Handbook home
Tax Treaties: International Perspectives (LAWS90132)
Graduate courseworkPoints: 12.5On Campus (Parkville)
About this subject
- Overview
- Eligibility and requirements
- Assessment
- Dates and times
- Further information
- Timetable (login required)(opens in new window)
Contact information
June
Lecturer:
Dr Dhruv Janssen-Sanghavi (Coordinator)
Email: law-masters@unimelb.edu.au
Phone: 13 MELB (13 6352), International: +(61 3) 9035 5511
Website: law.unimelb.edu.au
Overview
Availability(Quotas apply) | June |
---|---|
Fees | Look up fees |
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.
Intended learning outcomes
A student who has successfully completed this subject should be able to:
- discern, interpret and apply income tax treaties
- examine critically, analyse and assess tax treaty decisions from around the world and their application to different tax treaties
- contribute to discussions and ongoing debates around base erosion and profit shifting
- independently examine, research and analyse existing and emerging legal issues relating to tax treaties
- communicate and convey complex information regarding comparative international tax treaties to specialist and non-specialist audiences
- demonstrate autonomy, expert judgment and responsibility as a practitioner and learner in the field of international tax treaties
Last updated: 18 March 2024
Eligibility and requirements
Prerequisites
None
Corequisites
None
Non-allowed subjects
None
Recommended background knowledge
Students should have completed Tax Treaties (LAWS70146) or have a good working knowledge of tax treaties prior to undertaking this subject.
Applicants without legal qualifications should note that subjects are offered in the discipline of law at an advanced graduate level. While every effort will be made to meet the needs of students trained in other fields, concessions will not be made in the general level of instruction or assessment. Most subjects assume the knowledge usually acquired in a degree in law (LLB, JD or equivalent). Applicants should note that admission to some subjects in the Melbourne Law Masters will be dependent upon the individual applicant’s educational background and professional experience.
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: 18 March 2024
Assessment
Description | Timing | Percentage |
---|---|---|
Assessment 1 - 2 reaction papers (on topics discussed in class)
| Due within one week after the end of teaching | 30% |
Assessment 2 - Take-home examination
| 2 - 5 August 2024 | 70% |
Hurdle requirement: A minimum of 75% attendance is required. | Throughout the teaching period | N/A |
Additional details
Note: Students must choose assessment from the options listed above. If an option contains parts, all parts must be completed if that option is chosen.
Last updated: 18 March 2024
Quotas apply to this subject
Dates & times
- June
Mode of delivery On Campus (Parkville) Contact hours Total time commitment 150 hours Pre teaching start date 22 May 2024 Pre teaching requirements Please 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 period 19 June 2024 to 25 June 2024 Last self-enrol date 27 May 2024 Census date 20 June 2024 Last date to withdraw without fail 5 July 2024 Assessment period ends 5 August 2024 June contact information
Lecturer:
Dr Dhruv Janssen-Sanghavi (Coordinator)
Email: law-masters@unimelb.edu.au
Phone: 13 MELB (13 6352), International: +(61 3) 9035 5511
Website: law.unimelb.edu.au
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
This subject has a quota of 30 students.
Enrolment is on a first come, first served basis. Waitlists are maintained for subjects that are fully subscribed.
Students should note priority of places in subjects will be given as follows:
- To currently enrolled Graduate Diploma and Masters students with a satisfactory record in their degree
- To other students enrolling on a single subject basis, eg Community Access Program (CAP) students, cross-institutional study and cross-faculty study.
Please refer to the Melbourne Law Masters website for further information about the management of subject quotas and waitlists.
Last updated: 18 March 2024
Further information
- Texts
Prescribed texts
Specialist printed materials will be made available free of charge from the Melbourne Law School prior to the pre-teaching period.
- Links to additional information
- Available through the Community Access Program
About the Community Access Program (CAP)
This subject is available through the Community Access Program (also called Single Subject Studies) which allows you to enrol in single subjects offered by the University of Melbourne, without the commitment required to complete a whole degree.
Entry requirements including prerequisites may apply. Please refer to the CAP applications page for further information.
- Available to Study Abroad and/or Study Exchange Students
This subject is available to students studying at the University from eligible overseas institutions on exchange and study abroad. Students are required to satisfy any listed requirements, such as pre- and co-requisites, for enrolment in the subject.
Last updated: 18 March 2024