International Taxation
Code
2519
Academic unit
null
Department
null
Credits
null
Teacher in charge
Carlos Loureiro
Teaching language
Objectives
The aim of this course is to provide participants with basic mechanisms of international taxation and source rules, covering Portuguese tax aspects, EU law and international tax principles. The basis provided should prove a useful tool for tax practitioners. The main topics covered in the course are the following:
- The limits of tax planning
- International double taxation when and how does it occur
- Identification and analysis of mechanisms to mitigate the double taxation
- OECD Model Tax Convention
- EU Tax Directives
- International tax planning
- Special Purpose Vehicles
- Madeira Free Zone
- Anti-abuse measures/Economic Substance
- CFC rules
- Thin capitalization rules
- Transfer pricing rules
Prerequisites
Subject matter
Bibliography
- Ault, Hugh, The role of the OECD commentaries in the interpretation of tax treaties, in Essays in
International Taxation to Sydney Roberts, 1993;
- Baker, Philip, Double Taxation Conventions, Sweet & Maxwell, 2004;
- Jones, John F. Avery (et al.), Tax Law: Rules or Principles, in Fiscal Studies , Vol. 17, n.º 3, 1996;
- Rohatgi, Roy, Basic International Taxation, Londres, 2002;
- Xavier, Alberto, Direito Tributário Internacional , Almedina, 2007;
- Vogel, Klaus, On double taxation conventions - A commentary to the OECD, UN and US Model Conventions for the avoidance of double taxation of income and capital, Vol. I e II, 1991;
- OECD Model Tax Convention on Income and on Capital, OECD, 2014;
- Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, OECD, 2010 ;
- Class handouts;
- Exercises and cases to discuss in class;
- PowerPoint slides for the lectures.
Teaching method
The course will use the business case method and a final business case study will be provided in order to enable participants to gain confidence in applying the skills acquired during the course.
Evaluation method
The evaluation of students will be made on the basis of the following criteria:
- Final exam (70%)
- Attendance to classes (10%)
- Participation during classes, including the case studies (20%)