Tax Treaties Special Issues (LAWS6946)


This unit of study considers a number of specialised topics in the area of tax treaties, largely reflecting the work of the OECD and United Nations on tax treaties currently and in the last decade, particularly the OECD/G20 project on Base Erosion and Profit Shifting (BEPS). Topics covered include a selection of: OECD and UN policy development processes, permanent establishment, high value services and the digital economy, transfer pricing, harmful tax practices, treaty abuse, non-discrimination, entities and tax treaties (especially partnerships and collective investment vehicles), transparency and assistance in collection, dispute resolution, BEPS multilateral instrument. The goal of this unit is to provide in depth analysis of the policy and practical issues in recent tax treaty developments. Upon completion of this unit, students will have a detailed understanding of the current driving forces and issues in the development of tax treaties and other international tax standards.

Our courses that offer this unit of study

Further unit of study information


1x2-hr lecture/week


3000wd essay (30%) and 2hr exam or 7000wd essay (70%)

Faculty/department permission required?


Unit of study rules

Assumed knowledge

It is assumed that students undertaking this unit have an understanding of Australian income taxation law commensurate with that which would be obtained from completing undergraduate study in Australian taxation law or five years working with Australian tax law in a law or accounting practice in an industry role or in the Australian Taxation Office. For students who do not have such knowledge or work experience they first should undertake LAWS6825 Introduction to Australian Business Tax before enrolling in this unit.

Study this unit outside a degree

Non-award/non-degree study

If you wish to undertake one or more units of study (subjects) for your own interest but not towards a degree, you may enrol in single units as a non-award student.

Cross-institutional study

If you are from another Australian tertiary institution you may be permitted to underake cross-institutional study in one or more units of study at the University of Sydney.