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Course

Double Tax Agreements - ATAX0437

Faculty: Australian School of Business

School: Australian School of Taxation and Business Law

Course Outline: ATAX0437 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: ATAX0337, ATAX0537

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 provides a comprehensive and in depth study of Double Tax Agreements (DTAs). It addresses the influence of international models on the formulation of DTAs. The primary focus is on the OECD model which will be examined in detail, emphasising key issues such as treaty design and interpretation, dual residency, treatment of passive income flows and capital gains, and mechanisms to alleviate double tax. This will be followed by an examination of specific DTAs so as to illustrate key differences and similarities. The practical application of the DTAs will be considered in the context of numerous examples.


Recommended Prior Knowledge

Whilst there are no formal prerequisites, an understanding of the material covered in ATAX0420 Principles of Australian International Taxation would be most desirable.

Course Objectives

  • To give students an overview of Australia's Double Taxation Agreements ('DTAs')
  • To survey the key basic issues associated with DTAs including: taxes covered; taxpayers covered; classes and schedules of income/taxpayer; dual residency
  • To address and understand some more difficult issues including: treaty overrides; tripartite situations; class or schedule overlap

Main Topics

  • An introduction to Double Tax Agreements
  • The interpretation and structure of DTAs
  • Gateways to accessing DTAs - personal scope, taxes covered and residence
  • Business profits
  • Passive income flows under DTAs
  • Income from personal services
  • Property related income, capital gains, other income, beneficial ownership and capital
  • Anti-avoidance and administrative provisions

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.
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Study Levels

Undergraduate Study Postgraudate Study Postgraduate Research Study Non-Award Study

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