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
• Introduction to International Tax Law
• Tax planning in multinational enterprises, and corresponding anti-avoidance rules. This includes:
  • Locational decisions under consideration of statutory and effective tax rates
  • Determination of tax burden differences for inbound and outbound investment conditional on legal form (i.e. PE/corporate forms/non-corporate forms)
  • Determination of tax burden differences for cross-border financing (i.e. equity/debt/hybrid financing)
  • Cross-border loss offset and loss utilization
  • Additional selected topics based on current Austrian and international tax law
• Intra-group contracting, including:
  • Transfer pricing
  • Re-allocation of functions
  • Cross-border financing
• Qualification conflicts between different tax systems. This includes the following aspects:
  • Hybrid legal forms
  • 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

The instructor will present these topics in class and discuss them together with the students.

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

Students are required to attend at least 7 out of 9 content sessions in order to pass the course. No reason for absence is necessary. If a student is absent in more than two sessions, a positive completion of the course is no longer possible.

The class comprises nine content sessions with 2 hours each (+ 1 introductory session, 1 mid-term exam, 1 final exam). During these sessions, the instructor discusses the relevant topics together with the students. The instructor presents the topics and outlines core concepts using practical examples and case studies. The students will also present case studies and examples. Moreover, the instructor outlines key findings in academic research and the connection to the topics covered in class. Students are expected to participate actively in the classroom discussion. Active student involvement will be essential for a successful completion of the course. Slides and relevant additional materials will be available via Learn@WU.

20% In-class Participation: The quality of students’ active participation in class will be evaluated. To achieve full in-class participation, nine participation points during the course are required. Students can earn these points by actively involving in the classroom discussion and by responding to questions raised by the instructor.

20% Group Presentation: Students will be asked to prepare the solution to examples / case studies related to a specific topic discussed in class. The instructor will assign students into groups and allocate a paper to each group. The group size will depend on the number of students enrolled in the class.

20% Midterm Exam: The midterm exam covers the first part of the course and will take place on April 14, 2021.

40% Final Exam: The final exam covers theory-based questions and problem-centered open questions. The final exam convers the entire content of the class and will take place on May 26, 2021. No retake will be offered.

Grading:

87.5% or more: 1 (excellent)

75% or more: 2 (good)

62.5% or more: 3 (satisfactory)

50.5% or more: 4 (sufficient)

50% or less: 5 (fail) - sorry

Successful completion of Course I of the Specialization and course „Financial Reporting and Analysis”

Office hours, schedule via e-mail!