Theme of the present course

The 2010-2011 Subject
This year the main theme is "The limits to Tax Planning, Minimizing Taxes and Corporate Social Responsibility'. ".  As every year the main theme is divided into 6 subparts for the different students to explore and write their theses on.
The main objective of the wintercourse is to explore different aspects of one major theme. Not only different subparts are important, but the added value of this project is the cooperation between the different universities in different countries. Students from each university will research on the same subparts, just from their national point of view.
During the seminar, which will be held in Rome from 6 to 15 April 2011, the students and researchers will discuss these differences. Why do these differences exist and what problems may arise because of those differences are just two aspects that will be dealt with. The various discussion groups will try to come up with solutions for the various problems arisen by those differences.

The subparts defined for this year's Eucotax-wintercourse are:

1. General anti-avoidance rules and doctrines
E.g., sham transactions, abuse of law, abuse de droit, fraus legis, substance over form;
2. Anti-base erosion rules
E.g., earnings stripping rules, limitation of interest deductions and exit taxes (personal income tax and corporate income tax);
3. Treaty shopping
E.g., limitation on benefits, beneficial owner, rent a star company, real estate company;
4. Anti-deferral rules
E.g., CFC/subpart-F rules, switch-over clauses;
5. Implementation of EC Directives’ anti-avoidance rules
a. Parent-Subsidiary Directive b. Merger Directive c. Interest & Royalty Directive d. Interest on Savings Directive * ;
6. Disclosure rules
E.g., disclosure of tax risks (including, ethical issues, disclosure of tax claims in financial accounts, disclosure of aggressive tax planning structures to the tax administration), money laundering, burden of proof, patented tax planning structures.