International Corporate Taxation

Recommended Prerequisites

Accounting

Finance

Teaching Methods

Economic analysis of international taxation.

Normative explanation of Treaties and Directives

Case studies on the application of legal tools in international tax management

Learning Outcomes

The course unit objetives/outcomes  are:

a)Highlight tax topics that corporate managers operating in an international economic  environment should take into consideration

b)Analyse the instruments (Tax treaties, EU Directives, etc.) that such corporations can use in the tax management of operations

c)Prepare stduents to work in a international tax environment, with a special focus on tax planning and anti avoidance measures

d)Stressing the importance of taxes in international investment/financing decisions, given the sources of divergence between accounting income and taxable income after the introduction of International Financial Reporting Standards (IFRS) based systems

Work Placement(s)

No

Syllabus

1.Introduction

 

2.The problem of international double taxation of income in corporate management: its especial relevance to dividends, capital gains, royalties, interest and other corporate income flows

 

3.Methods to avoid double taxation

 

4.The taxation of international groups and dividend repatriation

- territorial and worldwide tax systems

- participation exemption regimes

- EU directive on dividends

 

5.Double taxation agreements (DTA) based on the OECD model

- The tax treatment of: dividends, interest, royalties, capital gains, other income

- DTA and corporate investment and financing decisions

 

6.International tax planning and anti-abuse clauses 

- what is tax planning?

- why do anti abuse clauses exist?

- how is international tax planning affected by these clauses?

 

7.Transfer pricing

- what is the nature of transfer pricing?

- methods used in transfer pricing

- transfer pricing reports

- tax audits and TP

Assessment Methods

Assessment
Periodic or by final exam as given in the course information: 100.0%

Bibliography

Martins, António and Taborda, Daniel (2017), Taxes and management: an introduction, e-book, Coimbra, Almedina, pp. 110.

http://www.almedina.net/catalog/ebook_info.php?ebooks_id=97897240720506

 

Michael Lang, Pasquale Pistone, Josef Schuch, Claus Staringer (2020) Introduction to European Tax Law on Direct Taxation, Sixth edition, Spiramus ed.

 

Angharad Miller and Lynne, Oats (2020) Principles of International Taxation, Bloomsbury