International Taxation

Code

2519

Academic unit

null

Department

null

Credits

3,5

Teacher in charge

António Neves, Pedro Fugas, Vera Figueiredo, Miguel Puim, Rita Vaz, Carolina Ferreira

Teaching language

English

Objectives

Enable students to understand the main concepts in International Taxation, as well as some tax planning techniques in terms of Holdings, IP and Financing structures.

Prerequisites

N/A

Subject matter

Week 1 - 9 September 2016, from 5.30pm to 8.30pm - Main principles and concepts - ANTÓNIO NEVES

Tax residency rules

Income source rules

OECD Model Tax Convention

Double taxation

Elimination of double taxation

Branch profits remittance tax

EU Directives on dividends, interest and royalties

EU Merger Directive

Tax consolidation

Week 2 - 16 September 2016, from 5.30pm to 8.30pm - Holdings and financing - MIGUEL PUIM

Holding companies

Redomiciliation of companies

Financing

Week 3 - 23 September 2016, from 5.30pm to 8.30pm - Practical case # 1 - RITA VAZ + EY Luxembourg

Week 4 - 30 September 2016, from 5.30pm to 8.30pm - IP and Madeira - PEDRO FUGAS

IP regime

Madeira International Business Center (MIBC) tax regime

Comparison between Malta, Ireland, Luxembourg and Hungary

Week 5 - 7 October 2016, from 5.30pm to 8.30pm - Practical case # 2 - VERA FIGUEIREDO + EY Netherlands

Week 6 - 14 October 2016, from 5.30pm to 8.30pm - Anti-abuse measures - CAROLINA FERREIRA

General anti-abuse rule

Specific anti-abuse provisions (dividends, interest, royalties, restructuring)

Beneficial owner

Treaty shopping

BEPS

Bibliography

OECD Model Tax Treaty Commentaries

EU Parent-Subsidiary Directive

EU Interest & Royalties Directive

EU Merger Directive

Van Raad, K. Materials on International, TP and EU Tax Law 2015-2016. Volume 1 (Leiden: International Tax Centre, 2015)

Miller, A. and Oats, L. Principles of International Taxation (Bloomsbury Professional, 5th edition, 2016)

Arnold, Brian J. and McIntyre, Michael J., International Tax Primer, Kluwer Law International, 2002, 2nd ed.

Harris, Peter, Corporate Tax Law - Structure, Policy and Practice, Cambridge University Press, 2013

BEPS Action Plan and Reports - available from www.oecd.org/ctp/beps.htm

Read articles 33, 34, 35, 36 and 36-A of the Portuguese Tax Incentive Code ("Estatuto dos Benefícios Fiscais")

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

ASSESSMENT.

The Final Exam is mandatory and must cover the entire span of the course. Its weight in the final grade can be between 30 to 70%. The remainder of the evaluation can consist of class participation, midterm exams, in class tests, etc. Overall, written in class assessment (final exam, midterm) must have a weight of at least 50%.

Courses

• Masters in Economics