Keynote presentation at the opening of the 2018 edition of the Summer School in International Taxation, University of Dubrovnik, Croatia. The event was co-organized with the support of the University of Zagreb. In the presentation the aftermath of the naval battle of Vis (1866) has been used to explain to the students the challenges of tax law.

1. Current Trends in
International Tax Law
Introduction to the Course

2. The Importance of International Taxation

3. The Wreck, as It was Found

4. Why International Taxation ?
• Theoretical Aspects:
• Does International Taxation exist ?
• Income taxation;
• VAT;
• Customs Duties;
• State aids;
• Compliance and Disclosure duties …
• Find ways and means to facilitate cross border investment;
• Practical aspects:
• The Croatia – Italy case.

5. Croatia – Italy Cross Border Business
(According to Infocamere.it)
• In 2017 business interchange
for more than 4,7 Billion Euro;
• Italy first market for Croatian
Businesses (more than 1,9
Billion Euro);
• Annualincrease of 13%
• Italy third largest investor in
Croatia after Austria and the
Netherlands;
• Conduitcompanies are not
considered anyway;
• Here is where taxationcomes
in …

6. A Focus on the Financial
Sector
• Bank of Zagreb operated by
Unicredit at 84,47%of the
stock capital (as in 2017);
• Provredna Bank Zagreb
operated by San Paolo Intesa
at 97,47%of the stock
capital (as in 2017);
• More than 43% of the
Croatian Bank market is in
connection with Italy.

7. The Strategy of the Summer School (as I see it)
• “Top Down” and “Bottom Up” approaches:
1. Understand the Importance of Taxation on cross border transactions and
investments;
2. Have a clear picture of the “State of the art” of International Taxation
(beyond the Sea, beyond the Ocean);
3. Understand what is happening in Croatia and in the nearby Countries,
tracking the most recent changes;
• Are these consistent with what is occurring elsewhere ?
• How is it possible to increase the competitiveness of the Country and the Business
opportunities ?

8. International Taxation, as We see it in Dubrovnik
• Mixing Classes and Workshops;
• Theory and Practice;
• Mixing Professors and Teachers;
• From Croatia and from other EU and non-EU Countries
• Mixing International with European law;
• Tax Treaties and European Directives;
• Mixing Hard Law and Soft Law;
• Domestic provisions and supra-national policy guidelines.

9. A General Overview of the Seminars
• Global Economy, Taxation and Entrepreneurs;
• Opportunities and Challenges for Regional Multinational in Business
Taxation and Business Position and Responses;
• Current trends in International Taxation;
• Consolidated Financial Reports, CBC Reporting, CCCTB;
• State Aid, Tax Incentives: Discrimination and Judicial Constitutional
Review;
• EU and State Aid in Taxation, cases;
• Continued …

10. A General Overview, continued …
• Licensed Tax Advisers, the Chambers and the Relation to Taxpayers
and Tax Administrations;
• Big Businesses and Big Advisers;
• Possible developments in Tax Arena – General Issues;
• … in Croatia and beyond.

11. Time to Draw Conclusions: International
• Base Erosion and Profit Shifting;
• Re-alignment of International
taxation;
• Preservation of the Country’s
power to tax;
• Reshaping international taxation
via multi-lateral instruments;
• Addressing aggressive tax planning
and international tax evasion;
• Data- and Information- driven
project.

12. In the European
Union: now …
• Anti tax avoidanceDirective 2016/1164
(ATAD-1) from January1st 2019;
• Anti tax avoidanceDirective 2017/952
(ATAD-2) for hybrid mismatches;
• Exchange of Information (latest
developmentwith Directive 2018/822);
• ….

13. In the European
Union: in the future …
• Digitaltaxationand digitalpresence of
MNEs;
• Changes to VAT implementation
consistentlywith Directive proposals:
• COM(2017)569;
• COM(2018)021 (SMEs);
• COM(2018)020 Rates adjustment;
• COM(2017)706 Anti-fraud.
• Towardsa definitiveregime ?

14. Have a Nice Summer School !
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