Topics 9
Introduction to International Tax Law
This topic will provide an overview of international tax law, its importance, key principl...
Tax Residency and Domicile Rules
Premium content - upgrade to unlock
Double Taxation and Methods of Relief
Premium content - upgrade to unlock
Transfer Pricing Rules
Premium content - upgrade to unlock
Controlled Foreign Corporation (CFC) Rules
Premium content - upgrade to unlock
Tax Havens and Anti-Avoidance Measures
Premium content - upgrade to unlock
Tax Treaties and their Interpretation
Premium content - upgrade to unlock
BEPS (Base Erosion and Profit Shifting) Project
Premium content - upgrade to unlock
Case Studies in International Tax Planning
Premium content - upgrade to unlock
Unit Outline 40h
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
PreviewUnit 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
Unlock the full outline
Get the complete content outline, learning outcomes and assessment methods for International Tax Law.
KSh 20 one-off, or included with a plan
Learning Outcomes
Unlock the outline above to see learning outcomes.
Assessment Methods
Unlock the outline above to see assessment methods.
Study Materials
No notes yet
Notes will appear here once uploaded.
No questions yet
Practice questions will appear here.
Get Study Materials
CATs
Loading…
Assignments
Loading…
Exam Papers
Loading papers…