Outline

Overview

Taxation strategy of an international business has a significant impact on not only the overall financial performance of the enterprise but also the quantum of tax revenue that governments can collect. The increasing globalisation and integration of operations of multinational enterprises, together with the ingenuity of the army of tax advisors, provides ample opportunities for international tax planning. This unit introduces students to international tax principles and practices. Students will learn how the international tax rules are implemented in practice, and tax strategies that international businesses can adopt to minimise their global tax liabilities. Case studies on major multinational enterprises, such as Apple and Google, will be used to analyse and evaluate the international tax rules and business tax strategies. This unit will cover the fundamental residence and source principles, the taxation of inbound and outbound investments, the taxation of international finance, and common international tax strategies of multinational enterprises, including tax arbitrage between tax rules of entity classifications, the tax treatment of debt and equity, and transfer pricing.

Unit details and rules

Academic unit
Credit points	6
Prerequisites ?	None
Corequisites ?	None
Prohibitions ?	None
Assumed knowledge ?	None
Available to study abroad and exchange students	Yes

Teaching staff

Coordinator	Ka Ting, antony.ting@sydney.edu.au
Lecturer(s)	Ka Ting, antony.ting@sydney.edu.au

Type	Description	Weight	Due	Length
Final exam (Open book)	Final exam Written exam	50%	Formal exam period	2 hours
Outcomes assessed:
In-semester test (Open book)	Mid-semester exam Written exam	20%	Week 07 Due date: 15 Oct 2020 at 15:00	50 minutes
Outcomes assessed:
Small continuous assessment	Individual assignment Written task	30%	Weekly	600 words
Outcomes assessed:
= Type C final exam ? = Type C in-semester exam ?

Assessment summary

Individual assignment: You have to submit answers to a minimum of 2 and a maximum of 3 weekly exercises of your choice out of the total 9 exercises. Each answer is worth 15% and must be submitted before the corresponding lecture in which the answer is discussed. If you submit 3 answers, you will get the marks of the 2 best answers. This assessment is designed to provide timely feedback to you, aiming to supplement your learning. The feedback provided to your answer will be useful to improve your answers to subsequent exercises, as well as mid-semester test and final exam.
Mid-semester exam: This open-book exam is designed to assess your understanding of the topics covered in previous lectures, and equally importantly, to provide timely feedback on your learning.
Final exam: This is an open-book exam designed to assess your overall understanding of the tax law and your ability to apply the tax rules to commercial structures and transactions. The exam may cover any topic discussed in the semester.

Detailed information for each assessment can be found on Canvas.

Assessment criteria

The University awards common result grades, set out in the Coursework Policy 2014 (Schedule 1).

As a general guide, a high distinction indicates work of an exceptional standard, a distinction a very high standard, a credit a good standard, and a pass an acceptable standard.

Result name	Mark range	Description
High distinction	85 - 100	Awarded when you demonstrate the learning outcomes for the unit at an exceptional standard, as defined by grade descriptors or exemplars outlined by your faculty or school.
Distinction	75 - 84	Awarded when you demonstrate the learning outcomes for the unit at a very high standard, as defined by grade descriptors or exemplars outlined by your faculty or school.
Credit	65 - 74	Awarded when you demonstrate the learning outcomes for the unit at a good standard, as defined by grade descriptors or exemplars outlined by your faculty or school.
Pass	50 - 64	Awarded when you demonstrate the learning outcomes for the unit at an acceptable standard, as defined by grade descriptors or exemplars outlined by your faculty or school.
Fail	0 - 49	When you don’t meet the learning outcomes of the unit to a satisfactory standard.

For more information see guide to grades.

Late submission

In accordance with University policy, these penalties apply when written work is submitted after 11:59pm on the due date:

Deduction of 5% of the maximum mark for each calendar day after the due date.
After ten calendar days late, a mark of zero will be awarded.

Academic integrity

The Current Student website provides information on academic integrity and the resources available to all students. The University expects students and staff to act ethically and honestly and will treat all allegations of academic integrity breaches seriously.

We use similarity detection software to detect potential instances of plagiarism or other forms of academic integrity breach. If such matches indicate evidence of plagiarism or other forms of academic integrity breaches, your teacher is required to report your work for further investigation.

Use of generative artificial intelligence (AI) and automated writing tools

You may only use generative AI and automated writing tools in assessment tasks if you are permitted to by your unit coordinator. If you do use these tools, you must acknowledge this in your work, either in a footnote or an acknowledgement section. The assessment instructions or unit outline will give guidance of the types of tools that are permitted and how the tools should be used.

Your final submitted work must be your own, original work. You must acknowledge any use of generative AI tools that have been used in the assessment, and any material that forms part of your submission must be appropriately referenced. For guidance on how to acknowledge the use of AI, please refer to the AI in Education Canvas site.

The unapproved use of these tools or unacknowledged use will be considered a breach of the Academic Integrity Policy and penalties may apply.

Studiosity is permitted unless otherwise indicated by the unit coordinator. The use of this service must be acknowledged in your submission as detailed on the Learning Hub’s Canvas page.

Outside assessment tasks, generative AI tools may be used to support your learning. The AI in Education Canvas site contains a number of productive ways that students are using AI to improve their learning.

Learning support

Simple extensions

If you encounter a problem submitting your work on time, you may be able to apply for an extension of five calendar days through a simple extension.  The application process will be different depending on the type of assessment and extensions cannot be granted for some assessment types like exams.

Special consideration

If exceptional circumstances mean you can’t complete an assessment, you need consideration for a longer period of time, or if you have essential commitments which impact your performance in an assessment, you may be eligible for special consideration or special arrangements.

