International Tax: Principles, Structure (LAWS70006)

Graduate coursework level 7Points: 12.5On Campus (Parkville)

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Overview

Availability(Quotas apply)
April
October
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This core international tax subject is of central importance given Australia’s ever-growing role in the global economy. This subject covers the fundamental international income tax rules that apply where income or capital gains are derived in circumstances that have a connection with Australia. It considers Australia’s tax jurisdiction of residence and source, and relief from double taxation under domestic law and tax treaties. It also examines measures to prevent tax avoidance, such as controlled foreign company measures and transfer pricing.

This subject is designed to explore in detail the fundamental principles of Australia’s international taxation regime. The subject will examine both the issues of tax design and policy, and the relevant provisions in the legislation, cases and rulings.

Indicative list of principal topics:

  • Principles of international taxation
  • Rules for determining residence and source
  • Rules for the taxation and avoidance of double tax of residents’ foreign income including foreign income tax offsets and exemption of foreign income
  • Rules for the taxation of non-residents’ Australian source income (business income, interest, dividends and royalties)
  • Introduction to tax treaties
  • Introduction to accruals taxation of controlled foreign corporations and foreign trusts.
  • Overview of rules for the prevention of base erosion and profit shifting including the multinational anti-avoidance law, diverted profits tax and thin capitalisation rules.

Note: Advanced treatment of tax treaties, controlled foreign corporations and trusts, thin capitalisation, base erosion and profit shifting will be provided in the following suite of advanced and specialist international tax subjects.  

  • International Tax: Anti-Avoidance
  • Transfer Pricing
  • Tax Treaties
  • Current Issues in International Tax

Intended learning outcomes

A student who has successfully completed this subject will:



  • Have an advanced and integrated understanding of the policies underlying Australia’s rules for taxing international transactions
  • Have a detailed knowledge of the principles of law applicable to the taxation of inbound and outbound transactions
  • Be able to critically examine, analyse, interpret and assess the effectiveness of Australia’s rules for the taxation of inbound and outbound transactions
  • Be an engaged participant in the debate on the principles of international taxation and international tax avoidance
  • Have a sophisticated appreciation of the international tax policy issues
  • Have an understanding of the competing policy issues of deriving an appropriate amount of tax from cross-border transactions without impeding international trade and investment
  • Have the cognitive and technical skills to generate critical and creative ideas relating to the taxation of cross-border transactions, and to critically evaluate legal and policy issues
  • Have the skills to independently examine, research and analyse current and emerging legal issues relating on international taxation
  • Have the oral and written communication skills to articulate and convey complex information regarding international taxation to specialist and non-specialist audiences.

Last updated: 4 March 2025

Eligibility and requirements

Prerequisites

None

Corequisites

None

Non-allowed subjects

None

Recommended background knowledge

Applicants without legal qualifications should note that subjects are taught at an advanced graduate level and requires a thorough background in common law. While efforts are made to meet the needs of students trained in other fields, teaching and assessment activities are designed to give an advanced and integrated understanding of the discipline of law for legal practitioners, learners and researchers. 

Inherent requirements (core participation requirements)

The University of Melbourne is committed to providing students with reasonable adjustments to assessment and participation under the Disability Standards for Education (2005), and the Assessment and Results Policy (MPF1326). Students are expected to meet the core participation requirements for their course. These can be viewed under Entry and Participation Requirements for the course outlines in the Handbook.

Further details on how to seek academic adjustments can be found on the Student Equity and Disability Support website: http://services.unimelb.edu.au/student-equity/home

Last updated: 4 March 2025

Assessment

April

DescriptionTimingPercentage

Class participation

Throughout the teaching period10%

Take-home exam

  • 5000 words
30 May - 2 June 202590%
Hurdle requirement: A minimum of 75% attendance is required.Throughout the teaching periodN/A

October

DescriptionTimingPercentage

Class participation

Throughout the teaching period10%

Take-home examination

  • 5000 words
12 - 15 December 202590%
Hurdle requirement: A minimum of 75% attendance is required.Throughout the teaching periodN/A

Last updated: 4 March 2025

Quotas apply to this subject

Dates & times

  • April
    Principal coordinatorDavid Watkins
    Mode of deliveryOn Campus (Parkville)
    Contact hours34
    Total time commitment150 hours
    Pre teaching start date 2 April 2025
    Pre teaching requirementsPlease refer to the Reading Guide on the LMS subject page for confirmation of which resources need to be read and what other preparation is required before the teaching period commences.
    Teaching period30 April 2025 to 6 May 2025
    Last self-enrol date 7 April 2025
    Census date 2 May 2025
    Last date to withdraw without fail13 June 2025
    Assessment period ends18 July 2025

    April contact information

    Teaching staff: 

    David Watkins (Coordinator)
    Jonathan Hill

    For current student enquiries, contact the Law School Academic Support Office 

     

  • October
    Principal coordinatorDavid Watkins
    Mode of deliveryOn Campus (Parkville)
    Contact hours34
    Total time commitment150 hours
    Pre teaching start date24 September 2025
    Pre teaching requirementsPlease refer to the Reading Guide on the LMS subject page for confirmation of which resources need to be read and what other preparation is required before the teaching period commences.
    Teaching period22 October 2025 to 28 October 2025
    Last self-enrol date29 September 2025
    Census date24 October 2025
    Last date to withdraw without fail 5 December 2025
    Assessment period ends 9 January 2026

    October contact information

    Teaching staff: 

    David Watkins (Coordinator)
    Jonathan Hill

    For current student enquiries, contact the Law School Academic Support Office 

     

What do these dates mean

Visit this webpage to find out about these key dates, including how they impact on:

  • Your tuition fees, academic transcript and statements.
  • And for Commonwealth Supported students, your:
       -  Student Learning Entitlement. This applies to all students enrolled in a Commonwealth Supported Place (CSP).
     

    Subjects withdrawn after the census date (including up to the ‘last day to withdraw without fail’) count toward the Student Learning Entitlement.

Additional delivery details

Please refer to the Melbourne Law Masters enrolment webpage for further information about re-enrolment, subject quotas and waitlists. 
Melbourne Law School may reserve places in a subject for incoming international cohorts or where a subject is core to a specialisation with limited alternate options. 

Last updated: 4 March 2025

Further information

Last updated: 4 March 2025