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Globalisation is driving corporate tax systems closer together and often into conflict. For many tax practitioners, it is now not enough to know their own corporate tax system—they must grapple with and question the operation of other corporate tax systems. This subject seeks to develop an ability to understand and analyse any corporate tax system and assess its impact on corporate decision-making. With a dedicated textbook (written by the presenter), this subject compares a number of influential and archetypal corporate tax systems (both common law and civil law) and assesses their behaviour in the context of practical problems. For tax professionals, this subject develops an ability to ask direct and informed questions about a foreign corporate tax system and discuss that system at a high level with foreign tax professionals.
This subject will compare and analyse corporate income tax law in selected countries (Australia, China, Germany and the US, with some reference to the UK) and consider how these laws interface with corporate law. Participants will be encouraged to discuss other jurisdictions with which they are familiar and students are permitted to cover other countries in their research paper. The approaches adopted are analysed by reference to various policy options available. There is a particular focus on problems caused by the artificiality of corporations.
Principal topics include:
- Identification of entities (including hybrids) subject to corporation tax
- Corporate groups and personal service companies
- Debt versus equity and relief from economic double taxation of dividends
- Cross-border corporate income and dividends
- Gains/losses on the disposal of shares, takeovers and sale of loss companies
- Corporate formation, share buy-backs and liquidation
- Bonus issues, convertible notes, mergers and demergers.
Intended learning outcomes
A student who has successfully completed this subject will:
- Have an advanced and integrated understanding of income tax law and policy as it relates to corporations and their shareholders
- Be able to critically examine, analyse, interpret and assess the effectiveness of these laws and policies
- Be an engaged participant in debate regarding emerging and contemporary issues in the field of corporate tax
- Have a sophisticated appreciation of the factors and processes driving reform of the legal framework in the countries chosen for comparison
- Have an advanced understanding of the significance of the role of the courts in judicial approaches to taxation of corporations in the common law and other legal traditions
- Have a detailed understanding of the latest developments and trends in laws dealing with corporate taxation
- Have the cognitive and technical skills to generate critical and creative ideas relating to laws and policies dealing with corporate taxation, and to critically evaluate them
- Have the cognitive and technical skills to independently examine, research and analyse the key elements and features of corporate taxation from a comparative perspective
- Have the communication skills to clearly articulate and convey complex information regarding corporate taxation to relevant specialist and non-specialist audiences
- Be able to demonstrate autonomy, expert judgment and responsibility as a practitioner and learner in the field of comparative corporate taxation.
Last updated: 12 November 2022