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International Tax: Design and Structure - ATAX0428
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 9255 or 9260 or 9245 or 9200 or 5740 or 9210 or 9230
 
 
Excluded: ATAX0328, ATAX0528, ATAX0628
 
 
Fee Band: 3 (more info)
 
 
Further Information: See Class Timetable
 
 

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

  • To explain the fundamentals of international tax and how it works in practice
  • To understand fundamental tax concepts such as: residence; source; double taxation and double taxation relief; withholding tax; Double Tax Agreements; international tax avoidance and the measures adopted to combat it
  • To focus on how residents and non-residents are taxed in different jurisdictions
  • To analyse the different approaches that jurisdictions can adopt in addressing these issues, the different design imperatives that led to these different approaches and the different outcomes (from both a practical and policy perspective) that they produce

Main Topics

  • Introduction and conceptual framework
  • Taxation of residents and double tax relief
  • Taxation of non-residents
  • International anti-avoidance measures
  • Double Tax Agreements (DTAs)
  • Additional case studies

Assessment

1 Research Paper
1 Exam

Course Texts

Information regarding the Atax Textbook Lists for Semester 1 will be available on the UNSW Bookshop website from 1 February.

Information regarding the Atax Textbook Lists for Semester 2 will be available on the UNSW Bookshop website from 1 July.

Order from UNSW Bookshop:
http://www.bookshop.unsw.edu.au/atax.html

URL for this page:

© 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.