JJUA55224U International Taxation

The main pillar of the course is the OECD and the BEPS (Base Erosion and Profit Shifting) project.
The OECD Model Treaty for the Avoidance of Double Taxation (with some references also to the UN Model Treaty for Avoidance of Double Taxation) its commentaries, the expected upcoming unilateralisation of Double Tax Treaties and examples of some of the many Double Tax Treaties existing. A more thorough analysis of the interpretation rules in the Vienna Convention; a harmonized interpretation, the relevance of domestic law.

The BEPS refers to tax avoidance strategies that exploit gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations. Over 100 countries and jurisdictions are collaborating to implement the BEPS measures and tackle BEPS, see more here: http://www.oecd.org/tax/beps/beps-about.htm

The course will also deal with the implications of domestic law on interpretation, application and choices between applying Treaty relief or Domestic tax relief and the EU-initiatives on tax-avoidance, e.g. EU directives 2016/1164 on rules against tax avoidance.

The course builds on the BA-education courses; International Public Law, EU-law and Administrative Law.