This course encompasses various topics pertinent to international business taxation, tax accounting, and tax management:

• Examination of existing tax systems worldwide alongside alternative concepts and approaches to business taxation.
• Exploration of different methods for calculating, applying, and assessing effective tax rates.
• Analysis of existing tax disclosure requirements, including financial statement information, public country-by-country reports, and tax strategy disclosures.
• Study of tax planning within multinational enterprises, along with corresponding anti-avoidance rules, which include:
  1. Locational decisions, taking into account statutory and effective tax rates.
  2. Assessment of tax burden disparities for inbound and outbound investments based on legal structure (e.g., permanent establishment/corporate/non-corporate forms).
  3. Evaluation of tax burden variances for cross-border financing (e.g., equity/debt/hybrid financing).
  4. Cross-border loss offsetting and utilization.
  5. Additional selected topics derived from current Austrian and international tax laws.
• In-depth examination of intra-group contracting, covering:
  1. Transfer pricing.
  2. Re-allocation of functions.
  3. Cross-border financing.
• Exploration of tax planning based on qualification conflicts arising between different tax systems, along with corresponding anti-avoidance rules which include:
  1. Hybrid legal forms.
  2. Hybrid financing arrangements.
• Analysis of anti-abuse provisions and measures countering aggressive tax planning on both unilateral and multilateral levels, incorporating Austrian laws, EU regulations, and OECD initiatives.
• Examination of the impact of the ongoing international tax revolution on firms, including:
  1. OECD Pillar 1 and Pillar 2 (global minimum taxation).
  2. European Union initiatives such as BEFIT and DEBRA.

Social and Individual Competencies:

Upon completion of this course, students will be able to:

• Critically assess questions pertaining to taxation in a cross-border context and their effects on the firm.
• Actively participate in discussions related to taxation in a cross-border context.

Competencies in Scientific Research:

Upon completion of this course, students will be able to:

• Evaluate scientific research concerning international tax management and tax accounting.
• Assess and apply legal norms, administrative rules, legal precedents, and double tax treaties concerning questions related to taxation in a cross-border context.
• Quantify the effects of international tax rules on the firm and its decision-making processes.
• Identify and apply scientifically sound methods to evaluate and quantify alternatives related to taxation in a cross-border context.

attendance requirement : 50%

The course assessment will be based on a comprehensive examination covering a total of three courses in "Business Taxation" (Modulprüfung Betriebswirtschaftliche Steuerlehre). This approach ensures that students develop connections across different sub-areas of tax management and accounting. Attendance in all three courses (active participation, with a requirement of 50% attendance) is mandatory to take the Modulprüfung.

The Modulprüfung encompasses the content of the following three courses:

• Taxation, Investment, and Financing Decisions (Steuern und Investitions- und Finanzierungsentscheidungen),
• Business Restructuring (Umgründungen),
• International Business Taxation.

The Modulprüfung has a duration of three hours. The examination primarily focuses on case studies where students must provide numerical or argumentative solutions to presented problems. Additionally, students must reference relevant legal norms necessary to derive the correct solution. Theoretical study questions will also be included in the examination. The minimum requirement to pass the Modulprüfung is achieving more than 50% of the total points, and additionally, obtaining at least 1/3 of the maximum points per course.

Furthermore, it is possible to enhance the grade of the Modulprüfung with participation points earned from each of the three courses, provided that the minimum requirements are met. Students who fail the Modulprüfung cannot benefit from participation points. A total of up to 18 points can be attained, with a maximum of 6 points collectible per course. To receive all participation points in the International Business Taxation course, students must actively participate in discussions during 6 out of 8 sessions. For preparation, students will receive course materials and respective questions ahead of each session. Students must indicate in advance whether they are prepared for active participation.

To participate, a prerequisite is the successful completion of the PI "Introduction to the Master's Program." Additionally, admission to the "Modulprüfung" requires successful completion of the course "Introduction to Tax Management," as well as active participation in the courses "Business Restructuring," "Taxation, Investment, and Financing Decisions," and "International Business Taxation."

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- 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