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DRPS : Course Catalogue : School of Law : Law

Postgraduate Course: Principles of International Taxation (LAWS11307)

Course Outline
SchoolSchool of Law CollegeCollege of Humanities and Social Science
Course typeOnline Distance Learning AvailabilityAvailable to all students
Credit level (Normal year taken)SCQF Level 11 (Postgraduate) Credits20
Home subject areaLaw Other subject areaNone
Course website Taught in Gaelic?No
Course descriptionThis course provides an introduction to the issues surrounding the taxation of cross-border activities, which is an increasingly important topic.
The course will consider the key concepts of international taxation, the problems caused by the overlap and gaps of domestic tax systems in an international environment, and some solutions, for example through double taxation agreements. Emphasis will be on the OECD model treaty. Consideration will be given to the operation of double taxation agreements in practical situations. The focus will be on direct taxation (particularly income and corporation tax) but indirect taxation will also be covered.
This course will cover most of the topics prescribed for the Principles of International Taxation paper in the Advanced Diploma of International Taxation, offered by the Chartered Institute of Taxation.
Students who take this course will benefit from having studied or having had some experience of taxation in a domestic situation, but this is not absolutely necessary providing some extra reading is undertaken at the start of the course.

Entry Requirements (not applicable to Visiting Students)
Pre-requisites Co-requisites
Prohibited Combinations Other requirements Please contact the distance learning team at
Additional Costs None
Information for Visiting Students
Pre-requisitesPlease contact the distance learning team at
Displayed in Visiting Students Prospectus?No
Course Delivery Information
Delivery period: 2013/14 Semester 1, Available to all students (SV1) Learn enabled:  Yes Quota:  None
Web Timetable Web Timetable
Class Delivery Information This course is taught by distance learning.
Course Start Date 16/09/2013
Breakdown of Learning and Teaching activities (Further Info) Total Hours: 200 ( Seminar/Tutorial Hours 40, Programme Level Learning and Teaching Hours 4, Directed Learning and Independent Learning Hours 156 )
Additional Notes
Breakdown of Assessment Methods (Further Info) Written Exam 0 %, Coursework 100 %, Practical Exam 0 %
No Exam Information
Summary of Intended Learning Outcomes
Through the use of primary sources, secondary literature and case studies, the course aims to:

1. Promote an understanding of the international tax environment and the challenges thereof;
2. Explore the solutions to these challenges;
3. Consider and analyse current international tax practice

By the end of the module students should be able to:
1. Understand the main challenges of the operation of domestic tax systems in a global environment;
2. Engage in debate as the efficacy of the different solutions;
3. Identify and assess the tax risks of particular cross-border operations.
Assessment Information
One exercise of up to 4,000 words (60%); one individual assignment (20%); contribution to weekly online discussions throughout the semester (20%). The exercise will involve the analysis of the tax issues of a practical problem.
Requirements for all module assessment will be outlined to students within the individual modules at the start of each semester.
Special Arrangements
This course is taught by distance learning.
Additional Information
Academic description Not entered
Syllabus 1. Basic principles of international taxation
2. Legal context of international taxation and double taxation agreements
3. Residence
4. Taxation of cross border business
5. Taxation of cross border employment income and Investment income
6. Double tax relief
7. Transfer pricing and thin capitalisation
8. International tax avoidance
9. Arm┐s length principle vs. unitary taxation
10.Cross border issues of indirect taxation
Transferable skills Not entered
Reading list Not entered
Study Abroad Not entered
Study Pattern Not entered
KeywordsNot entered
Course organiserMs Sandra Eden
Tel: (0131 6)50 2627
Course secretaryMs Clare Polson
Tel: (0131 6)51 4411
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