International Tax: Design and Structure - TABL5528

Faculty: UNSW Business School

School: School of Taxation and Business Law

Course Outline: TABL5528 Course Outline

Campus: Sydney

Career: Postgraduate

Units of Credit: 6

EFTSL: 0.12500 (more info)

Indicative Contact Hours per Week: 0

Enrolment Requirements:

Enrolled in programs 5231, 5740, 8428, 9200, 9210, 9231 and completed TABL5551 or TABL5901 or equivalent; OR enrolled in programs 5540, 9255, 9257, or 9260; OR in streams TABLBS9250, TABLDS9250, TABLES9250.

Excluded: ATAX0328, ATAX0528, TABL3028, ATAX0628

CSS Contribution Charge: 3 (more info)

Tuition Fee: See Tuition Fee Schedule

Further Information: See Class Timetable

View course information for previous years.


This course addresses the fundamental building blocks of those parts of domestic income tax systems that deal with cross border investment and income flows. A comparative approach will be adopted in order to highlight the different approaches that can be, and are, adopted by different jurisdictions in dealing with these issues. This comparative approach will extend to consideration of the outcomes that different approaches produce and the influences (such as tax policy, historical and/or cultural factors) which have contributed to the adoption of these differing approaches. Issues dealt with in the course include: jurisdictional nexus rules (residence and source); taxation of cross border active income flows; taxation of cross border passive income flows; unilateral measures adopted for the relief of double taxation; host country and home country considerations in taxing cross border business activities; international anti-avoidance provisions; and double tax treaties.

Recommended Prior Knowledge

There are no formal prerequisites, however an understanding of the material covered in TABL5520 Principles of Australian International Taxation (or an equivalent course dealing with another tax jurisdiction) would be most desirable.
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