ECTS credits ECTS credits: 4.5
ECTS Hours Rules/Memories Student's work ECTS: 74.2 Hours of tutorials: 2.25 Expository Class: 18 Interactive Classroom: 18 Total: 112.45
Use languages Spanish, Galician
Type: Ordinary Degree Subject RD 1393/2007 - 822/2021
Departments: Applied Economics
Areas: Applied Economics
Center Faculty of Economics and Business Studies
Call: Second Semester
Teaching: With teaching
Enrolment: Enrollable
This elective course, offered in the second semester of the fourth year of the Bachelor's Degree in Business Administration and Management, aims to deepen students’ knowledge of tax planning from an international perspective, complementing prior training on the Spanish tax system.
The syllabus is structured around the fundamental principles and criteria of international taxation, with special emphasis on the issues arising from double taxation — both legal and economic — and the mechanisms established for its elimination. The course includes a detailed study of the Non-Resident Income Tax (IRNR), distinguishing between cases with and without a permanent establishment, as well as the formal obligations arising from cross-border transactions.
The subject also examines the main anti-avoidance measures incorporated into the Corporate Income Tax regulations, as well as the analysis of real tax liability in Inheritance and Gift Tax and Wealth Tax. A specific section is dedicated to the tax regime of collective investment institutions.
Finally, the course addresses the tax treatment of the most common corporate restructuring operations — mergers, spin-offs, asset contributions, share swaps, and changes of tax residence — from a practical and applied perspective.
The methodology combines theoretical analysis of legislation and international case law with the resolution of practical cases, aiming to develop key competencies for fiscal decision-making in globalized business environments.
1. Principles and Criteria of International Taxation
Fundamentals of international taxation. Tax liability criteria: residence and source. Tax coordination among states. Objectives of tax planning in global contexts.
2. Double Taxation: Treaties and Elimination Mechanisms
Concept and types of double taxation. Double Taxation Agreements (DTAs): structure, principles, and effects. Methods for eliminating double taxation.
3. Non-Resident Income Tax (IRNR)
Applicable regulations. Taxpayers. Taxation with or without a permanent establishment. Taxable income. Withholdings and formal obligations. Relationship with international rules and DTAs.
4. Real Tax Liability in Inheritance and Wealth Taxes
Concept. Situations of non-resident taxation. Analysis of formal and material obligations. Compatibility with international treaties.
5. Anti-Avoidance Measures in Corporate Income Tax Legislation
Specific rules. Limitations on the deductibility of expenses. Taxation under international tax transparency rules. Analysis of aggressive tax planning schemes.
6. Tax Regime of Collective Investment Institutions
Types of institutions: funds and companies. Taxation of institutions and investors. Incentives and special regimes. Analysis of their use in international structures.
7. International Tax Transparency and Foreign Securities Holding Companies (ETVEs)
International tax transparency regime: requirements, effects, and planning. The ETVE regime: purpose, tax advantages, and applicable regulations.
8. Taxation of Corporate Restructuring Operations
Mergers, spin-offs, non-monetary contributions of business units, share exchanges, and transfer of tax residence. Requirements for the application of the special tax regime. Practical implications and case analysis.
1. Agencia Tributaria (última edición). Manual de Tributación de no residentes. https://sede.agenciatributaria.gob.es/Sede/ayuda/manuales-videos-follet…
2. Albi, E. et al. (última edición). Sistema fiscal español, Ariel Economía.
3. Domínguez-Barrero, F. (última edición). Introducción a la planificación fiscal. Prensas de la Universidad. Universidad de Zaragoza.
4. Domínguez-Barrero, F. (última edición). Planificación fiscal en la empresa. Prensas de la Universidad, Universidad de Zaragoza.
5. Lledó Yagüe, M. C. (última edición). Planificación fiscal y elusión tributaria. Tirant lo Blanch.
Updated Legal Regulations and Official Sources:
Law 27/2014, of November 27, on Corporate Income Tax.
Royal Legislative Decree 5/2004, of March 5, approving the consolidated text of the Non-Resident Income Tax Law.
Double Taxation Agreements signed by Spain.
European Union tax directives.
OECD documents and reports, especially those within the framework of the BEPS Plan.
Basic Competencies
CB2. Students should be able to apply the knowledge acquired to their work or vocation in a professional manner, and possess the necessary competencies typically demonstrated through the development and defense of arguments, as well as the resolution of problems within their field of study.
CB3. Students should have the ability to collect and interpret relevant data, usually within their field of study, in order to make judgments that include a critical reflection on social, scientific, or ethical issues.
CB4. Students should be capable of communicating information, ideas, problems, and solutions to both specialized and non-specialized audiences, using language appropriate to each context.
