combat tax evasion and avoidance are examined. In particular, in the context of the Double Taxation Avoidance Agreements, the scope of bilateral agreements, the concepts of tax resident and permanent establishment, the methods of eliminating double taxation, as well as the procedures of mutual settlement and administrative assistance are mainly examined. In the context of the actions to combat tax evasion and tax avoidance, the OECD Plan to address the erosion of the tax base and the transfer of profits abroad ("BEPS project"), as well as its individual fifteen (15) actions concerning the digital economy, hybrid mismatches, controlled foreign companies, deductibility of expenses, harmful tax practices, abuse of Double Taxation Agreements, permanent establishment status, intra-party transactions, data analysis for tax base erosion and of profit shifting abroad, the documentation of intra-party transactions, dispute resolution and the multilateral tool for implementing measures to address base erosion and profit shifting. Finally, the relationship between international tax law and EU tax law is examined, and in particular the relationship between the individual actions of the OECD project ("BEPS project") and the EU actions to deal with tax avoidance and aggressive tax planning, such as mainly the Directive on combating tax avoidance (ATAD I and II), the anti-abuse provisions of the Directives in the field of direct taxation