Presentation

This Module aims to introduce and analyze “Personal Income Tax in the European Union (henceforth PIT in the EU)”. It should be mentioned that PIT structure is not unified across the Europe. The tax structures adopted by different countries are significantly different, in terms of tax rates, allowances, and exemptions and so on (see e.g., Ernest and Young's “Worldwide Personal Tax and Immigration Guide 2018-19”). Therefore, while Module covers general principle of taxation in the EU, including non-discrimination and escaping double taxation, recognizes existing differences among individual member countries of the EU

The framework of this Module is a Summer School which will be held at the Allameh Tabataba'i University, as a leading academic centre in Social and Human Science in Iran. Members of the team are academicians and practitioners who are expert in tax law and economics of taxation with valuable experiences in teaching and analysing tax systems both from universities located in Iran and some country members of the EU.

The audience of this module are students and practitioners with special interest in International Tax Law, Economics of Taxation and Public Policy, both from Iran and its neighbour countries including Afghanistan, Tajikistan, Kazakhstan and Iraq. We will invite junior researchers who are going to advance their academic careers, tax practitioners who are involved in income tax reform in their countries, and researchers who are going to understand EU angle into PIT and derive its implication for their countries, as well together with possible other stakeholders.

Delivering this Module is essential for several reasons. Firstly, because EU country members by and large run a relatively well functioning PIT system, in terms of both generating income for government and more outstandingly, redistributing income from riches to poor, to include more people in economic and social life and lets government to adopt first best policies in other economic arena. Of course, the caveat should be taken into account that income tax is not perfect across the EU countries and some observers do believe that some reforms are required to improve income distribution.  

Secondly, at the host institution and other academic institutions across the country, there is no teaching or research activity with special focus on the EU tax system and the way its country members design and implement PIT and employ it as an effective instrument to raise tax revenue and decrease inequality. Through running this Module for three years, we expect that our audiences define new courses such as “International Tax Law : EU perspective” or reconsider the syllabus of their existing courses such as “Public Finance”, or “Tax Law”.

Thirdly, while graduate students and researchers have a good knowledge of the legal and economic theory of the tax, to promote their research program or academic careers they are in great need to understand income tax in practice and recognize key points in analysing, designing and implementing an income tax system. For the being time, under the influence of seminal textbooks translated into Persian, most of the evidence is solely considering US and UK tax system and ignores other experiences including EU.  

Fourthly, understanding the structure and performance of PIT in the EU is vital for Iran, also for its neighbour countries : As a matter of fact, the shortcomings of their PIT structures are well recognized and the policy makers and academicians are discussing to promote a fundamental reform in the next few years. General principles are in effect in EU countries, the methods they define taxpayers and taxable income, and the ways they deal with tax compliance issues, among others, are of too much of importance to promote effective PIT reforms.

This Module aims to achieve 3 alternative objectives :

Objective 1. Fosters the introduction of a European Union angle into mainly non EU related studies. Iran's income tax system is a scheduler one which levy taxes at the source and treat different sources of income with different structures in terms of tax base, tax rates and unit of taxation. Some types of income are benefited from overall exemption, while the others are taxed progressively and the others proportionately. Taxpayers differences in terms of household dimensions and necessary expenditures are not taken into account when defining tax base and levy taxes. Thus, Iran's PIT system is suffering from vital shortcomings and does not play its proper role in terms of redistributing income in society and generating tax revenue for government.
At the host country, therefore, reforming the PIT system is of high priority. To promote PIT reforms, understanding alternative designs and their performance are essential for both academicians and practitioners who are supposed to be the audiences of this Module.
To hit this objective, we identify unifying principles of PIT in EU as a whole and discuss it with our audiences and compare them with effective principles in the host country. Furthermore, details of PIT in the EU country members will be given a due scrutiny, and interesting questions will be raised to discuss with participants during the Summer School. In this way, we hope that we can introduce EU angle into designing, drafting and implementing PIT in non EU countries.

Objective 2. Fosters the publication and dissemination of the results of academic research. As mentioned above, while there is good deal of theoretical literature with regard Law and Economics of Taxation at the host country, nonetheless almost solely US and UK's PIT systems are considered as benchmark and actually these two tax structures are given special attention.
In this Module, by categorizing and analysing the structure of PIT in the EU country members, we try to fill the abovementioned gap in several complementary ways. First, we prepare a booklet which covers courses materials in brief and explains EU PIT systems in a very simple way. In addition, we publish at least one peer reviewed paper to introduce PIT in the EU and derive its implication for tax reform in developing countries including Iran. Also, we encourage students to diversify their researches and delve into studies with respect to PIT in the EU, and we give them assistance to have their findings published. Through this accumulative process, we hope to contribute in promoting research publication and dissemination of academic research.

Objective 3. Promotes research and first teaching experience for young researchers and scholars and practitioners in European Union issues. For the being time, the EU perspective on PIT does not appear in regular courses' syllabuses neither in Law schools nor in Economic Faculties in Iran. Furthermore, academicians and practitioners who are involved in the EU studies have not approached to EU from PIT point of view. This Module aims to provide new materials both to enable young scholars to either propose new courses or revise extensively their existing syllabuses, and to encourage EU experts to deepen their studies from this angle.

Program

July 5th,2021 

12:00 (ECT) 14:30 (Tehran Time) : Opening Speech
Ali Nassiri Aghdam, Director of the Summer School, major is economics of the public sector with special focus on the economics of taxation. He teaches economics of taxation regularly and holds regular workshops to disseminate legal and economic foundations of tax policy and tax reform

12:30 : Understanding Taxation. Taxation and the Power to Tax : their conditions and the possible limits
The Role of the State in defining Taxes. Supra-National Constraints deriving from the EU Legal System
Marco Greggi, Lawyer and Professor of International Taxation Law at the University of Ferrara, Italy; Advisor to the Tax Courts of Appeal in Bologna and Venice, Italy (Ufficio del Massimario). Scientific Manager of an EU Funded Erasmus+ Project (Ferrara).

