The specific aims of this module are to ensure that students can:
1. Understand the legal principles applying to international taxation.
2. Appreciate the broader economic, political and economic implications of international taxation law.
3. Carry out research in the field of international taxation law.
4. Recognise and describe the practical effects and commercial significance of legal rules relating to international taxation.

(LO1) By the end of the module the student will be able to:

(LO2) Demonstrate an awareness of the basic principles of international taxation law;

(LO3) Understand how tax systems are designed and administered;

(LO4) Identify and discuss the key issues in international taxation;

(LO5) Analyse the main features of the operation of double taxation treaties;

(LO6) Examine the differences in tax systems that can be exploited to minimize global tax liabilities;

(LO7) Evaluate the measures taken by governments and supra-national organisations to limit tax avoidance by multi-national enterprises;

(LO8) Conduct effective research, including the use of legal information retrieval systems, to locate and collate information about the law applicable in a given situation;

(LO9) Demonstrate an ability to analyse and present materials.

(S1) Critical analysis appropriate for advanced level masters study.

(S2) Problem-solving skills applicable to complex theoretical and practical contexts.

(S3) Time management and prioritisation skills by working to deadlines.

(S4) Individual and group communication skills by presentations in an online environment (e.g. the virtual classroom).

(S5) Take responsibility for independent learning agenda.

(S6) Reading, analysing and synthesising different viewpoints, becoming familiar with different viewpoints and presenting findings/conclusions in clear, comprehensible, structured format.

(S7) Critical skills with regard to the merits of particular arguments and making reasoned choices between alternative solutions or arguments in all modules and dissertation.

Week 1

Introduction to International Tax Law

Topics
- Globalisation and international tax law
- The nature of international tax and its legal context
- Objectives of international taxation (including capital export neutrality, capital import neutrality and inter-nation equity)
- Entitlement tax (worldwide and source based taxation)

Week 2
Double taxation and double taxation relief

Topics
- Causes of double taxation
- Differences between double economic and double juridical taxation
- Economic problems caused by double taxation
- Primary methods of relief from double taxation by the state of residence; relief by credit, relief by exemption and deduction method
- Double tax relief in practice
- Unilateral relief in the UK

Week 3 Tax treaties and permanent establishments

Topics
- History of tax treaties
- Function of tax treaties
- The development of the OECD and the UN model treati es
- Definitions in the UN Model Convention
- Legal nature of treaties
- Role and recommendations of the OECD
- Definitional and administrative OECD articles
- Permanent establishments
- A 'fixed place of business'
- The use of agents and agency rules
- Group companies as PEs
- Extent of exposure to tax in the PE location

Week 4 OECD Model Treaty I: Companies and Individuals

Topics
- Overseas branches and subsidiaries
- UK taxation of inward and outward investment
- Taxation of employees working abroad
- Financing for multi-national groups
- US and UK approaches to taxation of MNCs

Week 5 OECD Model Treaty II: Anti-haven legislation and transfer pricing

Topics
- Tax-havens and growth of the offshore financial sector
- Anti-haven legislation
- The problem of transfer pricing
- Role and recommendations of the OECD
- US, EU and UK approaches to transfer pricing - Thin capitalisation

Week 6 Treaty shopping and tax competition

Topics
- Tax treaties and treaty shopping
- US limitation of benefits provisions
- Competition between tax jurisdictions
- EU and OECD projects to limit 'harmful' tax competition
- Alternative method of allocating profits between two states
- Economic and Political issues surrounding such a change

Week 7 The OECD Model Treaty III: European Corporation Tax Issues

Topics
- EU principles affecting tax issues
- EU moves towards harmonisation
- The common consolidated corporate tax base
- European corporate income tax (EUCIT) and the societas europaea
- European tax harmonisation cases

Week 8 VAT and Custom Duties

Topics
- The basics of value added tax
- Alternative Systems for taxing cross-border supplies
- The EU 'transitional system' and MTIC fraud
- The 'definitive system'
- Cust oms and excise duties

Teaching Method 1 - Lecture Description: Weekly Online Discussions and Assignments in Virtual Classroom