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Using a series of case studies, this subject will explore complex issues involving the interpretation and application of tax treaty provisions. During this subject, students (who will have a previous general knowledge of tax treaties) will be asked to analyse how these provisions apply in situations to which multinational enterprises and tax administrations are often confronted.
The subject will be given by Jacques Sasseville, a former tax treaty negotiator who has lectured and written extensively on tax treaties and who is now Head of the Tax Treaty Unit of the OECD. In this capacity, he is involved in all the work related to the regular updating of the OECD Model Tax Convention and provides training and advice on tax treaty issues to OECD and non-OECD countries.
Principal topics that will be addressed during the subject include:
- The application of the permanent establishment definition
- The tax treaty rules for the attribution of profits to permanent establishments
- The application of tax treaties to transparent and hybrid entities
- The taxation of expatriates
- The tax treaty treatment of employee stock-options
- The tax treaty treatment of various digital economy payments
- The interaction between treaties and domestic anti-abuse rules
- Timing issues related to tax treaties.
Intended learning outcomes
A student who has successfully completed this subject will:
- Have an advanced and integrated understanding of the legal principles of international tax treaties, 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
- 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 tax treaties
- Have a detailed understanding of problems that arise in the international tax treaty context
- Have the cognitive and technical skills to generate critical and creative ideas relating to comparative international tax treaties
- Have the cognitive and technical skills to independently examine, research and analyse existing and emerging legal issues relating to international tax treaties
- Have the communication skills to clearly articulate and convey complex information regarding comparative international tax treaties 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 treaties.
Last updated: 10 November 2023