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Unit of study_
LAWS6129: Taxation of Offshore Operations
2025 unit information
This is an advanced unit suitable for experienced tax practitioners who wish to extend their Australian tax law knowledge. The unit examines Australias rules for taxing the income earned from offshore operations. The unit examines the taxation of conducting business and holding investments offshore through foreign branches companies trusts partnerships and hybrid entities. It also examines the repatriation of profits from these entities the treatment of the cost of financing these operations and the consequences of offshore reorganisations and relocations. The unit examines in detail Australias CFC rules transferor trust regime, the FITO regime thin capitalisation rules and foreign hybrid rules. Refer to the Sydney Law School timetable - https://canvas.sydney.edu.au/courses/4533/pages/postgraduate-lecture-timetable
Unit details and rules
Managing faculty or University school:
Sydney Law School
| Study level | Postgraduate |
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| Academic unit | Law |
| Credit points | 6 |
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Prerequisites:
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None |
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Corequisites:
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None |
| Prohibitions:
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None |
| Assumed knowledge:
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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 Students who do not have such knowledge or work experience should undertake LAWS6825 Fundamentals of Australian Taxation before enrolling in other units. For students who have not studied Australian law it is recommended that they undertake LAWS6252 Legal Reasoning and the Common Law System before enrolling in LAWS6825 and this unit. The Completion of LAWS6209 Australian International Taxation will provide students without such knowledge or work experience with additional knowledge and skills that will assists in successfully completing this unit |
At the completion of this unit, you should be able to:
- LO1. Critically analyse the policy underlying the legal rules on taxation of offshore operations
- LO2. Analyse the current legal rules on taxation of offshore operations
- LO3. Interpret and predict the implications of other legal rules on taxation applicable to offshore operations, including potential future developments
- LO4. Apply the legal rules on taxation of offshore operations to resolve practical problems, incorporating the assessment of risks and identification of optimal solutions
Unit availability
This section lists the session, attendance modes and locations the unit is available in. There is a unit outline for each of the unit availabilities, which gives you information about the unit including assessment details and a schedule of weekly activities.
The outline is published 2 weeks before the first day of teaching. You can look at previous outlines for a guide to the details of a unit.
| Session | MoA ? | Location | Outline ? |
|---|---|---|---|
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Semester 2b 2025
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Block mode | Camperdown/Darlington, Sydney |
Outline unavailable
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Modes of attendance (MoA)
This refers to the Mode of attendance (MoA) for the unit as it appears when you’re selecting your units in Sydney Student. Find more information about modes of attendance on our website.
