730-399 Principles of International Taxation

Taxation Law

The subject will introduce students to:

• the fundamental principles of international taxation law;

• the general operation of international tax treaties;

• the 'arms length principle' applicable to international transfer pricing;

• the policy issues faced by nation states in protecting national tax bases while providing relief from double taxation of international transactions, and the methods by which Australia and other nation states address these policy issues;

• the policy issues faced by nation states in controlling international tax avoidance, and the methods by which Australia and other nation states address these policy issues;

• the policy issues faced by nation states in constructing international tax rules which maintain tax revenues and tax equity at the national level, while promoting international trade and investment, and the methods by which Australia and other nation states address these policy issues.

A one-hour open-book in-class test 10% (to be held after the mid-semester break) and a final examination three hours 90%.

• Deutsch, Fundamental Tax Legislation. ATP 2006, with CD-rom (or equivalent).
• Kobetsky, O'Connell, Stewart, Income Tax: Text, Materials and Essential Cases. Federation Press 2005, 5th ed.