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September - Dual-Delivery
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The world of international tax is changing rapidly. This new subject offers a flexible and topical exploration of the brave new world of global digital tax. The subject will bring you up to date and give you an advanced understanding of the multilateral Inclusive Framework rules for taxation of profits of large corporations and a global minimum tax on corporate profits. It will examine how these new developments relate to the existing international tax rules that will cointue to apply, and will explore developments in multilateral treaties, international tax co-operation and dispute management in a global, digital world.
Principal topics will include:
- The Inclusive Framework and G20-OECD Base Erosion and Profit Shifting project: Parts One and Two
- The New Rules for Taxing Global Multinationals on profits in market jurisdictions (Pillar One)
- The New Global Corporate Minimum Tax (Pillar Two)
- The New International Tax Law Making Process: The Multilateral Treaty and Model Rules and their relationship with bilateral treaties and national tax reforms
- International tax co-operation and dispute management including Mutual Agreement Procedure, Arbitration and Review Panels in a Global Digital World
Intended learning outcomes
A student who has successfully completed this subject will:
- Have an advanced understanding of the latest trends and developments in tax law at the global level including policy and law
- Understand the context and relationship between the new rules and existing frameworks for international taxation.
- Understand and be able to analyse the Australian law, treaty and changes reforms in relation to these new global trends
- Understand the perspective of other countries on the new global digital tax law trends and their relation to Australia
- Apply new knowledge about these fields in advising on Australian tax law to clients exposed to the new global digital tax rules
- Be able to communicate, orally and in writing an explanation, and detailed critical analysis of thse new rules.
- Legislative, treaty and case sources research, analysis and writing skills in international tax law
- The ability to understand the politics and policy of global digital tax, enabling analysis of tax law in in context
- Communication skills (oral and written) in class presentations, and in writing and applying tax law to problems
Last updated: 17 February 2023