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International Tax: Design and Structure - ATAX0428 | |||||||||||||||||||||||||||||||||||||||||||||||
Description 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 ATAX0320/0420/0520 Principles of Australian International Taxation (or an equivalent course dealing with another tax jurisdiction) would be most desirable.
Course Objectives
Main Topics
Assessment 1 research paper
1 exam Course Texts Prescribed 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:
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