INTERNATIONAL TAXATION 

Prof. FRANZE’

Program

1. Introduction to International tax law (3 h): it provides an overview of the basics of international tax jurisdiction and of (the relief of) juridical and economic double taxation.
2. Double Taxation and its Avoidance: the Legal Framework of Double Tax Treaties (3 h): it comprises a general analysis of content, elements, structure and application of double tax treaties.
3. Double Tax Treaties and Changes to Domestic Law. Double Tax Treaties and European Law (3 h): it focuses on the impact of double taxation treaties on domestic and European law (i.e., the legal consequences of the “Treaty Override”).
4. Interpretation of Double Tax treaties (3 h): it focuses on principles for interpretation of international tax agreements, including the role of OECD Model Treaty and its Commentary.
5. Scope of the OECD Model Treaty and its general definitions (3 h): it includes an analysis of Arts. 1 to 5 of the OECD Model Treaty
6. OECD Model’s treaty attribution rules (9 h): the treaty attribution rules are analysed with regard to business and professional income (Art. 7), transportation income (Art. 8), real property income (Art. 6), dividends (Art. 10), interest (Art. 11), royalties (Art. 12), capital gains (Art. 13), services, including employment and pension income (Art. 15 through 20), other income (Art. 21) capital (Art. 22) and double taxation relief (Art. 23A-B).
7. Double Tax Treaties: cases (3 h): e-commerce, beneficial ownership & international tax avoidance, partnerships, triangular cases, financial instruments and international trade dispute resolution in tax matters.
8. Transfer Pricing Rules in International Taxation (6 h): the course develops a sense of economic dimensions of legal issues and provides them with the tools to undertake the necessary analyses of advanced transfer pricing issues, both under the guidance of the OECD Transfer Pricing Guidelines and the US Regulations on Transfer Pricing.
9. International Tax Planning (6 h): this course provides a survey of basic techniques employed in international tax planning. It covers basic tax planning techniques for multinational groups, with insights in the domestic legislation of major economies and case law on the subject. Supply chain management structures are discussed, taking into account the basic principles of domestic legislations and their interaction with tax treaties. It provides detailed analyses of acquisition techniques, with a special focus on private equity and venture capital. The course also deals with the tax treatment of derivatives and other financial instruments often used in practice and it covers in general terms the accounting issues arising in relation to the above-mentioned subjects.
10. International Tax Avoidance and Evasion and the Role of Exchange of Information (3 h): this course emphasizes the role of the exchange of information in counteracting international tax avoidance and evasion.

STRATEGIC PLANNING

Prof. MCDONNELL from  University of Technology – Sydney

1. Introduction

The course is an insight into the thought processes of general managers. It applies knowledge and skills gained from subjects such as, financial management and the generic business subjects to various industry settings, which will give students an understanding of the strategic planning processes and frameworks in industry. This subject will give students the ability to identify and comprehend the broad view of current objectives and consequent strategies deployed when working in a large or small organisations and it will enable them to use strategic planning skills in all aspects of their working and personal life.

2. Subject Objectives

On successful completion of this subject students should be able to:

1. understand the need for, and the frameworks used in, strategic planning in industry and government;

2. identify and discuss the interests of stakeholders in strategy formulation, and how these sometimes conflicting viewpoints can be integrated into a coherent strategy;

3. plan to implement these strategies;

4. apply strategic management principles and concepts to industry firms by means of the production of a strategic plan;

5. examine ethical, environmental and technological issues impacting on the management of organisations;

6. define and use correctly the various terms and concepts used in strategic planning and management;

7. construct a budget and a financial management strategy that can quantify a strategic plan;

3. Subject Structure

This subject is presented over four days, each consisting of two 2.5 hour sessions, each of which will focus on an aspect of strategic management.

To ensure that the topic has meaning and relevance, students are to choose a firm with which they are familiar and use the firm’s context to construct a strategic plan for it.

In other words, all aspects of strategic management that are discussed during the subject will be placed into the context of the chosen firm or organisation.

4. Text and Other Subject Materials

The text used as background for this subject is:

Johnson, G., Scholes, K. & Whittington, R., (2011) Exploring Corporate Strategy: 9th ed., Pearson Education, Harrow, U.K.

Another recommended other text is:

Hubbard, G., & Beamish, P., (2011) Strategic Management: Thinking, Analysis, Action 4th ed. Pearson, Australia