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This subject will provide a detailed comparative analysis of the principal topics in international taxation. Following an introduction to comparative law theories and methods, 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) and digital taxation projects 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 country.
Principal topics include:
- Broad trends in international tax policy and structure across countries
- Jurisdiction to tax (residence and source)
- Taxation of foreign income of residents, including elimination of double taxation
- Taxation of non-residents, including the scope of source taxation
- International tax expenditures
- International anti-avoidance rules, including controlled foreign company rules, thin capitalisation rules, indirect transfer rules, and transfer pricing
- Tax treaties, including automatic exchange of information
- Transparency initiatives, including disclosure of beneficial owners and country-by-country reporting
- OECD and UN initiatives in international taxation, including BEPS issues, combatting tax evasion, and digital taxation issues
Intended learning outcomes
A student who has successfully completed this subject will be able to:
- explain the major differences in approaches to comparative tax law theories and methods and justify decisions about which countries to compare and their method for comparison;
- identify the major policy differences among countries in the design of their international tax law frameworks and explain how those policy differences reflect differences in economic and political systems, values, and other explanatory variables;
- describe the deep structure of international tax systems;
- defend their position on the sensibility of recent international tax initiatives undertaken by the UN and OECD;
- convey the approach to the major issues in international taxation in their home country and compare that approach to the approach taken in other jurisdictions
- explain why countries differ in their approach to the major international tax framework;
- participate actively in debates about emerging and contemporary issues in international taxation; and
- demonstrate autonomy, expert judgment and responsibility as a practitioner and learner in the field of comparative international tax.
Last updated: 10 November 2023