After this course,students are able to:

• Analyze independently complex international tax law questions
• Evaluate comprehensive, international fact cases concerning international tax law in thecontext of a tax treaty negotiation
• Develop an own opinion related to legal questions on the basis of literature and judicial opinion
• Discuss controversial issues on a high academic level
• Defend an opinion in an academic discussion and in a simulated tax treaty negotiation

> 80% studentische Anwesenheit

1. Active participation in the analysis of the OECD Model Convention (10%).
2. Motivated cooperation in the qualification process for membership in the negotiation team (40%).
3. Core activities (50%):
   - for students in the negotiation team the main evaluation basis will be their ability to present and defend the Austrian treaty position in the video conference with Brazil;
   - for the other students the main evaluation will be based on a written summary with a detailed analysis of the key issues of the negotiations;
   - for the "drafter" who is a member of the negotiation team but not actively involved in the oral negotiations the main evaluation will be based on his/her ability to handle the e-mail correspondence and the drafting of alternative provisions during the negotiations as well as the quality of the final text of the convention to be drafted in accordance with the outcome of the negotiations.
4. Although the final evaluation will be based primarily on the grading of the core activities, assessment points can be gained in activities mentioned under 1 and 2, which will be taken into account where the assessment of the core   activity may fall between two grades.