Syllabus

Title
5444 International Business Taxation
Instructors
Univ.Prof. Dr. Eva Eberhartinger, LL.M.(Exeter), Ayse Sule Özdogan, M.Sc.
Contact details
ayse.sule.oezdogan@wu.ac.at
Type
MPV
Weekly hours
2
Language of instruction
Englisch
Registration
02/15/21 to 03/15/21
Registration via LPIS
Notes to the course
Subject(s) Master Programs
International Business Taxation
Dates
Day Date Time Room
Monday 03/22/21 08:30 AM - 12:30 PM Online-Einheit
Thursday 03/25/21 08:30 AM - 12:30 PM Online-Einheit
Thursday 04/08/21 08:30 AM - 12:30 PM Online-Einheit
Monday 04/12/21 08:30 AM - 12:30 PM Online-Einheit
Wednesday 04/14/21 08:30 AM - 12:30 PM Online-Einheit
Monday 04/19/21 08:30 AM - 12:30 PM Online-Einheit
Thursday 06/17/21 05:30 PM - 08:30 PM TC.0.10 Audimax

On this page:

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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

- Existing tax disclosure requirements, such as financial statement information, public country-by-country reports, and tax strategy disclosure

- Tax planning in multinational enterprises, and corresponding anti-avoidance rules. This includes:

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

- Intra-group contracting, including:

  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 Austrian laws, EU rules, and OECD initiatives

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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

 

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Attendance requirements

attendance requirement : 50%

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Teaching/learning method(s)

This course covers international tax laws, theory of the effect of tax law on corporate decisions, and respective case studies. The online format of the class requires students to prepare carefully for each unit, according to the time schedule and plan. For class preparation, students will be provided with literature references, slides, comments on slides and cases, and video tutorials. The online classes will be used for clarifying student´s questions (q&a), which may remain after careful preparations.

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Assessment

The course will be graded on the basis of a comprehensive examiniation covering in total three courses in "Business Taxation" (Modulprüfung Betriebswirtschaftliche Steuerlehre). This ensures that students develop linkages across the different sub-areas of Tax Management. The Modulprüfung covers the following three courses:

- Investment, Finance & Taxation,

- Business Restructuring,

- International Business Taxation .

The Modulprüfung has 3 hours of working time. The focus of the examination is 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 will also 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.

There will be no additional, separate examen for this class specifically.

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Readings
1 Author: Eberhartinger E. / Pummerer E.
Title:

Handbuch der Österreichischen Steuerlehre, Band V, Internationale Steuerplanung

Publisher: LexisNexis
Edition: 3. Auflage
Year: 2020
Content relevant for class examination: Yes
Content relevant for diploma examination: Yes
Recommendation: Essential reading for all students
Type: Book
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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: 2021-02-03



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