GLOBAL CORPORATE TAXATION

Chapter I Participation exemption on dividends
Chapter II Participation exemption of capital gains from share disposals
Chapter III Deductibility of corporate interest expenses
Chapter IV Domestic tax consolidation
Chapter V The CFC legislation
Chapter VI Transfer pricing

What is “global law”? what is “global taxation”? The book addresses these questions by focusing on “global corporate taxation” as an exemplary illustration. Corporate tax policies compete and evolve different solutions adopted by individual countries form clusters that map the distribution of these solutions. The relationship between global tax models and local tax solutions is bidirectional: tax models are implemented by countries through legal transplants in the form of specific tax solutions; tax solutions are exported and transplanted elsewhere and affect the structure and the spread of tax models. There is a complex relationship between the global and the local level that results in unique outcomes in different countries through a selective process. The influence of corporate tax models is altered by local tax systems and re- activated into the global level in a constant cycle. Thus, the circulation of corporate tax models is the main topic of global corporate taxation and of this book which analyses a basic set of corporate tax policies. Each chapter first discusses the circulation of policy models and then focuses on the application of the models within a specific national corporate tax system.

Carlo Garbarino is Full Professor and Director of the LLM Global tax law and governance at Bocconi University, Milan where he is member of the Executive Committee of the Department of Legal Studies, member of the Faculty Board of the PhD in Legal Studies and Fellow, Green Centre for Research on Geography, Resources, Environment, Energy & Networks. PhD in international and comparative law and LLM University of Michigan Law School. Visiting Scholar at Yale University, Senior Emily Noel Fellow at NYU, Grotius Research Scholar at the University of Michigan. He has held positions as Visiting Professor at Sorbonne- Paris, University of Michigan Law School, NYU Law School and San Paulo.