International Tax Law
Unit Outlines

International Tax Law

AI Generated Advanced 40 hours 9 topics

Learning Objectives

5 objectives
  • Understand the fundamental principles and importance of international tax law and tax treaties.
  • Analyze criteria for tax residency, domicile, and their implications on international taxation.
  • Examine double taxation issues and evaluate methods for relief including tax treaties and unilateral measures.
  • Explore transfer pricing, Controlled Foreign Corporation rules, and anti-avoidance measures to prevent tax base erosion.
  • Evaluate international initiatives such as the OECD BEPS project and interpret tax treaty provisions through case studies.

Content Outline

Preview

Unit 1734: International Tax Law

1. Introduction to International Tax Law

  • Overview and significance of international tax law
  • Key principles governing international taxation
  • Role and relevance of tax treaties in cross-border taxation

2. Tax Residency and Domicile Rules

  • Definition and importance of tax residency
  • Criteria for determining residency of individuals
  • Residency rules for entities (corporate residency)
  • Concept of domicile and its impact on tax obligations
  • Conflicts and tie-breaker rules in residency determination

3. Double Taxation and Methods of Relief

  • Understanding double taxation: economic vs juridical
  • Consequences of double taxation on taxpayers and economies
  • Methods of relief:
    • Tax treaties (bilateral agreements)
    • Unilateral relief measures
    • Tax credits and exemptions
  • Interaction between domestic laws and international agreements

4. Transfer Pricing Rules

  • Definition and purpose of transfer pricing regulations
  • Arm’s length principle and its application
  • Methods for determining transfer prices
  • Documentation and compliance requirements
  • Challenges in enforcement and dispute resolution

5. Controlled Foreign Corporation (CFC) Rules

  • Objectives of CFC rules in preventing profit shifting
  • Definition and identification of CFCs
  • Types of income targeted (e.g., passive income)
  • Mechanisms of CFC taxation
  • Impact on multinational corporations and tax planning

6. Tax Havens and Anti-Avoidance Measures

  • Characteristics and use of tax havens
  • Tax avoidance vs tax evasion
  • Risks and implications for international tax compliance
  • Anti-avoidance rules:
    • General anti-avoidance rules (GAAR)
    • Specific anti-avoidance rules (e.g., substance requirements)
  • International cooperation against aggressive tax planning

7. Tax Treaties and their Interpretation

  • Purpose and structure of tax treaties
  • Allocation of taxing rights between contracting states
  • Key treaty provisions (e.g., residence, permanent establishment, dividends, interest, royalties)
  • Interpretation principles:
    • Vienna Convention on the Law of Treaties
    • OECD Model Tax Convention guidance
  • Resolving treaty disputes and mutual agreement procedures

8. BEPS (Base Erosion and Profit Shifting) Project

  • Background and rationale for the OECD BEPS project
  • Common BEPS strategies employed by multinational enterprises
  • Key BEPS actions and measures:
    • Treaty abuse prevention
    • Transfer pricing documentation
    • Country-by-country reporting
  • Impact on international tax policy and compliance

9. Case Studies in International Tax Planning

  • Analysis of real-world multinational tax planning structures
  • Application of tax residency and treaty rules
  • Transfer pricing controversies and resolutions
  • Use of CFC and anti-avoidance rules in practice
  • Evaluation of BEPS compliance efforts
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Quick Information

Unit International Tax Law
Difficulty Advanced
Duration40 hours
Topics9
CreatedJul 19, 2026
GeneratedJul 19, 2026 20:09

Prerequisites

  • Basic understanding of domestic taxation principles
  • Familiarity with corporate finance and accounting concepts
  • Introductory knowledge of international law

Recommended Resources

  • OECD Model Tax Convention on Income and on Capital (latest edition)
  • OECD BEPS Project Reports and Action Plans
  • "International Taxation" by Philip Baker (textbook)
  • "Transfer Pricing and Corporate Taxation" by Elizabeth King
  • Journal of International Taxation articles on tax treaties and anti-avoidance
  • Online resources from the International Fiscal Association (IFA)

Unit Topics

9
Introduction to International Tax Law
This topic will provide an overview of international tax law, its importance, key principles, and th...
Tax Residency and Domicile Rules
This topic will cover the criteria for determining tax residency of individuals and entities, as wel...
Double Taxation and Methods of Relief
This topic will explore the issue of double taxation, types of double taxation (economic, juridical)...
Transfer Pricing Rules
This topic will discuss transfer pricing regulations aimed at preventing tax evasion through the man...
Controlled Foreign Corporation (CFC) Rules
This topic will examine CFC rules designed to tax passive income earned by foreign subsidiaries of a...
Tax Havens and Anti-Avoidance Measures
This topic will address the use of tax havens for tax avoidance purposes, the implications for inter...
Tax Treaties and their Interpretation
This topic will delve into the purpose and structure of tax treaties, the allocation of taxing right...
BEPS (Base Erosion and Profit Shifting) Project
This topic will cover the OECD's BEPS project, focusing on the strategies used by multinational ente...
Case Studies in International Tax Planning
This topic will involve analyzing real-world case studies to understand how multinational companies...