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About this subject
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This subject is an advanced study of the rules under the Australian income tax legislation and tax treaties for dealing with international tax avoidance. The subject builds on the basic principles studied in International Tax: Principles and Structure and will include an advanced study of Australia’s anti-deferral rules (CFCs and transferor trusts), including their interactions and reconciliations. Other major BEPS issues to be examined in the Australian context include interest deductibility, cross-border tax arbitrage, and abuse of tax treaties (including treaty shopping). The subject will critically examine the policy underlying Australia’s rules and evaluate whether their technical implementation achieves their policy objectives. There will be consideration of the ongoing reform of the rules, including international developments through the work of the Inclusive Framework. BEPS is redefining the rules for countering international tax avoidance and students working in international tax need to be aware of how these rules are being developed and reformed both globally and in Australia.
Principal topics include:
- Australia’s CFC and transferor trust rules
- Multinational anti-avoidance law (MAAL)
- Diverted profits tax (DPT)
- Thin capitalisation rules
- Hybrid mismatch rules (tax arbitrage)
- Treaty-related anti-avoidance rules
- Exchange of information.
Intended learning outcomes
A student who has successfully completed this subject will:
- Have an advanced and integrated understanding of the tax law and policy relating to Australia’s rules for dealing with international tax avoidance
- Be able critically to 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 international tax avoidance both globally and in Australia
- Have the cognitive and technical skills to generate critical and creative ideas relating to laws and policies dealing with international tax avoidance, and to evaluate them
- Have the communication skills to clearly articulate and convey complex information regarding the various approaches to dealing with international tax avoidance 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 international tax avoidance.
Last updated: 24 January 2023