Syllabus

Title
5890 International Business Taxation
Instructors
Univ.Prof. Dr. Eva Eberhartinger, LL.M.(Exeter), Raffael Speitmann, M.Sc.
Type
MPV
Weekly hours
2
Language of instruction
Englisch
Registration
01/22/19 to 02/23/19
Registration via LPIS
Notes to the course
Subject(s) Master Programs
Dates
Day Date Time Room
Thursday 02/28/19 10:00 AM - 01:30 PM D3.0.233
Thursday 03/07/19 10:00 AM - 01:00 PM D3.0.233
Thursday 03/14/19 10:00 AM - 01:30 PM D3.0.233
Thursday 03/21/19 10:00 AM - 01:30 PM D3.0.233
Thursday 04/11/19 10:00 AM - 01:30 PM D3.0.233
Thursday 05/02/19 10:00 AM - 01:30 PM D3.0.233
Thursday 05/16/19 10:00 AM - 12:00 PM D3.0.233
Contents

This course includes the following broad topics all related to international business taxation and international tax management:

- Existing tax systems around the world as well as alternative concepts and approaches to business taxation

- Different concepts to calculate and apply effective tax rates

- Tax planning and tax management within multinational enterprises. This includes:

  1. Locational decisions under consideration of statutory and effective tax rates, tax havens, treaty shopping, etc.
  2. Determination of tax burden differences for inbound investment conditional on legal form (i.e. PE/corporate forms/non-corporate forms)
  3. Determination of tax burden differences for outbound investment conditional on legal form (i.e. PE/corporate forms/non-corporate forms)
  4. Determination of tax burden differences for cross-border financing (i.e. equity/debt/hybrid financing)
  5. Cross-border loss offset and loss utilization
  6. Additional selected topics based on current Austrian and international tax law

- Tax optimal intra-group contracting. This includes the following aspects:

  1. Transfer pricing
  2. Re-allocaiton of functions
  3. Cross-border financing

- Qualification conflicts between different tax systemts. This includes the following aspects:

  1. Hybrid legal forms
  2. Hybrid financing arrangements

- Anti-abuse provisions and provisions countering aggressive tax planning on a unilateral and multilateral level. This includes regulation of the European Union as well as of the OECD (e.g., BEPS).

Learning outcomes

Social and individual competences:

After completing this course, students are able:

- to critically assess questions related to taxation in a cross-border context

- to actively participate in the discussion process related to taxation in a cross-broder context

Competences in scientific research:

After completing this course, students are able:

- to evaluate scientific research related to international tax management and tax accounting

- to evaluate and apply legal norms, administrative rules, legal precedent and double tax treaties on questions related to taxation in a cross-border context

- to identify and apply the scientifically correct method to evaluate alternatives related to taxation in a cross-border context

 

Attendance requirements

attendance requirement : 50%

Teaching/learning method(s)

This course consists of a lecture provided by the instructor and is supplemented by an in-class discussion of case studies.

The lecture mainly includes the theoretical foundations of international tax management and how they are related to international tax planning.

The case studies apply the theoretical knowledge to relevant questions and problems related to international tax management.

Assessment

The course will be graded on the basis of a subject examiniation covering two additional courses of the subject "Tax Management". This ensures that students develop linkages across the different sub-areas of Tax Management.

The subject examination covers the following courses:

- Investment, Finance & Taxation,

- Business Restructuring,

- International Business Taxation .

 

The subject examination has 3 hours of working time. The focus of the subject examination is put on case studies were students have to provide numerical or argumentative solutions to the problems presented. Furthermore, students have to indicate relevant legal norms necessary to derive the correct solution. Theoretical study questions may to a lesser extent be part of the subject examination. Students pass the exam if they achieve more than 50 % of the total points. In addition, students are required to achieve at least 1/3 of the maximum points per course.

Recommended previous knowledge and skills

- Advanced knowledge in Austrian tax law and Austrian corporate income tax law

- Knowledge in international tax law

- Advanced knowledge in business taxation and tax management

Last edited: 2019-02-25



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