The course deals with the most recent chapter of international taxation that is dominated by the OECD/G20 Base Erosion and Profit Shifting (BEPS) project initiated in 2013. The BEPS project aims at countering aggressive tax planning, tax base eroding and profit shifting activities by multinational enterprises (MNEs). The course introduces students into MNE tax planning through which they make use of loopholes in the international tax rules and exploit mismatches between domestic tax systems to reduce their overall tax liability. It provides an insight into MNE tax planning through case studies and examines the measures that the OECD/G20/Inclusive Framework put forward to fight aggressive tax planning under the two phases of the BEPS project. It will explain the purpose and operation of various anti-avoidance rules that were introduced into domestic tax laws as a result of the first phase of the BEPS project. In addition, it will examine the second phase of the BEPS project that proposed fundamental changes to the international tax rules going beyond the fight against profit shifting and that is still awaiting implementation. Parallel efforts and the implementation of anti-BEPS measures in the EU will also be examined during the course.

The students will get familiar with the essential forms and objectives of tax planning by multinational enterprises. They will understand why it is important to curtail aggressive tax planning and tax avoidance and what the legal means and instruments are through which the latter is realized. In addition, the students will get a basic understanding of the fundamental reform of the international tax system that is currently ongoing under the two pillar-solution agreed on in 2021 by the vast majority of nations and what the stakes are in this reform in terms of the allocation of taxing rights between nations and the future of tax competition.

> 70% attendance requirement

Lecture, case studies, group presentations by students, moderated whole-class and group discussions

Prerequisites to pass the course:

• Attendance, preparation for and active participation in the classes (10% of the final grade)
• Group presentation (15% of the final grade)
• Written exam (75% of the final grade)

The Seminar requires basic knowledge of:

• company taxation in an international context

• the OECD Model Tax Convention and

• EU direct tax law