5194 International Business Taxation
Bernhard Winkelbauer, MSc (WU), Xixi Zhang, M.Sc.
Weekly hours
Language of instruction
02/13/23 to 03/19/23
Registration via LPIS
Notes to the course
Subject(s) Master Programs
Day Date Time Room
Wednesday 03/29/23 02:30 PM - 05:30 PM TC.2.02
Thursday 03/30/23 12:30 PM - 03:30 PM TC.1.02
Friday 03/31/23 09:30 AM - 12:30 PM TC.1.01 OeNB
Tuesday 04/11/23 09:30 AM - 12:30 PM TC.1.02
Wednesday 04/12/23 01:30 PM - 04:30 PM TC.0.03 WIENER STÄDTISCHE
Friday 04/14/23 09:30 AM - 12:30 PM TC.1.01 OeNB
Tuesday 04/18/23 09:30 AM - 12:30 PM TC.2.01
Friday 04/21/23 01:30 PM - 04:30 PM TC.2.01

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

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 covers international tax laws, theory of the effect of tax law on corporate decisions, and respective case studies.

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.


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. Attendance in all 3 courses (active participation, 50% attendance) is required to take the Modulprüfung.

The Modulprüfung covers the following three courses:

- Taxation, Investment and Financing Decisions,

- 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.


Prerequisites for participation and waiting lists

Prerequisite for participation is the positive completion of the PI "Introduction to the Master's Program".

Admission to the "Modulprüfung" additionally requires positive completion of the course "Introduction to Tax Management" and successful participation in the courses "Reorganizations", "Taxation, Investment and Financing Decisions" and "International Business Taxation".


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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: 2023-02-01