UNSW Handbook Course - International Tax: Anti-Avoidance

International Tax: Anti-Avoidance - ATAX0308


	Faculty: Faculty of Law
	School: Australian School of Taxation
	Course Outline: See below
	Campus: ATAX Campus
	Career: Postgraduate
	Units of Credit: 6
	EFTSL: 0.125 (more info)
	Contact Hours per Week: 0
	Enrolment Requirements:
	Restricted to students enrolled in Program 5540
	Fee Band: 1 (more info)
	Further Information: See Class Timetable

Description

This course exposes students to the main aspects of the law which are specifically relevant to anti-avoidance of international taxation. It aims to instil a clear understanding of these aspects so that students, when dealing with cross border income flows in their roles as tax professionals, may avoid inadvertently falling into an unexpected trap created by these provisions. Specifically, students studying this course will be required to come to grips with Australia's: (i) controlled foreign company ('CFC') rules; (ii) foreign investment fund ('FIF') rules; (iii) transferor trust rules and (iv) the thin capitalisation and transfer pricing rules. :

Recommended Prior Knowledge

ATAX0305 Taxation of Trusts
ATAX0311 Taxation of Capital Gains
ATAX0320 Principles of Australian International Taxation
Or Equivalent

Course Objectives

To familiarise students with the basics of the attribution (Controlled Foreign Corporations, Transferor Trusts and Foreign Investment Funds), thin capitalisation, and transfer pricing measures.
To provide a detailed study of the attribution rules, focusing on concepts of control, active income and methods of attribution.
To provide a brief review of international comparisons of anti-avoidance measures.

Modes of Delivery

Flexible Learning

Assessment

Graduate Diploma in Advanced Taxation

Assignment 1	2000-3000 words	20%
Assignment 2	2000-3000 words	20%
Final Examination	Open book	60%

Pass Requirements

50 per cent or more of the total marks available in the course and
at least 40 per cent of the marks available for the final examination in the course.

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