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International Tax: Anti-Avoidance - ATAX0408
Library

 
Faculty: Australian School of Business
 
 
School:  Australian School of Taxation and Business Law
 
 
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, 9255, 9200, 9210, 9230 or 5740 or 9257 or 9231 or 5231
 
 
Excluded: ATAX0308, ATAX0508
 
 
CSS Contribution Charge:Band 3 (more info)
 
 
Tuition Fee:See Tuition Fee Schedule
 
 
Further Information: See Class Timetable
 
 

Description

International Taxation comprises a complex body of learning which is relevant to any cross border event whether that be in the form of cross border investment or cross border movement of people. This course exposes participants to the main aspects of the law which are relevant specifically to preventing avoidance of taxpayer obligations in respect of Australia's international taxation jurisdiction. The areas covered need to be clearly understood by anyone dealing with cross border income flows in order to avoid inadvertently falling into an unexpected trap created by these provisions.


Recommended Prior Knowledge

ATAX0405 Taxation of Trusts
ATAX0411 Taxation of Capital Gains
ATAX0420 Principles of Australian International Taxation

Students without this prior knowledge may find that they need to take steps to ensure adequate understanding of the related area. Note: as some area of tax law are interrelated in some courses, we recommend that students either have prior knowledge of the related area or study another course in that area concurrently.

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

Main Topics

  • Taxation of deferred foreign income - an overview
  • CFC's, control and attributable taxpayers
  • Active income test
  • CFC-attributable income
  • Dividends, exemptions and foreign tax credits
  • Second tier CFC provisions and deemed dividends
  • Non resident trusts (excluding FIFs)
  • Foreign investment funds
  • Other anti avoidance measures
  • Record keeping requirements

Assessment

1 Research Paper
1 Exam

Course Texts

Prescribed
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.

Recommended
Refer to Course Profile supplied by Lecturer.

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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.