TAXATION OF CROSS-BORDER SERVICES IN THE CURRENT INTERNATIONAL, EUROPEAN AND ITALIAN CONTEXT

The PhD thesis is entitled to the study of the rules concerning the taxation of services in the International, European and Italian context. The decision to study the taxation of services stems from the prominent position of these activities in today’s economy: such a consideration applies both to developed countries, as well as to developing countries. Such prominence position has been further intensified by the digital revolution. Because of this even more “service – oriented” structure, the taxation of services has been under scrutiny for at least thirty years: lately this issue has been brought to the forefront of international taxation debate, in relation to which the taxation of services appears to be nowadays one of the most controversial topic. The work is structured in three chapters, which focus on the taxation of cross – border services in the current international tax system (chapter 1), on the taxation of cross – border intra group services in light of its main transfer pricing implications (chapter 2) and on the taxation of digital cross – border services (chapter 3). Each of the three mentioned chapters starts with an introductory question, followed by the analysis of the main aspects related to the International and European frameworks. The domestic level is also considered: those domestic frameworks that appear to be of most interest for the analysis performed in each chapter have been indeed selected. The last chapter 4 discusses the conclusions of the analysis performed in the three preceding chapters in light of the Italian experience, the one which the PhD student is most familiar with.