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Course

International Tax: Design and Structure - ATAX0428

Faculty: Australian School of Business

School: Australian School of Taxation and Business Law

Course Outline: ATAX0428 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 9255 or 9260 or 9245 or 9200 or 5740 or 9210 or 9230 or 9257 or 9231 or 5231

Excluded: ATAX0328, ATAX0528, ATAX0628

CSS Contribution Charge: 3 (more info)

Tuition Fee: See Tuition Fee Schedule

Further Information: See Class Timetable

View course information for previous years.

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

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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