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The aim is to overview the current UK international tax system, and its historical development. Focus will be on corporate taxation, but with some background on individuals (trust, partnerships etc will be mentioned only briefly). This will cover issues such as: residence and source definitions; relief from double taxation (both unilateral and bilateral), CFC legislation, transfer pricing and thin cap, worldwide debt cap, the impact of tax treaties, dividend exemption and PE exemption, and some discussion of the Diverted Profits Tax. Key themes will include the impact of European Union law, and the UK’s policy of tax competition. The subject will give students an overview and general understanding of the UK corporate tax system for both inbound and outbound investments.
Principal topics include:
- Historical introduction to the UK international tax system
- Individuals – residence and domicile
- Corporates – residence and source definitions
- Relief from double taxation: unilateral and bilateral measures – the UK treaty network
- CFCs – the impact of EU law
- Transfer pricing, thin cap and worldwide interest cap – the impact of EU law
- Foreign tax credits; dividend exemption and PE exemption – the impact of tax competition
- Non-residents and the UK tax system – attribution of profits to PEs.
Intended learning outcomes
A student who has successfully completed this subject will:
- Have an advanced and integrated understanding of the legal principles of UK international tax law, the underlying structural, institutional and policy influences that make international 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 revision of the international tax legal framework
- Have an advanced understanding of the similarities and differences of international 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 international tax
- Have the cognitive and technical skills to independently examine, research and analyse existing and emerging legal issues relating to UK international tax
- Have the communication skills to clearly articulate and convey complex information regarding comparative UK 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 UK international tax.
Last updated: 10 November 2023