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 5 out of 6 content sessions in order to pass the course. No reason for absence is necessary.

The class comprises 12 content sessions with 1,5 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. Students are expected to actively involve in the classroom discussion.

35% Midterm Exam: The midterm exam covers the first part of the course and will take place on April 26th, 2023.

45% 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 June 21st 2023. 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

Please log in with your WU account to use all functionalities of read!t. For off-campus access to our licensed electronic resources, remember to activate your VPN connection connection. In case you encounter any technical problems or have questions regarding read!t, please feel free to contact the library at readinglists@wu.ac.at.

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

Office hours, schedule via e-mail!