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DRPS : Course Catalogue : School of Law : Law

Postgraduate Course: Principles of International Taxation (LAWS11314)

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 Credits5 ECTS Credits2.5
SummaryThis 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 and additional reading will be recommended for the few topics which are not covered.

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.
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 should 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
Course Start Date 18/09/2017
Timetable Timetable
Learning and Teaching activities (Further Info) Total Hours: 50 ( Seminar/Tutorial Hours 10, Programme Level Learning and Teaching Hours 1, Directed Learning and Independent Learning Hours 39 )
Assessment (Further Info) Written Exam 0 %, Coursework 100 %, Practical Exam 0 %
Additional Information (Assessment) Students must log in on a regular basis throughout the course, sufficient to have covered all modules; and they must contribute constructively to at least one online discussion in most weeks. They will also be assessed on two written essays of 1500 words each.
Feedback Students can expect to receive timely feedback on their assessment.
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 Miller and Oats, Principles of International Taxation, 5th Edition, 2016, published by Bloomsbury Professional. The previous edition, which can still be used for most topics, is available as an e-book through the university 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.
KeywordsNot entered
Course organiserDr Luca Cerioni
Tel: (131 6)50 6952
Course secretaryMs Clare Polson
Tel: (0131 6)51 9704
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