0084 Simulated Tax Treaty Negotiations with Brazil
Dr. Jan Szczepanski, Laura Turcan, LL.M. (WU)
Weekly hours
Language of instruction
08/31/23 to 09/22/23
Registration via LPIS
Notes to the course
Subject(s) Master Programs
Day Date Time Room
Friday 10/13/23 01:00 PM - 05:00 PM D3.2.243
Friday 10/20/23 01:00 PM - 05:00 PM D3.2.243
Saturday 11/04/23 09:00 AM - 01:00 PM D3.2.243
Friday 11/17/23 01:00 PM - 05:00 PM D3.2.243
Saturday 11/18/23 01:00 PM - 05:00 PM D3.2.243

The Seminar in Tax Law (Fachseminar aus Steuerrecht) will be held in English only and will be conducted in cooperation with the University of Sao Paolo. In that context a joint video conference shall take place in which it is intended that students of both universities lead simulated tax treaty negotiations.

Learning outcomes

After this course, students are able to:

- Analyse complex international tax law questions independently

- Evaluate comprehensive, international fact cases concerning international tax law in the context of a tax treaty negotiation

- Develop an own opinion related to legal questions on the basis of literature and judicial opinion

- Discuss controversial issues on a high academic level

- Defend an opinion in an academic discussion and in a simulated tax treaty negotiation 

Attendance requirements

100% attendance on the two negotiation days, > 70% attendance for the rest of the course after consultation with the instructors.

Teaching/learning method(s)
Lecture, discussion, negotiation.

1. Active participation in the analysis of the OECD Model Convention (10%).

2. Motivated cooperation in the qualification process for membership in the negotiation team (40%).

3. Core activities (50%):

a. for students in the negotiation team the main evaluation basis will be their ability to present and defend the   Austrian treaty position in the videoconference with the Netherlands;

b. for the other students the main evaluation will be based on a written summary with a detailed analysis of the key issues of the negotiations;

c. for the "drafter" who is a member of the negotiation team but not actively involved in the oral negotiations the main evaluation will be based on his/her ability to handle the e-mail correspondence and the drafting of the alternative provisions during the negotiations as well as the quality of the final text of the convention to be drafted in accordance with the outcome of the negotiations.

Although the final evaluation will be based primarily on the grading of the core activities assessment points can be gained in activities mentioned in 1 and 2, which will be taken into account where the assessment of the core activity may fall between two grades.


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Recommended previous knowledge and skills

In order to prepare for this event it is essential that all participants are familiar with the OECD Model Tax Convention. Participants therefore should make a “self-test” in advance of the course in order to check whether he/she is in a position to give brief explanations with regard to each of the Articles of the OECD Model Tax Convention in the English language. The preparation is necessary to ensure discussions on a high academic level.



The lecture is held by Dr. Jan Szczepanski Laura Turcan, LL.M. The negotiation partner varies each semester.

Additional information on MyLEARN.
    1. When writing a seminar paper, the introduction must contain a declaration of the use of AI. If no form of AI was used, a note to this effect is sufficient. If AI was used, the introduction must explain accordingly where and in what form.
    2. For seminar papers, increased attention will be paid to:
  • Whether the processed legal status is up-to-date
  • Correct/existent citations
  • Correct use of abbreviations
  • Comprehension
  • Errors in the outline
Unit details
Unit Date Contents
1 Preparatory Part I
2 Preparatory Part II
3 Preparatory Part III
4 Treaty Negotiation Part
5 Treaty Negotiation Part
6 Evaluation Part
Last edited: 2023-10-03