International taxation is an important factor in the decision-making of international businesses, and in many cases it has a direct influence on the manner in which corporate groups and transactions are structured. It is of course also fundamentally important to nation states, which need tax revenues to fund public expenditure.
The module takes a theoretical approach to specific issues relating to international taxation in the context of international trade and investment. It does not focus on the national laws of any particular jurisdiction but rather on the general principles and structure of international taxation. The module will therefore be useful to students from any country or background.
The focus of the module is on international tax issues relevant to cross-border trade and investment and to the multinational companies that engage in the majority of such trade and investment. It considers international tax law from many perspectives: historical, policy and compliance perspectives and also the perspective of both revenue authorities and taxpayers.
The module covers the basic principles of jurisdiction to tax and the connecting factors frequently used by countries in imposing taxes as well as the rules governing the main types of corporate income. It also looks at how conflicts lead to international double taxation, the problems that this creates for international trade and investment and the solutions provided for in double taxation treaties. It then considers tax planning and tax competition, tax havens and the response of developed countries to tax planning.
This is a particularly interesting time to study international taxation. The taxation of multinationals has become a subject of public discourse and a political issue, and the G20, the OECD and others are undertaking substantial work to address ‘Base Erosion and Profit Shifting’ (‘BEPS’). The OECD/G20 BEPS project and other developments in international taxation will be covered in the module.
This is an indicative module outline only to give an indication of the sort of topics that may be covered. Actual sessions held may differ.
Basic tax terminology and concepts
The meaning of international tax law and its parameters
The jurisdiction to tax
Double taxation conventions – nature and purpose
Double taxation conventions – interpretation and operation
Tax avoidance and evasion
Tax planning, tax competition and the role of tax havens
State responses to tax planning
Transfer pricing
Mutual assistance and co-operation between revenue authorities and enforcement of foreign tax claims
Current and future developments
The module does not assume any previous knowledge of tax law, national or international.
By the end of the module, students should be able to:
Reuven S Avi-Yonah, Advanced Introduction to International Tax Law (Edward Elgar Publishing 2015)
Angharad Miller and Lynne Oats, Principles of International Taxation (5th edn, Bloomsbury Professional 2016)
Kevin Holmes, International Tax Policy and Double Tax Treaties (2nd edn, IBFD 2014)
Peter Harris and David Oliver, International Commercial Tax (Cambridge University Press 2010)
No subject specific skills defined for this module.
No transferable skills defined for this module.
Type | Required |
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Seminars | (0%) |
Tutorials | 9 sessions of 1 hour (4%) |
Online learning (independent) | 9 sessions of 1 hour (4%) |
Private study | 182 hours (91%) |
Total | 200 hours |
No private study requirements defined for this module.
Consultation
No further costs have been identified for this module.
You must pass all assessment components to pass the module.
Students can register for this module without taking any assessment.
Weighting | Study time | |
---|---|---|
4000 word essay | 100% | |
Students will write 4000 words on one of a number of listed titles. |
Feedback via Tabula
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