This course introduces bachelors’ students to international tax law. The course is aimed at students who have some knowledge of a domestic tax system.

While this course will focus on the articles of the OECD Model Tax Convention, important differences with the UN Model will be highlighted. Further, the interaction of some EU law directives with tax treaties will be considered. Finally, students will also be encouraged to make the first steps into developing critical thinking about the international tax agenda.

The course consists of the following 7 units: 

Unit 1: Fundamental concepts

Unit 2: Scope of tax treaties & anti-avoidance

Unit 3: Methods of elimination of double taxation, non-discrimination & dispute resolution

Unit 4:  Allocation rules part 1 – Business income and income from immovable property

Unit 5: Allocation rules part 2 – Passive income

Unit 6: Allocation rules part 3 – Personal services

Unit 7: Integrated case study & international tax agenda/current developments

On completion of this course students should be able to determine and describe the allocation of taxing rights of a given scenario by applying the facts of a case to the relevant provisions of the OECD or UN Model tax treaties.

Please consult the course outline on the online learning platform for a more detailed description of the learning outcomes.

At most, 2 contact sessions may be missed.

Attendance of the first contact session is mandatory as well as attendance of the session at which the student’s group has been allocated to present.

If you are aware of any clashes or other reasons why you might not be able to attend a particular session, please notify the course instructors as soon as possible so that they can determine how they can best accommodate you.

This course uses a variety of teaching/learning methods.

Every unit of this course (excluding the first and the last) will consist of two parts:

1. An interactive lecture
2. 50 min where the assigned group will present their proposed solution to a case study (which will be made available a week before the contact session) followed by a discussion.

The lecture component aims to explain the more challenging theoretical concepts of the prescribed study material which the students are expected to have engaged with prior to the lecture.

As the groupwork consists of solving case studies, students are given the opportunity to practice their application of the theory to a set of facts. The groupwork component of this course facilitates students’ learning through peer learning. As the group’s proposed solution will also be discussed in class, students will receive feedback during the course regarding their performance.

Students are strongly encouraged to actively participate in the lecture as well as pose questions to the group presenting.

The student’s final grade for the course will comprised as followed:

• 30% weighting for the group assignment and
• 70% weighting for the exam.

All students are required to write the first exam. The second exam (scheduled for 11 June 2024 from 14:00 until 16:00) is only available as a supplementary exam for students who were sick for the first exam or have not passed the course after the first exam.

For students of Wirtschaftsrecht: During the registration period places are allocated on the "first-come, first-served" basis. After the registration period, students from the waiting list who do not yet have a valid registration will be assigned to available places based on the progress in their studies. Preference will be given to students who have successfully completed the introduction to tax law course (“Einfüring in das Steuerrecht”), the basic tax law course (“Grundkurs Steuerrecht”) and the advanced course ("Vertiefungskurs Steuerrecht").

NB! The deadline for deregistration requests is 17:00 on the day after the first contact session.

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.

To be able to derive the maximum value from this course, it is recommended that students have had exposure to a course dealing with a domestic tax system. Basic knowledge of a domestic tax law system would be useful before embarking on the study of international tax law.

For BaWiRe students: it is HIGHLY RECOMMENDED that you have completed the “Einfürung in das Steurrecht” course before taking this course and it is recommended that you have completed the “Grundkurs Steurrecht” and the “Vertiefungskurs Steurrecht”.

Via email

All course communication will take place via the Canvas online platform. The announcement function in Canvas will be used. Please either regularly check for announcements in Canvas or ensure that your individual Canvas settings are such that you receive email notifications for announcements made on Canvas.

When communicating with the instructors, please use your WU email address.

• 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