Special consideration applications will not be affected by a simple extension application.

Using AI responsibly

Co-created with students, AI in Education includes lots of helpful examples of how students use generative AI tools to support their learning. It explains how generative AI works, the different tools available and how to use them responsibly and productively.

Weekly schedule

WK	Topic	Learning activity
Week 01	Overview	Seminar (3 hr)
Week 02	Residence and source principles	Seminar (3 hr)
Week 03	Taxation of companies	Seminar (3 hr)
Week 04	Taxation of company groups	Seminar (3 hr)
Week 05	International taxation of residents and non-residents	Seminar (3 hr)
Week 06	Tax treaty	Seminar (3 hr)
Week 08	Transfer pricing	Seminar (3 hr)
Week 09	Tax avoidance using interest deductions	Seminar (3 hr)
Week 10	Controlled foreign companies	Seminar (3 hr)
Week 11	International tax avoidance - part 1	Seminar (3 hr)
Week 12	International tax avoidance - part 2	Seminar (3 hr)

Attendance and class requirements

Lecture recordings: All lectures are recorded and will be available on Canvas for student use. Please note the Business School does not own the system and cannot guarantee that the system will operate or that every class will be recorded. Students should ensure they attend and participate in all classes.

Study commitment

Typically, there is a minimum expectation of 1.5-2 hours of student effort per week per credit point for units of study offered over a full semester. For a 6 credit point unit, this equates to roughly 120-150 hours of student effort in total.

Required readings

Sadiq, et al, Principles of Taxation Law (2020, Thomson, Sydney)
Pinto, et al, Fundamental Tax Legislation (2020, Thomson, Sydney)
Deutsch, et al, Australian Tax Handbook 2020 (available at Library’s “Checkpoint” database)

Learning outcomes

Learning outcomes are what students know, understand and are able to do on completion of a unit of study. They are aligned with the University's graduate qualities and are assessed as part of the curriculum.

Outcomes
Graduate qualities

At the completion of this unit, you should be able to:

LO1. analyse and critically evaluate alternative tax policies based on a good understanding of key taxation law concepts and major constraints in business environment
LO2. determine tax implications of business transactions and structures by applying knowledge of tax law and practice for businesses
LO3. compute tax liabilities for business entities and their interest holders
LO4. refine academic writing.

Graduate qualities

The graduate qualities are the qualities and skills that all University of Sydney graduates must demonstrate on successful completion of an award course. As a future Sydney graduate, the set of qualities have been designed to equip you for the contemporary world.

GQ1	Depth of disciplinary expertise Deep disciplinary expertise is the ability to integrate and rigorously apply knowledge, understanding and skills of a recognised discipline defined by scholarly activity, as well as familiarity with evolving practice of the discipline.
GQ2	Critical thinking and problem solving Critical thinking and problem solving are the questioning of ideas, evidence and assumptions in order to propose and evaluate hypotheses or alternative arguments before formulating a conclusion or a solution to an identified problem.
GQ3	Oral and written communication Effective communication, in both oral and written form, is the clear exchange of meaning in a manner that is appropriate to audience and context.
GQ4	Information and digital literacy Information and digital literacy is the ability to locate, interpret, evaluate, manage, adapt, integrate, create and convey information using appropriate resources, tools and strategies.
GQ5	Inventiveness Generating novel ideas and solutions.
GQ6	Cultural competence Cultural Competence is the ability to actively, ethically, respectfully, and successfully engage across and between cultures. In the Australian context, this includes and celebrates Aboriginal and Torres Strait Islander cultures, knowledge systems, and a mature understanding of contemporary issues.
GQ7	Interdisciplinary effectiveness Interdisciplinary effectiveness is the integration and synthesis of multiple viewpoints and practices, working effectively across disciplinary boundaries.
GQ8	Integrated professional, ethical, and personal identity An integrated professional, ethical and personal identity is understanding the interaction between one’s personal and professional selves in an ethical context.
GQ9	Influence Engaging others in a process, idea or vision.

Outcome map

Learning outcomes	Graduate qualities
Learning outcomes

Responding to student feedback

This section outlines changes made to this unit following staff and student reviews.

This unit has been improved continuously in response to comments and feedback in previous student surveys.

Additional information

Disclaimer

The University reserves the right to amend units of study or no longer offer certain units, including where there are low enrolment numbers.

To help you understand common terms that we use at the University, we offer an online glossary.

Current students

Overview

Overview

Unit details and rules

Teaching staff

Assessment

Assessment

Assessment summary

Assessment criteria

Late submission

Academic integrity

Learning support

Learning support

Simple extensions

Special consideration

Using AI responsibly

Weekly schedule

Weekly schedule

Attendance and class requirements

Study commitment

Required readings

Learning outcomes

Learning outcomes

Graduate qualities

Outcome map

Responding to student feedback

Responding to student feedback

Additional information

Additional information

Disclaimer

On this page

Useful links

Media

Student links

About us

Connect

Current students

CLAW6033: International Business Tax Strategy

Semester 2, 2020 [Normal day] - Camperdown/Darlington, Sydney

Overview

Overview

Unit details and rules

Teaching staff

Assessment

Assessment

Assessment summary

Assessment criteria

Late submission

Academic integrity

Learning support

Learning support

Simple extensions

Special consideration

Using AI responsibly

Weekly schedule

Weekly schedule

Attendance and class requirements

Study commitment

Required readings

Learning outcomes

Learning outcomes

Graduate qualities

Outcome map

Responding to student feedback

Responding to student feedback

Additional information

Additional information

Disclaimer

On this page

Useful links

Media

Student links

About us

Connect