Tax Treaties: International Perspectives (LAWS90132)

The theory and practice of international tax law has always been dynamic, as it involves the interaction of at least two states’ tax laws, which are constantly changing, through the medium of tax treaties. The concerted, intergovernmental response following the public outcry against aggressive tax planning through the OECD/G20 BEPS project has only increased this dynamism. This means it is increasingly important for international tax practitioners–professionals and administrators – to understand the technicalities of tax treaties. This is also true of policy makers who are engaged in the process of negotiating tax treaties.

This subject provides significant insights into tax treaties interpretation and application, issues faced by multinational businesses. It will also delve into how competing interests of developed and developing countries are reflected in tax treaties.

Principal topics that will be addressed during the subject include:

• Juridical Double Taxation;
• Economic Double Taxation & Relief;
• Introduction to Tax Treaties;
• Treaty Interpretation & Treaty Residence;
• Permanent Establishments & Attribution of Profits to Permanent Establishments;
• Dividends, Interest, Royalties;
• Income from immovable property and capital gains;
• Partnerships and Hybrid Entities;
• Non-Discrimination in International Taxation.