Global Digital Tax (LAWS90232)

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 continue 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