This advanced 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.
Oct 17-19 and 22, 23 (9-3.30)
3000wd essay (30%) and 2hr exam or 7000wd essay (70%)
As this is an advanced unit, it is assumed that students undertaking this unit have successfully completed LAWS6177 Tax Treaties