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This subject will provide a detailed comparative analysis of the principal topics in international taxation. The core principles of international income tax will be examined, with the different approaches taken by nations (developed, emerging, and developing countries) outlined and critiqued. The compatibility of international tax systems in dealing with international transactions will be examined, and key areas of mismatch and overlap identified. The ongoing reform of international tax rules under the O.E.C.D. Base Erosion and Profit Shifting (BEPS) project will be considered. This subject will equip students to analyse international tax issues using a comparative approach and to acquire a deep understanding of the underlying structural, institutional, and policy influences that have shaped international income tax systems. This knowledge is directly applicable to analysing international tax problems in any particular country.
Principal topics include:
- Jurisdiction to tax (residence and source)
- Taxation of foreign income of residents, including elimination of double taxation
- Deductibility of expenses to earn dividends from foreign corporations
- Controlled foreign company rules
- Taxation of non-residents
- Thin capitalisation rules
- Tax treaties
- BEPS issues.
Intended learning outcomes
A student who has successfully completed this subject will:
- Have an advanced and integrated understanding of the legal principles of comparative international law; the underlying structural, institutional and policy influences that make income tax systems the way they are; and recent developments in this field of law and practice particularly as a result of the BEPS project
- 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 international revision of the legal framework
- Have an advanced understanding of the similarities and differences of international income 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 comparative international tax
- Have the cognitive and technical skills to independently examine, research, and analyse existing and emerging legal issues relating to international tax
- Have the communication skills to clearly articulate and convey complex information regarding comparative 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 comparative international tax.
Last updated: 18 December 2020