14:00 : Break

14:30 : Source and Residence in International Taxation
International Double Taxation on Business Income and its reflection on Individual Income
Marco Greggi

16:30 (ECT) 19:00 (Tehran Time) : End

July 6th, 2021 

12h00 : Fundamental Functions of Personal Income Tax in Economy : Redistribution
Optimal Personal Income Tax: Equity-Efficiency Trade off
Ali Nassiri Aghdam

13:00 : Haig-Simon's Income Definition
Economic Rational of Deviating from Haig-Simon's Income definition : Dealing with exemptions, Allowances and credits
Ali Nassiri Aghdam

14:00 : Break

14:30 : Tax Rates and Tax Systems : Progressive, Proportional and Regressive
Ali Nassiri Aghdam

15:30 : Criteria of the Fairness of Tax System: Horizontal Equity versus Vertical Equity
Tax Unit and Marriage Tax
Ali Nassiri Aghdam

16:30 : End

From 14:30 to 19:00 (Tehran Time)

July 7th 2021 

12:00 : Passive Income and Taxation of Dividends
Marco Greggi

13:00 : Passive Income and Taxation of Interests and Royalties
Marco Greggi

14:00 : Break

14:30 : Relief from Double Taxation
Marco Greggi

15:30 : The Non-discrimination Clause in International Tax Law
Marco Greggi

16:30 : End

From 14:30 to 19:00 (Tehran Time)

July 8th 2021 

12:00 : Fundamental Types of Personal Income Tax Systems
Bagher Darvishi

13:00 : Comparing Alternative PIT Systems Based on Simplicity, Efficiency, Equity, Compliance and Tax Revenue
Bagher Darvishi, Assistant Professor of public Economics at the University of Ilam

14:00 : Break

14:30 : Personal income taxation: a comparative approachwithin the European models of taxation
Assessing the power to tax of the states according to the OECD and UN Model conventions. An Analysis of the Tie Break rules
Jesús Ramos Prieto, Lawyer and Professor of Taxation at Pablo de Olavide University of Seville (Spain) ; José Miguel Martin ; José Manuel Macarro Osuna

15:30 : Income taxation and tax competition ; the race to the bottom. The so-called “special attraction regimes”
Jesús Ramos Prieto ; José Miguel Martin ; José Manuel Macarro Osuna

16:30 : End

From 14:30 to 19:00 (Tehran Time)

July 12th 2021 

12:00 : The HNWI regime
Continued : The retired individual regimes
Continued : skilled workers and top management
Marco Greggi

13:00 : Concluding remarks : ways and means to address unfair tax competition
Marco Greggi

14:00 : Break

14:30 : Capital Gain Tax and its Economic Rational
How Capital Gain is taxed ?
Lock in Effect and Capitalization Effect
CGT in EU Country Members
Bagher Darvishi

16:30 : End

From 14:30 to 19:00 (Tehran Time)

July 13th 2021 

12:00 : Overlapping tax jurisdictions : origin of international double taxation
Georges Cavalier, Associate Professor of Law at the University of Lyon, France, Director of the Tax LL.M, and Deputy Director of the Research Centre on Financial and Tax Law

14:00 : Break

14:30 : Double tax treaty assignment rules (including the concept of PE)
Georges Cavalier

16:30 : End

From 14:30 to 19:00 (Tehran Time)

July 14th 2021 

12:00 : The Role of Tax Planning in Business and individual Decision-making Process
Marco Greggi

13:00 : Understanding the Concepts : The Formal Approach versus “Substance over Form”
Marco Greggi

14:00 : Break

14:30 : Ways and Means to Prevent Avoidance : A Comparative Perspective
Marco Greggi

15:30 : Continued : discussion of cases
Marco Greggi

16:30 : End

From 14:30 to 19:00 (Tehran Time)

July 15th 2021 

12:00 : Dealing with tax Returns : Tax Administrator and Taxpayers' Perspective
Mahdi Movahedi Beknazar

14:00 : Break

14:30 : Introduction to Transfer Pricing
Georges Cavalier

16:30 : End

From 14:30 to 19:00 (Tehran Time)

July 19th 2021 

12:00 : Shortoutline of EU dispute mechanisms and effective protection of taxpayers rights
Nataša Žunić Kovačević, full professor of Law at the Faculty of Law, University of Rijeka

14:00 : Break

14:30 : Political Economy of Implementing Personal Income Tax
Mohammad Javad Rezaie

16:30 : End

From 14:30 to 19:00 (Tehran Time)

July 20th 2021 

12:00 : Personal Income Tax in Spain
JesúsRamos Prieto ; José Miguel Martin José ; Manuel Macarro Osuna

14:00 : Break

14:30 : Personal Income Tax in Croatia
Nataša Žunić Kovačević

16:30 : End

From 14:30 to 19:00 (Tehran Time)

Registration is open to anybody who is interested in "Personal Income Tax", as in this event lecturers will cover fundamentals of taxation, economic rational, legal structure as well as EU member countries expriences.
These material not only will be useful for students in Economics and Law faculties, but also will be beneficial to policy advocators who consider tax reforms, especially in developing countries with underdeveloped income tax system.
To register at this event please fill the form in this link : http://185.95.180.184/en-piteu/en/form/5/form1