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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
Credit level (Normal year taken)SCQF Level 11 (Postgraduate)
Course typeOnline Distance Learning AvailabilityNot available to visiting students
SCQF Credits20 ECTS Credits10
SummaryThis course provides an introduction to the issues surrounding the taxation of cross-border activities and incomes, 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.
Course description Session 1: Basic principles of international taxation
Session 2: Legal context of international taxation and double taxation agreements
Session 3: Residence
Session 4: Taxation of cross border business
Session 5: Types of income and distributive rules
Session 6: Transfer pricing and thin capitalisation
Session 7: Double tax relief
Session 8: International tax evasion and avoidance
Session 9: Tax avoidance, ALP vs FA?
Session 10: Cross border issues of indirect taxation
Entry Requirements (not applicable to Visiting Students)
Pre-requisites Co-requisites
Prohibited Combinations Other requirements Please contact the distance learning team at
Additional Costs Students must have regular and reliable access to the internet
Course Delivery Information
Academic year 2017/18, Not available to visiting students (SS1) Quota:  None
Course Start Semester 1
Timetable Timetable
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 )
Assessment (Further Info) Written Exam 0 %, Coursework 100 %, Practical Exam 0 %
Additional Information (Assessment) One essay of up to 4,000 words (60%); one individual assignment (20%); contribution to weekly online discussions throughout the semester (20%).

Requirements for all module assessments will be outlined to students at the start of each semester.

Feedback Students can expect to receive timely feedback on their assessments
No Exam Information
Learning Outcomes
On completion of this course, the student will 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.
Reading List
You will regularly reference: A.Miller and L.Oats, Principles of International Taxation, published by Bloomsbury Professional, 2016, 5th Edition, available in the Library (it is also possible to use the previous edition, 4th Edition, 2014. which is available as an e-book through the Library Catalogue).

A list of key module readings will be available in advance of the module. Detailed reading lists are then available each week.
Additional Information
Course URL
Graduate Attributes and Skills Students will develop their skills and abilities in:

1. Research and enquiry, through e.g. selecting and deploying appropriate research techniques;
2. Personal and intellectual autonomy, e.g. developing the ability to independently assess the relevance and importance of primary and secondary sources;
3. Communication, e.g. skills in summarising and communicating information and ideas effectively in written form;
4. Personal effectiveness, e.g. working constructively as a member of an online community;
5. Students will also develop their technical/practical skills, throughout the module, e.g. in articulating, evidencing and sustaining a line of argument, and engaging in a convincing critique of another¿s arguments.
Special Arrangements This course is taught by distance learning.
Additional Class Delivery Information This course is taught by distance learning.
Keywordstaxation,international allocation of taxing powers,cross-border activities and incomes
Course organiserDr Luca Cerioni
Tel: (131 6)50 6952
Course secretaryMs Clare Polson
Tel: (0131 6)51 9704
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