This course provides a broad understanding of the legal and economical aspects of the taxation of income and capital in international setting as well as a demon-stration of how the basic building blocks of most tax systems can generate tax planning opportunities.
The course is based on general principles of international taxation and uses examples from domestic taxation to illustrate them. The course illustrates these concepts by referring to international instruments and the legis-lation in specific countries.
In particular, the course will examine key provisions of the OECD Model Convention with respect to Taxes on Income and on Capital (the Model Convention) as the global benchmark for Double Taxation Agree-ments concluded by and applicable to fiscal jurisdictions.
This Model Convention will be contrasted with the UN Convention.
Principles of the U.S., French and German International Taxation will be discussed as well. The course introduces the concept of income/capital taxation and focuses on residency, applicable deductions, and anti-avoidance legislation.
Students will become familiar with tax treaties and other techniques aimed at the avoidance of double taxation.
Towards this structural background the course aims at raising students’ awareness of basic strategies applied in tax optimization schemes.
In times of evolving attitudes towards some aspects of international taxation the course concludes on the most salient topics in the current discussion.