4108270: C15 International Taxation

Description

The course of International Taxation comprehensively covers aspects of tax planning and
international taxation.

The course starts with an introduction and definition of tax planning from a company’s perspective, it provides a comprehensive understanding of the impact of taxation on investment decisions and capital structures. In this context the concept of neutral taxation is also covered.

Additionally the students will learn to compare dividends and share repurchase, and they will quantify the tax disadvantage of dividends.

Aspects of international business taxation will also be discussed. The lecture provides a comprehensive understanding about the fundamentals of international taxation.

Two case studies in domestic and cross-border tax planning will complement the course. In doing so, the impact of financing choices, different forms of profit, the choice of legal group structure, holding activities, and intellectual property management will be discussed in the context of cross-border tax planning.

Additionally, the impact of specific tax rules, such as anti-avoidance rules, are discussed in the tax planning case studies.

Learning Outcomes

After completion of the course, the students

• are familiar with the fundamentals of international business taxation and aspects of cross-border tax planning.
• have extensive knowledge regarding the taxation of cross-border investments and the allocation of profits.
• will comprehend the instruments of international tax planning, will understand and apply target variables for international tax burden comparisons.
• will understand the tax treatment of leases and will have extensive knowledge regarding the evaluation of leasing terms with taxation.

Lectures Method

Interactive lecture with cases.

Materials

A comprehensive list of literature is available on moodle. In addition lecture material, cases, and illustrations of facts relating to the exercises as well as possible further materials are also available on moodle.

All the recommended literature is available in the university library.

Comments

Course Structure

The course is structured in three major sections covering the following topics:

Part I: National Tax Planning

• Taxation and investment decisions, tax paradox, neutral taxation
• Debt and taxes, MM-Theorem with tax
• Financial distress and taxes
• Payout policy and taxes
• Taxation and business valuation
• Taxation and leasing

• Fundamentals of International Taxation
• Taxation of Cross-Border Investments
• Allocation of Profits

• Introduction to International Tax Planning
• Target Variables for International Tax Burden Comparisons
• Case Studies on Domestic Tax Planning: Financing of Corporations in Different EU Member States and the United States
• Case Studies on Cross-Border Tax Planning