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UK International Tax (LAWS90054)
Graduate courseworkPoints: 12.5Not available in 2018
Overview
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The aim is to overview the current UK international tax system, and its historical development. Focus will be on corporate taxation, but with some background on individuals (trust, partnerships etc will be mentioned only briefly). This will cover issues such as: residence and source definitions; relief from double taxation (both unilateral and bilateral), CFC legislation, transfer pricing and thin cap, worldwide debt cap, the impact of tax treaties, dividend exemption and PE exemption, and some discussion of the Diverted Profits Tax. Key themes will include the impact of European Union law, and the UK’s policy of tax competition. The subject will give students an overview and general understanding of the UK corporate tax system for both inbound and outbound investments.
Principal topics include:
- Historical introduction to the UK international tax system
- Individuals – residence and domicile
- Corporates – residence and source definitions
- Relief from double taxation: unilateral and bilateral measures – the UK treaty network
- CFCs – the impact of EU law
- Transfer pricing, thin cap and worldwide interest cap – the impact of EU law
- Foreign tax credits; dividend exemption and PE exemption – the impact of tax competition
- Non-residents and the UK tax system – attribution of profits to PEs.
Intended learning outcomes
A student who has successfully completed this subject will:
- Have an advanced and integrated understanding of the legal principles of UK international tax law, the underlying structural, institutional and policy influences that make international tax systems the way they are and recent developments in this field of law and practice
- Be able to critically examine, analyse, interpret and assess the effectiveness of these legal rules and the underlying structural, institutional and policy influences
- Be an engaged participant in debate regarding emerging and contemporary issues in the field
- Have a sophisticated appreciation of the factors and processes driving revision of the international tax legal framework
- Have an advanced understanding of the similarities and differences of international tax systems
- Have a detailed understanding of problems that arise in the international tax context
- Have the cognitive and technical skills to generate critical and creative ideas relating to international tax
- Have the cognitive and technical skills to independently examine, research and analyse existing and emerging legal issues relating to UK international tax
- Have the communication skills to clearly articulate and convey complex information regarding comparative UK international tax to relevant specialist and non-specialist audiences
- Be able demonstrate autonomy, expert judgment and responsibility as a practitioner and learner in the field of UK international tax.
Last updated: 3 November 2022
Eligibility and requirements
Prerequisites
Melbourne Law Masters Students: None
JD Students: Successful completion of the below subject:
| Code | Name | Teaching period | Credit Points |
|---|---|---|---|
| LAWS50046 | Taxation Law and Policy |
Semester 1 (On Campus - Parkville)
Semester 2 (On Campus - Parkville)
|
12.5 |
Corequisites
None
Non-allowed subjects
None
Recommended background knowledge
Applicants without legal qualifications should note that subjects are offered in the discipline of law at an advanced graduate level. While every effort will be made to meet the needs of students trained in other fields, concessions will not be made in the general level of instruction or assessment. Most subjects assume the knowledge usually acquired in a degree in law (LLB, JD or equivalent). Applicants should note that admission to some subjects in the Melbourne Law Masters will be dependent upon the individual applicant’s educational background and professional experience.
Inherent requirements (core participation requirements)
The University of Melbourne is committed to providing students with reasonable adjustments to assessment and participation under the Disability Standards for Education (2005), and the Assessment and Results Policy (MPF1326). Students are expected to meet the core participation requirements for their course. These can be viewed under Entry and Participation Requirements for the course outlines in the Handbook.
Further details on how to seek academic adjustments can be found on the Student Equity and Disability Support website: http://services.unimelb.edu.au/student-equity/home
Last updated: 3 November 2022
Assessment
Additional details
Take-home examination (5,000-6,000 words) (100%)
A minimum of 75% attendance is a hurdle requirement.
Last updated: 3 November 2022
Quotas apply to this subject
Dates & times
Not available in 2018
Time commitment details
136-150 hours The pre-teaching period commences four weeks before the subject commencement date. From this time, students are expected to access and review the Reading Guide that will be available from the LMS subject page and the subject materials provided by the subject coordinator, which will be available from Melbourne Law School. Refer to the Reading Guide for confirmation of which resources need to be read and what other preparation is required before the teaching period commences.
Additional delivery details
This subject has a quota of 30 students. Please refer to the Melbourne Law Masters website for further information about the management of subject quotas and waitlists.
Last updated: 3 November 2022
Further information
- Texts
Prescribed texts
Specialist printed materials will be made available free of charge from the Melbourne Law School prior to the pre-teaching period.
- Related Handbook entries
This subject contributes to the following:
Type Name Course Graduate Diploma in Legal Studies Course Graduate Diploma in International Tax Course Graduate Diploma in Tax Course Master of Commercial Law Course Master of International Tax Course Master of Laws Course Master of Tax Course Master of Public and International Law - Links to additional information
law.unimelb.edu.au
- Available through the Community Access Program
About the Community Access Program (CAP)
This subject is available through the Community Access Program (also called Single Subject Studies) which allows you to enrol in single subjects offered by the University of Melbourne, without the commitment required to complete a whole degree.
Entry requirements including prerequisites may apply. Please refer to the CAP applications page for further information.
Additional information for this subject
If required, please contact law-admissions@unimelb.edu.au for subject coordinator approval.
- Available to Study Abroad and/or Study Exchange Students
This subject is available to students studying at the University from eligible overseas institutions on exchange and study abroad. Students are required to satisfy any listed requirements, such as pre- and co-requisites, for enrolment in the subject.
Last updated: 3 November 2022