Tax residence of companies: interaction between the new domestic rules and the international framework

Tanini, Emanuele (A.A. 2024/2025) Tax residence of companies: interaction between the new domestic rules and the international framework. Tesi di Laurea in International and European taxation, Luiss Guido Carli, relatore Andrea Silvestri, pp. 99. [Single Cycle Master's Degree Thesis]

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Abstract/Index

Tax residence of companies in Italy. Legal definition and traditional framework: article 73 of the TUIR (Testo unico delle imposte sui redditi). Relevant criteria. The new rules. Critical issues and compatibility with international law. Tax residence of companies in the international framework. Introductory remarks: notion of “residence” in international tax law and lack of harmonization in EU law. Tax residence of companies under OECD model convention and commentary. Comparative approaches to tax residence of companies. United Kingdom. United States. France.

References

Bibliografia: pp. 89-99.

Thesis Type: Single Cycle Master's Degree Thesis
Institution: Luiss Guido Carli
Degree Program: Single Cycle Master's Degree Programs > Single Cycle Master's Degree Program in Law (LMG-01)
Chair: International and European taxation
Thesis Supervisor: Silvestri, Andrea
Thesis Co-Supervisor: Rasi, Federico
Academic Year: 2024/2025
Session: Autumn
Deposited by: Alessandro Perfetti
Date Deposited: 14 May 2026 16:01
Last Modified: 14 May 2026 16:01
URI: https://tesi.luiss.it/id/eprint/45766

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