International Business Tax Law

This module is gives students an introduction to international and European tax law.

The module will start with the history of international taxation, double taxation, and tax treaties. The primary focus will be on the OECD Model Tax Convention and the main business articles therein. The interpretation of tax treaties and the main business taxation articles will be studied. Recent developments in international tax law will be outlined.

The history of direct taxation within the European Union will be outlined, starting with EU primary law and its impact on Member States’ direct taxation, seen through fundamental cases and case studies. Key EU tax directives in the area of direct taxation and fiscal state aid will be introduced.

Throughout the module, there will be discussions of tax competition and cooperation, emerging trends in international and European taxation and a consideration of the role of businesses as taxpayers within European and global society.

Previous knowledge of taxation or tax law is not required.

Learning Outcomes:

On successful completion of this module, students should be able to:

• Identify and critically engage with the jurisdictional bases upon which states impose business taxation with particular reference to the OECD Model Convention
• Critically evaluate and discuss key business taxation articles of the OECD Model Convention
• Critically evaluate and discuss international tax law case law across a number of jurisdictions
• Critically evaluate and discuss key EU measures in the area of direct taxation
• Critically evaluate and discuss key jurisprudence of the CJEU in the area of direct taxation
• Critically evaluate and discuss recent developments in international tax law.

Assessment:

• Two Essays (2,500 words each) – 47% each
• Attendance in class – 6% (measured via attendance list)

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