CB5. Students should develop the learning skills necessary to undertake further studies with a high degree of autonomy.
General Competencies
CG3. Ability to identify, collect, and interpret relevant data related to the business environment, incorporating social, scientific, or ethical considerations into the formulation of judgments and proposals.
CG4. Ability to communicate information, ideas, problems, and solution proposals in the business environment, addressing both specialized and non-specialized audiences, using appropriate oral and written language as well as discipline-specific data representation and presentation tools.
Transversal Competencies
CT1. Capacity for analysis and synthesis, applied to understanding and addressing complex situations in academic or professional settings.
CT4. Skill in effectively searching for, selecting, managing, and using relevant information from various sources.
CT6. Ability to identify, formulate, and solve problems effectively, using appropriate methodologies and tools.
CT9. Development of autonomy in learning, taking responsibility for one's own educational process and being able to self-organize study and knowledge acquisition.
CT10. Ability to integrate and collaborate effectively in work teams, actively contributing to the achievement of common goals.
CT13. Commitment to personal and professional ethics, acting with social responsibility and integrity in academic and work activities.
Specific Competencies
A3: Understand the national and international economic reality, productive sectors, the public sector, economic institutions, and their evolution over time.
B7: Know and apply management support systems, including their planning, analysis, design, and implementation functions.
D4: Produce advisory reports on specific company and market situations, providing accurate and relevant recommendations.
D8: Derive relevant information from complex data that would be impossible for non-professionals to interpret, facilitating understanding and decision-making.
Lecture-Based Teaching
To develop the course program, a combination of lecture-based teaching is used, aimed at delivering a complete, systematic, and orderly presentation of the topics and sections described previously, along with interactive classes that require active student participation and engagement.
Interactive Teaching
Following the theoretical lectures, various exercises will be proposed, some of which will be carried out using computer-based tools.
Students must be able to use the virtual classroom platform and Microsoft Teams, through which materials, assessments, and other resources will be shared. For this purpose, the use of RAI and access to computer equipment (www.rai.usc.es/) are required.
Considering the teaching methodology described in the previous section, the evaluation combines the student's interactive and lecture-based activities. Part of the assessment is based on the results achieved in continuous assessment tests, assignments, discussions, and class participation, as well as the final exam.
The relative weight of continuous assessment will be 40%, while the final exam will account for 60% of the final grade. In any case, in order to pass the course, students must complete a significant portion of the continuous assessment as well as the final exam.
Students officially exempt from class attendance will take a final exam covering the course content. This exam will represent 100% of the final grade. In any case, five days prior to the official exam date, they must send an email to the course instructor providing their personal information and stating their exemption status.
ON-SITE CLASSROOM WORK
Lectures: 18h
Interactive classes: 18h
Small group or individual tutorials: 9h
Total on-site classroom work hours: 45h
STUDENT'S INDIVIDUAL WORK
Individual or group self-study: 50h
Writing exercises, conclusions, or other assignments: 7.5h
Programming/experimentation or other computer/laboratory work: 5h
Recommended readings, library activities or similar: 5h
Total student individual work hours: 67.5h
It is recommended that students become familiar with handling legal documentation and tax legislation. They should learn to navigate the tax laws analyzed in this course and understand their provisions and application in the business context.
It should be noted that in cases of fraudulent completion of exercises or exams, the provisions set out in the Regulations will apply.
For the assessment of academic performance of students with an exemption status, an email must be sent to the course instructor indicating their personal details and the reason for the exemption.
Maria Cadaval Sampedro
Coordinador/a- Department
- Applied Economics
- Area
- Applied Economics
- Phone
- 881811664
- maria.cadaval [at] usc.es
- Category
- Professor: Temporary PhD professor
Jaime Gaya Moreno
- Department
- Applied Economics
- Area
- Applied Economics
- jaime.gaya [at] usc.es
- Category
- Professor: LOSU (Organic Law Of University System) Associate University Professor
| Tuesday | |||
|---|---|---|---|
| 18:00-19:00 | Grupo /CLE_01 | Galician | Classroom 20 |
| Thursday | |||
| 15:00-17:00 | Grupo /CLE_01 | Galician | Classroom 20 |
| 05.26.2026 16:00-19:00 | Grupo /CLIS_01 | Classroom 08 |
| 05.26.2026 16:00-19:00 | Grupo /CLE_01 | Classroom 08 |
| 07.03.2026 16:00-19:00 | Grupo /CLIS_01 | Classroom 21 |
| 07.03.2026 16:00-19:00 | Grupo /CLE_01 | Classroom 21 |