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Course

International Tax: Anti-Avoidance - ATAX0408

Faculty: Australian School of Business

School: Australian School of Taxation and Business Law

Course Outline: ATAX0408 Course Outline

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: 3 (more info)

Tuition Fee: See Tuition Fee Schedule

Further Information: See Class Timetable

View course information for previous years.

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

Course Texts

Textbook lists for ATAX courses will be available from the UNSW Bookshop from 1 February for Semester 1 courses and from 1 July for Semester 2 courses.
Library

Study Levels

Undergraduate Study Postgraudate Study Postgraduate Research Study Non-Award Study

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