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Principles of Australian International Tax - ATAX0420
Library

 
Faculty: Faculty of Law
 
 
School:  Australian School of Taxation
 
 
Course Outline: See below
 
 
Campus: ATAX Campus
 
 
Career: Postgraduate
 
 
Units of Credit: 6
 
 
EFTSL: 0.12500 (more info)
 
 
Indicative Contact Hours per Week: 0
 
 
Enrolment Requirements:
 
 
Restricted to students enrolled in Programs 9250 or 9260 or 9255
 
 
Equivalent: ATAX0320
 
 
Excluded: ATAX0320, ATAX0520, ATAX0620
 
 
Fee Band: 1 (more info)
 
 
Further Information: See Class Timetable
 
 

Description

This course provides a broad overview of the most important elements of Australian tax law as it affects international transactions (whether involving the movement of funds, of property or of people). It examines the policy issues in international taxation, the framework of Australian rules, the basis upon which Australian tax jurisdiction is exercised (ie, residence in Australia and source of income) and examines the manner in which Australia taxes Australian source income of non-residents and foreign source income of Australian residents (including foreign source income of controlled foreign corporations and trusts which is attributed to Australian resident controllers) as well as the operation of Australia's Double Tax Agreements and international anti avoidance provisions.


Recommended Prior Knowledge

None. Students are advised to complete this course or its equivalent before proceeding to other postgraduate courses dealing with off-shore elements of the Australian tax system.

Course Objectives

After completing this course you should be able to:
  • Summarise the framework of Australia's rules for taxation of residents and non residents
  • Identify key issues in the Australian tax treatment of residents in a given fact situation
  • Identify key issues in the Australian tax treatment of non residents in a given fact situation
  • Explain your response to the above issues both orally and in writing
  • Analyse the effects of Australian international tax rules using international tax policy considerations

Main Topics

  • Introduction to international tax issues
  • Residence rules
  • Source rules
  • Taxation of non-residents
  • Australian taxation of foreign source income of residents
  • International anti-avoidance provisions

Assessment

1 research paper
1 exam

Course Texts

Prescribed
There is no prescribed textbook for this course. Relevant readings will be provided in the Study Materials.

Acts
You must purchase or have access to the following publications:
  • Income Tax Assessment Act 1936
  • Income Tax Assessment Act 1997
  • International Tax Agreements Act 1953
Citation and Style Guides
The following is a selection of acceptable citation and style guides, which you may use as the basis for your written work. You must purchase or have access to one of the following publications:
  • Rozenberg P, Australian guide to uniform legal citation (Sydney: Lawbook Co, 2nd ed, 2003)
  • Stuhmcke A, Legal referencing (Sydney: Butterworths, 3rd ed, 2005)
  • Australian guide to legal citation (Melbourne University Law Review Association, 2nd ed, 2002) - Available from http://mulr.law.unimelb.edu.au/aglc.asp
Recommended
Below is a list of further references that you may find useful in this course. Purchase of recommended references is not compulsory. Selected references may be borrowed and dispatched to you through the Atax Book Borrowing Service (ABBS). This service will replace the Library collections previously held in Learning Centres.
  • Magney TW, Australia's Double Taxation Agreements - A critical appraisal of key issues (Sydney: Legal Books, 1994)
  • Magney TW, Source of Income, Paper presented at 10th Annual Tax Convention, NSW, Terrigal, 26-28 May 1978
  • Review of Business Taxation: A Tax System Redesigned, July 1999, (Ralph Report), available at http://www.rbt.treasury.gov.au
  • Board of Taxation, International Taxation: A Report to the Treasurer, Volume 1, February 2003, available at http://www.taxboard.gov.au

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© The University of New South Wales (CRICOS Provider No.: 00098G), 2004-2011. The information contained in this Handbook is indicative only. While every effort is made to keep this information up-to-date, the University reserves the right to discontinue or vary arrangements, programs and courses at any time without notice and at its discretion. While the University will try to avoid or minimise any inconvenience, changes may also be made to programs, courses and staff after enrolment. The University may also set limits on the number of students in a course.